Epstein Secrets

ROLA: Q. Which lawyers? A. Burman Critton, Jack Goldberger, and a bunch of the others, sir. Id at 116; lin

ys prepare responses to wildly irrelevant discovery in various locations at a minimum, sir. BY MR. SCAROLA: Q. Which lawyers? A. Burman Critton, Jack Goldberger, and a bunch of the others, sir. Id at 116; lines 8-19. Q. I want as much information as you can give me about this element of damage which you c

king of Epstein's affidavit is warranted. Edwards does not contend that Epstein failed to comply with a court order as contemplated by Rule 1.380 of the Florida Rules of Civil Procedure; nor does Edwards assert that Epstein's affidavit contains material that should be stricken from a pleading as delineated in Rule 1.140 o

inuance; work on proposed Orders and hearing packages; follow up on Objections to exhibits; work on Motion to Compel SJL Meeting with J. Epstein, J. Goldberger, D. Indyke and K. Rockenbach re strategies; work on Pre-Trial Stipulation and Motion for Continuance of Trial; work on preparations for B. Edwards'

mended Exhibit and Witness Lists AMM Analyze case law in support of our Supplemental Motion for 1.10 434.50 Continuance pursuant to Rule 1.460 of the Florida Rules of Civil 395.00/hr Procedure AMM Conduct research re how do we authenticate website articles and 2.10 829.50 website postings 395.00/hr AMM Prepare me

ch, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South, Suite 14

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

so those questions are still objected to, unresolved. So, we'll stoppage We will go from there, see what happens. Id. at page 98; lines 13-18. MR. GOLDBERGER: Well, wait a minute. Just one thing... So if we had asked the same questions, he would have raised the same objections, so not only are we going t

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

ch, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South, Suite 14

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

so those questions are still objected to, unresolved. So, we'll stoppage We will go from there, see what happens. Id. at page 98; lines 13-18. MR. GOLDBERGER: Well, wait a minute. Just one thing... So if we had asked the same questions, he would have raised the same objections, so not only are we going t

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

ch, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South, Suite 14

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder