Epstein Secrets

fic items: [a]II e-mails, data, correspondence, and similar documents dated April 1, 2008 through August 1, 2010 by and between Bradley J. Edwards. Scott W. Rothstein, Marc hlurik, Cam Holmes, Mike Fisten and any one of the following regarding or mentioning Jeffrey Epstein in any way: (a) the U.S. Attorney's Offi

EDWARDS. In addition, the Motion seeks authority to direct a subpoena to the Bankruptcy Trustee of the former law firm of the Defendants EDWARDS and ROTHSTEIN. The Court finds that the Amended Request for Production and request for subpoena, does request documents which the Court finds are either relevant

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

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

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

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

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

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

nt to his causes of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

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