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e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder
rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,
e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder
rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,
e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder
rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,
Entities connected to both the Florida Rules of Civil and the Plaintiff/Counter-Defendant

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSONJack Goldberger
PERSONJack Scarola
PERSONTonja Haddad Coleman
PERSONTHE CIRCUIT COURT
ORGANIZATIONPalm Beach Lakes Blvd
LOCATIONFred Haddad
PERSONMarc Nurik
PERSON
George W. Bush
PERSONAtterbury
ORGANIZATIONSearcy Denney Scarola
PERSONW. Chester Brewer
PERSONJai-Alai
PERSONJane Doe
PERSONFriedman v. Heart Institute of Port St. Lucie, Inc.
ORGANIZATIONFanner Jaffe Weissing Edwards
PERSONE.W.
PERSONLumber Co.
ORGANIZATION