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

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

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

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

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

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder