Epstein Secrets

. 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 calculated

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00799382 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

igation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301• EFTA00799385 during the time you were employed by RRA (or that is being claimed by the trust

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

. 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 calculated

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585353 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

ation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, L.M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301 EFTA00585356 during the time you were employed by RRA (or that is being claimed by the truste

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

. 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 calculated

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585374 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

ation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, L.M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301 EFTA00585377 during the time you were employed by RRA (or that is being claimed by the trustee

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

y 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 calculated

iff Bradley Edwards's Request for a Protective Order, and grant such other and further relief as deemed necessary and proper. 6 EFTA00691828 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 ' 301 WE HEREBY CERTIFY that a t

Request for a Protective Order, and grant such other and further relief as deemed necessary and proper. 6 EFTA00691828 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 ' 301 WE HEREBY CERTIFY that a true and correct copy o