Epstein Secrets

to effectuate their purpose), citing, Hickman v. Taylor, 329 U.S. 495, 501, 507 (1947). 21. Next, the

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs, Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their

to effectuate their purpose), citing, Hickman v. Taylor 329 U.S. 495, 501, 507 (1947). 15. Next, the r

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs, Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their

to effectuate their purpose), citing, Hickman v. Taylor, 329 U.S. 495, 501, 507 (1947). 14. Next, the

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1). see also Surf Drugs, Inc., v. Vermette 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their