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

vileged communication other than "Confidential Source," "RRA Staff," and "RRA Personnel." Such identifications violate the requirements set forth 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 200

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

g to Mr. Epstein. The objections are based 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 determ

5) of the Florida Rules of Civil Procedure as that Rule has been interpreted by the Fourth District Court of Appeal. 3. In TIG Insurance Corp. v. Johnson, 799 So. 2d 339 (Fla. 4'h DCA 2001), the court denied a writ of certiorari sought from an order requiring a party to produce documents because the

Dear Judge Carney: We have the following objections to the form of the Privilege Log produced by Farmer, Jaffe based on the standards set forth in TIG Insurance Corporation of America, 799 So. 2d 339, (Fla. 4th DCA 2001). We request until the close of business on Tuesday, March 1, 2011 to supplement these objections, if necessar