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nt prosecution agreement with Edwards' counsel, whereby both parties agreed to share information relative to their claims and/or defenses related to Scott Rothstein without waiving privilege as to their communications or documents shared." Edwards' Supp. Resp. to Epstein's Mot. to Declare Relevance, July 26, 201
in this action about his anxiety over being sued by Epstein They also directly relate to Edwards' interaction with Ponzi-schemer Scott Rothstein ("Rothstein") and the strengthAveakness of Edwards' clients' damage claims against Epstein, both which have become critical factual issues in this case. First
orable David Crow, found to be insufficient on its face and not-compliant with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)7 and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Edwards has claimed that none of the documents on the disc that were listed on his privilege log ha
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
other patties to assess the applicability of the privilege or protection. The key case in this District construing Fla. R. Civ. P. 1.280(b)(5) is TIG Ins. Corp., 799 So. 2d 339, in which the Fourth District Court of Appeal denied a petition for a writ of certiorari seeking review of an order requiring TIG,
ICT OF FLORIDA FORT LAUDERDALE DIVISION IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A. Debtor. CASE NO. 09-3479
s to produce a Privilege Log by January 31, 2011. While a Privilege Log was presented timely, Plaintiff objected that it was not in compliance with TIG Ins. Corp. v. Johnson, 799 So.2d 339 (Fla. 4th DCA 2001). The Parties met with your Special Master on February 16, 2011 and came to an agreement for productio
Entities connected to both Scott Rothstein and TIG Ins. Corp.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSONMarc S. Nurik
PERSON
Scarlett Johansson
PERSON
Adler
PERSONSouthern District
LOCATIONRothstein Rosenfeld
PERSONDelap v. State
PERSON