Epstein Secrets

ant to which such payment was made. Include in 2 Christie v. Hixson, 358 So. 2d 859 (Fla. 4th DCA 1978); Ma

f the award. Equitable remedies are not relinquished by virtue of this provision; nor does either Party relinquish the right to pursue any other 2 Tonja Haddad, P.A. • 315 SE t h Street, Fort Lauderdale, FL 33301 EFTA00805502 legal or equitable damages to which (s)he may be entitled as a result of the ot

iprocal Confidentiality. The Parties agree that the amount of this settlement shall be kept strictly confidential and shall not be disclosed at any Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• EFTA00805501 time to any third party, except: (a) to the extent required by law or rule; (b)

a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list this October 5, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Florida Bar No.: Tonja Haddad, PA 5315 SE 7th Street Suite 301 1111, Florida 33301 facsimile) S Tonja Haddad, P.A

bjections must be set forth with specificity. See Christie v. Hixson, 358 So. 2d 859 (Fla. 4th DCA 1978). D

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

bjections must be set forth with specificity. See Christie v. Hixson, 358 So. 2d 859 (Fla. 4th DCA 1978). D

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

bjections must be set forth with specificity. See Christie v. Hixson, 358 So. 2d 859 (Fla. 4th DCA 1978). D

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

issible evidence" are legally impermissible. See Christie v. Hixson, 358 So. 2d 859 (Fla. 4th DCA 1978). Di

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