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112-0730 Limited Intervenor Co-Counsel for M, E.W. and Jane Doe Jay Howell Jay Howell & Associate
to even assertedly privileged documents in any context other than at trial is completely nonsensical. Even a privilege log required under Florida's Rules of Civil Procedure as a condition to withhold documents on the basis of privilege must sufficiently identify the specific documents withheld with enough detail to fac
-0730 Limited Intervenor Co-Counsel for M , E.W. and Jane Doe Jay Howell Jay Howell & Associate
to even assertedly privileged documents in any context other than at trial is completely nonsensical. Even a privilege log required under Florida's Rules of Civil Procedure as a condition to withhold documents on the basis of privilege must sufficiently identify the specific documents withheld with enough detail to fac
1, 2010 by and between Bradley J. Edwards. Scott W. Rothstein, Marc Nurik, Cara Holmes, Mike Piston
pstein is entitled to reasonable attorney's fees necessitated by Defendant's flagrant disregard of both this Court's Order and the afore- referenced Rules of Civil Procedure. CONCLUSION Accordingly, for all of the reasons delineated above and in reliance upon the applicable law cited herein, Plaintiff Jeffrey Epstein r
as completed. Additionally, The Honorable Donald W. Hafele's stated interest in first allowing the Sh
dwards' failure to comply with the Court's Order. Because Edwards blatantly disregarded the Court's Order, as well as the requirements of Florida's Rules of Civil Procedure and the TIG case, the February 23, 2011 privilege log remains for any number of wholly deficient and worse - misleading. The privilege log misstate
Entities connected to both George W. Bush and Rules of Civil Procedure

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONMaria Farmer
PERSONJane Doe
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONScott Rothstein
PERSON
Paul Cassell
PERSONJack Scarola
PERSON
Jacksonville
LOCATIONGoldberger & Weiss
ORGANIZATION
Lauderdale
LOCATIONPalm Beach Lakes Boulevard
LOCATION
Jay Howell
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONMarc S. Nurik
PERSON
Scott J. Link
PERSON
Searcy
PERSONNichole J. Segal
PERSON