Epstein Secrets

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

here materials sought by a party 'would appear to be relevant to the subject matter of the pending action,' the information is fully discoverable." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So.2d 189, 194 (Fla. 2003) (citing to Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1988)) (emphasis added). Since Edwards is claimin

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

here materials sought by a party 'would appear to be relevant to the subject matter of the pending action,' the information is fully discoverable." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So.2d 189, 194 (Fla. 2003) (citing to Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1988)) (emphasis added). Since Edwards is claimin

n 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 is protected by

here is that personal financial material is discoverable in cases where "such information is relevant to subject matter of the pending litigation." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So. 2d 189, 194 (Fla. 2003); Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1998). When a party voluntarily puts his personal financia

n 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 is protected by

here is that personal financial material is discoverable in cases where "such information is relevant to subject matter of the pending litigation." Friedman v. Heart Institute of Port St. Lucie, Inc., 863 So. 2d 189, 194 (Fla. 2003); Epstein v. Epstein, 519 So. 2d 1042, 1043 (Fla. 3d DCA 1998). When a party voluntarily puts his personal financia