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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
ts that this Court enter an Order Striking Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Objections to Epstein's Discovery Requests' and Compelling Edwards to produce documents and/or Interrogatory responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstan
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
ts that this Court enter an Order Striking Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Objections to Epstein's Discovery Requests' and Compelling Edwards to produce documents and/or Interrogatory responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstan
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
ts that this Court enter an Order Striking Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Objections to Epstein's Discovery Requests' and Compelling Edwards to produce documents and/or Interrogatory responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstan
Entities connected to both the Florida Rules of Civil and Compelling Edwards

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