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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
uction of personal financial documents and information if shown to be relevant by the requesting party. Florida Gaming Corp. of Delaware v. American Jai-Alai, Inc., 673 So. 2d 523, 524 (Fla. 4th DCA 1996) (holding that the financial information at issue was relevant to the calculation of damages under th
ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of
ction of personal financial documents and information if shown to be relevant by the requesting party. Florida Gaming Corp. of Delaware v. American Jai-Alai, Inc., 673 So. 2d 523, 524 (Fla. 4th DCA 1996) (holding that the financial information at issue was relevant to the calculation of damages under the
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
uction of personal financial documents and information if shown to be relevant by the requesting party. Florida Gaming Corp. of Delaware v. American Jai-Alai, Inc., 673 So. 2d 523, 524 (Fla. 4th DCA 1996) (holding that the financial information at issue was relevant to the calculation of damages under th
ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of
ction of personal financial documents and information if shown to be relevant by the requesting party. Florida Gaming Corp. of Delaware v. American Jai-Alai, Inc., 673 So. 2d 523, 524 (Fla. 4th DCA 1996) (holding that the financial information at issue was relevant to the calculation of damages under the
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
uction of personal financial documents and information if shown to be relevant by the requesting party. Florida Gaming Corp. of Delaware v. American Jai-Alai, Inc., 673 So. 2d 523, 524 (Fla. 4th DCA 1996) (holding that the financial information at issue was relevant to the calculation of damages under th
Entities connected to both the Florida Rules of Civil and Jai-Alai

Jeffrey Epstein
PERSONScott Rothstein
PERSON
Bradley Edwards
PERSONTHE CIRCUIT COURT
ORGANIZATIONTonja Haddad Coleman
PERSONJack Goldberger
PERSONJack Scarola
PERSONPalm Beach Lakes Blvd
LOCATION
George W. Bush
PERSONFred Haddad
PERSONAtterbury
ORGANIZATIONMarc Nurik
PERSONW. Chester Brewer
PERSONJane Doe
PERSONFanner Jaffe Weissing Edwards
PERSONFriedman v. Heart Institute of Port St. Lucie, Inc.
ORGANIZATIONE.W.
PERSONSearcy Denney Scarola
PERSONWoodward
PERSONLangston
PERSON