Epstein Secrets

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

you put into Q-task regarding the claims against Mr. Epstein? Edwards had filed suits against Epstein on beha

rrett, 742 So. 2d 451 (Fla. 5th DCA 1999. Therefore, if the answer was evident from the complaint eventually filed by Edwards ("to seek redress from Jeffrey Epstein"), it would not be privileged. Likewise, if L.M. had initially hired Edwards to consult him about a claim she never pursued, the subject might argua

lm Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401 on Friday, April 1, at 9:00 a.m., the following: EPSTEIN'S AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOS

ion between fact and opinion work product. Work product protection is limited to materials which are not intended to be used as evidence at trial. Northup v. Acken, 865 So. 2d 1267, 1270 (Fla. 2004) ("when a party reasonably expects or intends to utilize an item before the court at trial, for impeachme

nt or otherwise, the video recording, document, exhibit, or other piece of evidence is fully discoverable and is not privileged work product."). In Northup, the court remarked that a litigant must decide whether the material is going to be used only for strategy and trial preparation purposes prior to t

iff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and El., individually, Defendant, RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO COMPEL BRADLEY EDWARDS TO IDENTIFY HIS TRIAL WITNESSES Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files th

osition to Defendant Jeffrey Epstein's Motion to Compel Bradley Edwards to Identify His Trial Witnesses, and as grounds therefor states as follows: Epstein's Standard for Admissibility of Witness Testimony Although Epstein's Motion concerns the disclosure of trial witnesses, he spend much of his time a

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

vilege, and Epstein's attempt to invade that privilege to cure any purported defect in the defense's preparation of this case should be rejected. 50 Northup v. Acken, 865 So. 2d 1267, 1270 (Fla. 2004) ("Personal views of the attorneys as to how and when to present evidence, his evaluation of its relativ

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

Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS Plaintiff, Jeffrey Epstein, by and through his undersigned

onse to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG log, claiming that over two thousand (2000) documents are pri

nc. v. Hernandez, 638 So. 2d 988 (Fla. 3d DCA 1994). The work product privilege does not extend to materials intended for use as evidence at trial. Northup v. Acken, 865 So. 2d 1267 (Fla. 2004). Work product falls into two categories: 1) "fact" work product consisting of factual information pertaining