Epstein Secrets

ing party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

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

ing party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

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

ng party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

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