Epstein Secrets

set forth in a Civil Complaint attached hereto as Exhibit ar attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A., deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions of justice, a

e theory of the requestor's case, or to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA 2003). In addition, Florida Rule of Civil Procedure 1.280(b)(3), does allow discovery of fact work product where the requesting party can show need and the inability to obtain the substantia

se and question his credibility, not because they will cause any undue prejudice because of their alleged late disclosure." Page 10 "A. Rothstein, Rosenfeldt and Adler E-mails Epstein identified and disclosed a number of emails from the Rothstein, Rosenfeldt and Alder firm that directly contradict sworn

ils), Edwards clearly waived any work-product protection he may have had by — among other compelling reasons -- his complete failure to comply with Florida Rule of Civil Procedure 1.280(b)(6). With Epstein's citation in his motion to the Fourth District Court of Appeal's controlling case of General Motors Corp v. Mc

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otion filed by 5 By KARA BERARD ROCKENBACH, ESQUIRE Epstein to remove the case from the trial 6 By SCOTT J. LINK, ESQUIRE ^ docket relative to Florida Rule of Civil 9 For Defendant/Counter-Plaintiff: Procedure 1.440 first. SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Yo