Epstein Secrets

; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm Telephone: Facsimile: Attorne

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

TORNEYS AT LAW r February 25, 2011 VIA EMAIL AND FIRST CLASS MAIL got Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 3301 Joseph L. Ackerman, Jr. ($60 472.6394 direct (56i) 472.6395 Fax lackermandpfowler-white.corn Robert B. Carney, Special Master 2281 Saratoga Lane West Palm Beach,

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

and legally sufficient privilege log, and granting such other and further relief as the Court deems necessary and proper. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive 16 EFTA00582872 Epstein v. Rothstein a

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