Epstein Secrets

in TIG Insurance Corporation of America - 2 - EFTA00613623 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG (TIG) v. Johnson, 799 So.2d 339 (Fla. 4'h DCA 2001). Consequently, Epstein would like to set a motion directed toward the sufficiency of the Privilege Log. 6. Epst

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plainti

urring during the course of a judicial proceeding, if those acts bear some relation to the proceeding. Edwards urged the Court to fmd that Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA 2007), is in conflict with Wolfe, thereby allowing the Court to find that the privilege does not apply. However, Olson

5 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800000CMB-A0 Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. JPLAINTIFF/COUNTER-DEFENDANT JE

ce and documents between Epstein's counsel and Federal prosecutors violates an Order entered in Jane Doe No. 2. v. Epstein, Case No. 08-80893-Marra/Johnson on January 5, 2011. (See D.E. 226) (Ex. A attached hereto). Pursuant to that Order, Edwards is required to seek leave of court before filing or mak

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaint

by privilege, then a privilege log must be prepared and attached to the response, or the privilege is waived See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001) (stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the p

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA0408003OOO134B Judge David F. Crow JEFFREY EPSTEIN, PlaintiffiCounter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaint

ed on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may be grounds to determine that a

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. NOTICE OF HEARING (Specially Se

he Court finds the privilege log is insufficient on its face and does not comply with the requirements of F.R.C.P. 1.280(b)(5) and TIC Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). In all other respects the Motion is denied at this time." On May 8, 2012, Edwards provided Epstein with 163 pa

sor to Judge Crow). As it has evolved, Epstein's lawsuit against Edwards was dismissed and the lawsuit now 3 Specifically, on April 10, 2012, Judge David F. Crow (presiding over the Epstein lawsuit) entered an Order requiring Edwards to produce any non-privileged documents identified in paragraph 13 of Epste

urring during the course of a judicial proceeding, if those acts bear some relation to the proceeding. Edwards urged the Court to fmd that Olson v. Johnson, 96] So. 2d 356 (Fla. 2d DCA 2007), is in conflict with Wolfe, thereby allowing the Court to fmd that the privilege does not apply. However, Olson

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800)OOOCMB-AO Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. pLAINTIEF/COUNTER-DErENDANT igg

ntempt, may be levied against Epstein because Epstein has not violated a court order or engaged in any contumacious conduct demonstrated by Edwards. Johnson v. Bednar, 573 So. 2d 822 (Fla. 1991) (civil contempt is used to coerce an offending party into complying with a court order rather than to punish

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaint

r a legally sufficient privilege log under Fla. R. Civ. P. 1.280 (b)(5), as interpreted by the Fourth District Court of Appeal in TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Edwards' privilege log is insufficient on its face in many respects. In addition, although the Special Master

PM IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaint