Epstein Secrets

from the U.S. Attorney's Office to Epstein's counsel (see ¶6) specifically in support of his contention that there was a 'joint attempt to minimize Epitein's civil exposure." 3 EFTA00208199 Case 9:08-cv-80736-KAM Document 177-1 Entered on FLSD Docket 06/06/2012 Page 16 of 22 Epstein v. Rothstein an

FLSD Docket 06/06/2012 Page 1 of 22 Tonja Haddad Coleman From: Sent: To: Subject: Thank you. Jack Scarola Tuesday, May 08, 2012 3:41 PM Re: Epstein discovery On May 8, 2012. at 3:27 PM. "Tonja Haddad Coleman" MINIMI > > Fine. > Tonja Haddad Coleman. Esq. > Tonja Haddad, P.A. > Justice Buildi

iffiCounter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. ORDER ON PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL AND AMEND PROTECTIVE ORDER THIS MATTER came before the Court on PlaintiffJeffrey Epstein's Motion to Compel and Amend Protective

NO. 502009CA0408003OOO134B Judge David F. Crow JEFFREY EPSTEIN, PlaintiffiCounter-Defendant, v. SCOTT

rmation requested from it is protected by privilege, then a privilege log must be prepared and attached to the response, or the privilege is waived See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001) (stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiv

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffr

RIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rules 1.280 and 1.380 of the Florida Rules of Civil Procedure, hereby requests that this

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

tion with Edwards's prosecution of cases against Mr. Epstein before and after Edwards joined RRA. Epstein's r

uch, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Moreover, Florida Rule of Civil Procedure 1.280(b)(3) permits discovery of fact work product where

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffr

RIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rules 1.280 and 1.380 of the Florida Rules of Civil Procedure, hereby requests that this

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

tion with Edwards's prosecution of cases against Mr. Epstein before and after Edwards joined RRA. Epstein's r

uch, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Moreover, Florida Rule of Civil Procedure 1.280(b)(3) permits discovery of fact work product where

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffr

RIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rules 1.280 and 1.380 of the Florida Rules of Civil Procedure, hereby requests that this

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

tion with Edwards's prosecution of cases against Mr. Epstein before and after Edwards joined RRA. Epstein's r

uch, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Florida Rule of Civil Procedure 1.280(b)(3) permits discovery of fact work product where the request