Epstein Secrets

objection again, Edwards was asked if he would assert the same objections to the questions, and both he and his counsel answered affirmatively. 2 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00799403 examination when a lawyer improperly uses speaking objections to pr

ort Lauderdale, FL 3330I• 954.467.1223 EFTA00799425 electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Suite 301 301 25 Attorneys for Epstein Tonja Haddad, M. • 315 SE 7th Street, Fort Lauderdal

dwards responded: "My objection to those previous questions would be my objection today." Deposition of Edwards dated 2013, page 98, lines 8-12. 3 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799404 question."). Edwards has impermissibly hidden behind unavailing p

0I• 954.467.1223 EFTA00799425 electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Suite 301 301 25 Attorneys for Epstein Tonja Haddad, M. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1

here materials sought by a party 'would appear to be relevant to the subject matter of the pending action,' the information is fully discoverable." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So.2d 189, 194 (Fla. 2003) (citing to Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1988)) (emphasis added). Since Edwards is claimin

objection again, Edwards was asked if he would assert the same objections to the questions, and both he and his counsel answered affirmatively. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585395 examination when a lawyer improperly uses speaking objections to prevent meaningf

ties on the attached service list, this September 25, 2017. 24 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585417 Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 Attorneys for

dwards responded: "My objection to those previous questions would be my objection today." Deposition of Edwards dated 2013, page 98, lines 8-12. 3 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585396 question."). Edwards has impermissibly hidden behind unavailing privileges and o

ervice list, this September 25, 2017. 24 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585417 Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 Attorneys for Epstein 25 Tonja Had

here materials sought by a party 'would appear to be relevant to the subject matter of the pending action,' the information is fully discoverable." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So.2d 189, 194 (Fla. 2003) (citing to Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1988)) (emphasis added). Since Edwards is claimin

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00799382 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

igation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301• EFTA00799385 during the time you were employed by RRA (or that is being claimed by the trust

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

here is that personal financial material is discoverable in cases where "such information is relevant to subject matter of the pending litigation." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So. 2d 189, 194 (Fla. 2003); Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1998). When a party voluntarily puts his personal financia

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585353 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

ation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, L.M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301 EFTA00585356 during the time you were employed by RRA (or that is being claimed by the truste

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

here is that personal financial material is discoverable in cases where "such information is relevant to subject matter of the pending litigation." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So. 2d 189, 194 (Fla. 2003); Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1998). When a party voluntarily puts his personal financia

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585374 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

ation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, L.M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301 EFTA00585377 during the time you were employed by RRA (or that is being claimed by the trustee

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

here is that personal financial material is discoverable in cases where "such information is relevant to subject matter of the pending litigation." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So. 2d 189, 194 (Fla. 2003); Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1998). When a party voluntarily puts his personal financia