Epstein Secrets

S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein Lilly Ann Sanchez, Esquire The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: (305)-503-5503 Fax: (305)-503-6801 Attorneys for Jeffrey Epst

ndant, REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGESI BRADLEY J. EDWARDS, by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and things described below for the purpose of inspection, copying,

rik, Es uire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phax. F Attorneys for Scott Rothstein Lilly Ann Sanchez, Esquire The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Pho Fax Attorneys for Jeffrey Epstein Tonja Haddad Colem Esquire

ndant, REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGES) BRADLEY J. EDWARDS, by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and things described below for the purpose of inspection, copying,

S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein Lilly Ann Sanchez, Esquire [email protected] The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: (305)-503-5503 Fax: (305)-503-6801 At

ndant, REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGESI BRADLEY J. EDWARDS, by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and things described below for the purpose of inspection, copying,

Epstein West P B h FL 33401-6170 Phone Fax: 6 EFTA00599576 From: Charles H. Uchtman Sent: Wednesday, February 16, 2011 10:20 AM To: Lilly Ann Sanchez; Robert Carney; Gary Farmer; Seth Lehrman Cc: Subject: MORE DOCUMENTS re Epstein As you know, Mr. Epstein's counsel served upon the Trustee a refi

So.2d 293, 296 (4th DCA 2006). "A party is required to file a log only if the information is `otherwise discoverable!" Gosman at 296 (referring to Florida Rule of Civil Procedure 1.280(b)(5)). Before a written objection to a discovery request is ruled upon, the documents are not "otherwise discoverable". Gosman at

st Palm Beach, FL 33401-6170 Phon=. Fax: 6 EFTA00283663 From: Charles H. Uchtman [mallto: Sent: Wednesday, February 16, 2011 10:20 AM To: Lilly Ann Sanchez; Robert Carney; Gary Farmer; Seth Lehrman Cc: Hmstettinatellsouth.net Subject MORE DOCUMENTS re Epstein As you know, Mr. Epstein's counsel served

So.2d 293, 296 (4th DCA 2006). "A party is required to file a log only if the information is `otherwise discoverable!" Gosman at 296 (referring to Florida Rule of Civil Procedure 1.280(b)(5)). Before a written objection to a discovery request is ruled upon, the documents are not "otherwise discoverable". Gosman at