Epstein Secrets

nd attorneys' fees. Next, the law is clear that Interrogatory responses are not filed with the court absent certain circumstances. Rule 1.340(e) of the Florida Rules of Civil Procedure specifically references Rule 2.425 of the Florida Rules of Judicial Administration and Rule 1.280(g) of the Florida Rules of Civil Procedure, and r

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

uments and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as use

T FOR PRODUCTION TO DEFENDANT (PUNITIVE DAMAGES) BRADLEY J. EDWARDS and PAUL G. CASSELL, by and through their undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby request Production from Defendant, ALAN M. DERSHOWITZ, of the documents and things described below for the purpose of inspe

cuments and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as use

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,

ttr-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to §768.79 of the Florida Statutes and Rule 1.442 of the Florida Rules of Civil Procedure, hereby files this Motion requesting that the Court enter an Order of entitlement to costs and attorneys' fees against Defendant/Counter- Plaintiff

ntitled to fees and costs. H. ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party

cuments and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as use

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,