Epstein Secrets

ives or any other electronic format and any written transcriptions). 13. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives

Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401, on Tuesday, April 5, at 8:30 a.m., the following: EPSTEIN'S MOTION TO COMPEL/MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED The following procedures must be noted on all specially set hearing notices i

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

and/or Scott Rothstein relating to any aspect of Mr. Epstein's case. Objections were based on relevance and o

g to Mr. Epstein. The objections are based on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may be grounds to determ

ter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR CLARIFICATION REGARDING DISCOVERY Plaintiff/Counter-Defendant JEFFREY EPSTEIN ("Epstein") by and through undersigned counsel, her

tiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR CLARIFICATION REGARDING DISCOVERY Plaintiff/Counter-Defendant JEFFREY EPSTEIN ("Epstein") by and through undersigned counsel, hereby moves for clarification of prior court directives regarding a stay of discovery until the pleadings

SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

vileged communication other than "Confidential Source," "RRA Staff," and "RRA Personnel." Such identifications violate the requirements set forth in TIG Insurance Corporation of America - 2 - EFTA00613623 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG (TIG) v. Johnson, 799 So.2d 339 (Fla. 4'h DCA 200

rt Lauderdale Division; Case No. 09-34791-BKC-RBR Our File NO. 80743 Dear Judge Carney: As a supplement to my February 25, 2011 letter, below are Epstein's further objections to the Farmer Jaffe Privilege Log as follows: 1. The Privilege Log consists of 159 pages with each page containing approximat

Dear Judge Carney: We have the following objections to the form of the Privilege Log produced by Farmer, Jaffe based on the standards set forth in TIG Insurance Corporation of America, 799 So. 2d 339, (Fla. 4th DCA 2001). We request until the close of business on Tuesday, March 1, 2011 to supplement these objections, if necessar