Epstein Secrets

PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR AN IN CAMERA INSPECTION OF 30 E-MAILS Counter-De

es to them. Following this Court's in camera review, Epstein seeks a ruling from this Court that these 30 e-mails, which were improperly withheld by Edwards, an officer of the court, on the false bases of irrelevancy, attorney-client privilege and inapplicable basis of work product3, should be unsealed,

orable David Crow, found to be insufficient on its face and not-compliant with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)7 and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Edwards has claimed that none of the documents on the disc that were listed on his privilege log ha

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

other patties to assess the applicability of the privilege or protection. The key case in this District construing Fla. R. Civ. P. 1.280(b)(5) is TIG Ins. Corp., 799 So. 2d 339, in which the Fourth District Court of Appeal denied a petition for a writ of certiorari seeking review of an order requiring TIG,

ehalf of Intertstal Party Farmer, Jale, Weissing, Edwards, Finos 6. Lehniumill. mieMei D Ltir behalf_ofDd

s to produce a Privilege Log by January 31, 2011. While a Privilege Log was presented timely, Plaintiff objected that it was not in compliance with TIG Ins. Corp. v. Johnson, 799 So.2d 339 (Fla. 4th DCA 2001). The Parties met with your Special Master on February 16, 2011 and came to an agreement for productio