Epstein Secrets

:35 PM JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J, EDWARDS, Individually, and L.M., individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.502009CA040800XXXXMBAG JUDGE: HAFELE DEFENDANT/COUNTER-PLAINTIF

z, 785 So. 2d 589, 591 (Fla. 5th DCA 2001) ("[M]erely attaching an unswom document ... does not . . . satisfy the procedural strictures inherent in Florida Rule of Civil Procedure 1.510(e)."). Scarola and Edwards are veteran trial attorneys, are well aware of these Rules, and are more than familiar with the signific

ep JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendant(s). IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG MOTION FOR PROTECTIVE ORDER, OBJECTIONS

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

108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT R

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 way, that the court should grant us the access to the information. That's in Florida Rule of Civil Procedure 1.280(b)(4), and in Genovese versus Provident Life 74 So.3d 1064 Florida Supreme Court 2011. It's also established, Judge, under the la

JEFFREY EPSTErN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXAMAG MOTION FOR PROTECTIVE ORDER, OBJECTIONS

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