Epstein Secrets

ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

tein"), by and through his undersigned counsel, hereby files his Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") legally and factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwar

ird, Edwards asserts that a protective order is warranted because the production requested "is unnecessarily intrusive into the financial privacy of BRADLEY EDWARDS'." See Exhibit B. However, because Edwards has put his financial status at issue by his assertion of damages, his Motion must be denied. When a party

a. 3d DCA 1980) (holding that trial court abused its discretion by its denial of plaintiffs motion to compel production of detailed financial data); Charlton v. Tennant, 365 So. 2d 418 (Fla. 2d DCA 1978). CONCLUSION Based on the arguments presented above and the authorities cited in support thereof, Pl

obert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel Garci

urns are pertinent and discoverable. Tennant v. Charlton, 377 so.2d 1169 (Fla. 1979) (holding that party

ct Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell K

to punitive damages, among other issues in these cases, and in this regard the Defendant’s tax returns are pertinent and discoverable. Tennant v. Charlton, 377 So.2d 1169 (Fla. 1979) (holding that party may obtain tax returns for purposes of net worth discovery on issue of punitive damages). See also

obert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel Garcia

turns are pertinent and discoverable. Tennant v. Charlton, 377 So.2d 1169 (Fla. 1979) (holding that party