Epstein Secrets

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

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

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

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

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

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

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

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

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

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