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

nadmissible at trial, if it may lead to the discovery of relevant evidence." Allstate Ins. Co. v. Langston, 655 So. 2d 91, 93 (Fla. 1995). See also Murray Van & Storage, Inc. v. Murray, 343 So. 2d 61 (Fla. 4th DCA 1977) (stating that an objection to discovery claiming that the sought-after information is not reasonably c

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

o. 2d 859 (Fla. 4th DCA 1978). Discovery responses containing bare-boned objections, without more, are stricken as a matter of course. Id. See also Murray Van & Storage, Inc. v. Murray, 343 So. 2d 61 (Fla. 4th DCA 1977) (stating that an objection to discovery claiming that the sought-after information is not reasonably c

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

o. 2d 859 (Fla. 4th DCA 1978). Discovery responses containing bare-boned objections, without more, are stricken as a matter of course. Id. See also Murray Van & Storage, Inc. v. Murray, 343 So. 2d 61 (Fla. 4th DCA 1977) (stating that an objection to discovery claiming that the sought-after information is not reasonably c

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

o. 2d 859 (Fla. 4th DCA 1978). Discovery responses containing bare-boned objections, without more, are stricken as a matter of course. Id. See also Murray Van & Storage, Inc. v. Murray, 343 So. 2d 61 (Fla. 4th DCA 1977) (stating that an objection to discovery claiming that the sought-after information is not reasonably c