Epstein Secrets

2010 seeking the similar relief. The grounds for this motion are: 1. Late last year, Epstein filed this action to recover damages from Defendants, Scott Rothstein ("Rothstein") and Edwards, based on Epstein's well founded belief that the two, and possibly others, had perpetrated an illegal pyramid scheme direc

WLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606624 Epstein v Rothstein, Edwards CASE NO. 502009CA040800=OCMBAG Notice of Hearing PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabilitie

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

OURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and El., individually, Defendant, RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION T

XXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

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

ALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF

eral 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 privileged.' Th

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