Epstein Secrets

ranscript at 50, 54, 91, 100-104, 114, 126,-127, 155, 170, 181, 184-187, 192, 198-202, 205-206, 208-210, 212, 215-217; Exhibit 1. Forty years ago, the Florida Supreme Court, in Surf Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), gave this general definition of work product saying what it is and what it is no

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

ed in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), explained what is covered by the work product privilege: [T]hose documents, pictu

DRAFT 213112 4:26 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-De

Fla. 1996) (citing Dodson v. Pend!, 390 So. 2d 704 (Fla. 1980); Suif Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970)). -"S ,r‘ II. In Elkins, the Florida Supreme Court commented on the purpose of pretrial discovery: Discovery was never intended to be used as a tactical tool to harass an adversary in a manner that

DRAFT IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT 5/1/118:14 PM IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN. Plaint

se in midst of the collapse of a firm in which he was a member, called Rothstein, Rosenfeldt & Adler, P.A. ("RRA"). 4. Rothstein was disbarred by the Florida Supreme Court on November 20, 2009. Subsequently, Rothstein was arrested, arraigned in federal court, pled guilty and ultimately was sentenced to fifty (50) year

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCO