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

ivision AG (TIG) v. Johnson, 799 So.2d 339 (Fla. 4'h DCA 2001). Consequently, Epstein would like to set a motion directed toward the sufficiency of the Privilege Log. 6. Epstein wishes to proceed with discovery of Edwards' alleged damages, but the Motion to Dismiss the Amended Counterclaim is pending, and Epste

S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley,

VICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail and U.S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbur

rior to that time, although Epstein does not hereby waive the right to an in camera review with respect to any of the other materials referenced in the Privilege Log. Finally, the actual prejudice to and impact on Epstein by Edwards' willful and continued non-compliance is palpable. Epstein has been prejudiced

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

iness on Tuesday, March 1, 2011 to supplement these objections, if necessary. The request is being made because we were not able to begin reviewing the Privilege Log for these objections until late Thursday afternoon, on February 24, 2011, because the arrival of the Privilege Log and documents was not communicate