Epstein Secrets

xpenses, deposition related costs, expert costs, etc.) that were incurred by_ysiu in the representation of you and/or your law firm in representing Jane Doe, M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and is

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

you may respond. Id. at p.100; line 15-22. THE WITNESS: I cannot respond. Id. at page 100; line 23. Q: Prior to the filing of the lawsuit against Jane Doe 1 and Jane Doe 2 against the United States Government, did you learn from any source, maybe a document, maybe a telephone call or a conversation that

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

expenses, deposition related costs, expert costs, etc.) that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

you may respond. Id. at p.100; line 15-22. THE WITNESS: I cannot respond. Id. at page 100; line 23. Q: Prior to the filing of the lawsuit against Jane Doe 1 and Jane Doe 2 against the United States Government, did you learn from any source, maybe a document, maybe a telephone call or a conversation that

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

expenses, deposition related costs, expert costs, etc.) that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder