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

s to confidential communications made in the rendition of legal services to the client. Section 90.502, Fla. Stat.; Southern Bell Tel. & TeL Co. v. Deason, 632 So. 2d 1377 (Fla.1994). Section 90.502 codifies the attorney-client privilege which protects those confidential communications between attorney

of whether they pertain to confidential communications between attorney and client. F1a.R.Civ.P. 1.280(b)(2). See Southern Bell TeL & Tel. Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). The privilege may also protect an attorney's mental impressions which may be disclosed through testimony. Hamilton v.

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS TO ANSWER OUESTIONS Plaintiff/Counter-Defendant Jeffrey Epste

ON TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS TO ANSWER OUESTIONS Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.380(a) of the Florida Rules of Civil Procedure, hereby moves this Court for entry

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

you put into Q-task regarding the claims against Mr. Epstein? Transcript of Deposition dated March 23, 2010, p

e the same or similar information is available through ordinary investigative techniques and discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS TO ANSWER OUESTIONS Plaintiff/Counter-Defendant Jeffrey Epste

ON TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS TO ANSWER OUESTIONS Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.380(a) of the Florida Rules of Civil Procedure, hereby moves this Court for entry

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

you put into Q-task regarding the claims against Mr. Epstein? Transcript of Deposition dated March 23, 2010, p

ques and 19 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585412 discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga

rivilege is very clearly defined in Florida Rule of Civil Procedure 1.280(b)(3). And, Your Honor, that is quoted in the response in opposition to Jeffrey Epstein's motion to overrule objections and compel answers to these questions. It is quoted in its entirety at page two of our response. And it says that a

urt is aware, the only thing pending at this point in time in the case is Mr. Edwards' claim of abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operativ

H COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

f abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed o

ng this 518 Southern And again, the was quoted by the Florida Supreme Court in 1994 in the Southern Bell Telephone and Telegraph Company versus Deason. Frankly, Judge, if the Court wants me to go through the other objections that were raised in deposition that have no basis in law in a depositio

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

f whether they pertain to confidential communications between attorney and client. Fla. R. Civ. P. 1.280(b)(2). See Southern Bell Tel. & TeL Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). Work product is a qualified immunity from discovery. See DeBartolo-Aventura, Inc. v. Hernandez, 638 So. 2d 988 (Fla.