Epstein Secrets

E OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail on this 4th day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger

. Mail on this 4th day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm B

vileged communication other than "Confidential Source," "RRA Staff," and "RRA Personnel." Such identifications violate the requirements set forth in TIG Insurance Corporation of America - 2 - EFTA00613623 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG (TIG) v. Johnson, 799 So.2d 339 (Fla. 4'h DCA 200

ng was emailed and mailed this gay of February, 2011 to Marc S. Nurik, Esq., One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. seph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BU

, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, 2139 Palm Beach Lakes Boulevard, P.O.

g to Mr. Epstein. The objections are based on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may be grounds to determ

s involved in this case until late afternoon on February 24, 2011. Respectfully submitted, 4494X CV 711-42— k Joseph L. Ackerman, Jr. JLA/nat cc: Jack Scuola, Esquire (via email and U.S. Mail) Gary Farmer, Jr., Esquire (via email and U.S. Mail) Seth Lehrman, Esquire (via email and U.S. Mail) Miami • For

Dear Judge Carney: We have the following objections to the form of the Privilege Log produced by Farmer, Jaffe based on the standards set forth in TIG Insurance Corporation of America, 799 So. 2d 339, (Fla. 4th DCA 2001). We request until the close of business on Tuesday, March 1, 2011 to supplement these objections, if necessar