Epstein Secrets

m day of March, 2012 to: Jack Scarola, Esq., Searcy Denney Searc4a Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atter:bury, Goldberger & Weiss, PS, 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-502; and Marc S. Nutik, Esq., Law Office

h Lakes Blvd. West Palm Beach, FL 33409 Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 A

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

s Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, M. 250 Australia

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

s Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, .. 250 Australia

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

k Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterb , Goldber er & Weiss, P.A. o- ounse or

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