Epstein Secrets

RIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.120 I Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWAR

on Friday, April 1, at 9:00 a.m., the following: EPSTEIN'S AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOSITION The following procedures must be noted on all specially set hearing notices in Division AG:

ion between fact and opinion work product. Work product protection is limited to materials which are not intended to be used as evidence at trial. Northup v. Acken, 865 So. 2d 1267, 1270 (Fla. 2004) ("when a party reasonably expects or intends to utilize an item before the court at trial, for impeachme

nt or otherwise, the video recording, document, exhibit, or other piece of evidence is fully discoverable and is not privileged work product."). In Northup, the court remarked that a litigant must decide whether the material is going to be used only for strategy and trial preparation purposes prior to t

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and El., individually, Defendant, RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO COMPEL BRADLEY EDWARDS TO IDENTI

[U]nless Edwards' listed witnesses have personal knowledge of the matter at issue and can speak to what Epstein believed when he filed suit against Edwards, the witnesses' testimony would be irrelevant and collateral, and thus, inadmissible, even for purposes of impeachment. Mot. at p. 14 (emphasis add

vilege, and Epstein's attempt to invade that privilege to cure any purported defect in the defense's preparation of this case should be rejected. 50 Northup v. Acken, 865 So. 2d 1267, 1270 (Fla. 2004) ("Personal views of the attorneys as to how and when to present evidence, his evaluation of its relativ

ISION 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 DOCUMENTS BY DEFENDANT BRADLEY EDWARDS

gh his undersigned counsel, hereby respectfully seeks the entry of an Order compelling Defendant Bradley Edwards to produce the documents listed in Edwards' privilege log, or, in the alternative, the entry of an Order compelling Edwards to serve a privilege log that fully complies with Fla. R. Civ. P. 2

nc. v. Hernandez, 638 So. 2d 988 (Fla. 3d DCA 1994). The work product privilege does not extend to materials intended for use as evidence at trial. Northup v. Acken, 865 So. 2d 1267 (Fla. 2004). Work product falls into two categories: 1) "fact" work product consisting of factual information pertaining