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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
roduct where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this producti
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
roduct where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this producti
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
roduct where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this producti
Entities connected to both the Florida Rules of Civil and Vesta Fire Ins

Jeffrey Epstein
PERSONScott Rothstein
PERSON
Bradley Edwards
PERSONTHE CIRCUIT COURT
ORGANIZATIONJack Goldberger
PERSONTonja Haddad Coleman
PERSONJack Scarola
PERSON
George W. Bush
PERSONPalm Beach Lakes Blvd
LOCATIONAtterbury
ORGANIZATIONMarc Nurik
PERSONFred Haddad
PERSONJane Doe
PERSONW. Chester Brewer
PERSONFriedman v. Heart Institute of Port St. Lucie, Inc.
ORGANIZATIONFanner Jaffe Weissing Edwards
PERSONJai-Alai
PERSONSearcy Denney Scarola
PERSON
Scarlett Johansson
PERSONE.W.
PERSON