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

nt), make Epstein's request for information about such expenditures, as well as the rationale for engaging in same, relevant. See also Behm v. Cape Lumber Co., 834 So. 2d 285 (Fla. 2d DCA 2002) (stating that proper discovery includes records and information that are relevant to the calculation of damages.

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

nt), make Epstein's request for information about such expenditures, as well as the rationale for engaging in same, relevant. See also Behm v. Cape Lumber Co., 834 So. 2d 285 (Fla. 2d DCA 2002) (stating that proper discovery includes records and information that are relevant to the calculation of damages.

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

nt), make Epstein's request for information about such expenditures, as well as the rationale for engaging in same, relevant. See also Behm v. Cape Lumber Co., 834 So. 2d 285 (Fla. 2d DCA 2002) (stating that proper discovery includes records and information that are relevant to the calculation of damages.