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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
rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,
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
rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,
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
rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,
Entities connected to both Figueroa and the Plaintiff/Counter-Defendant

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
Murray
PERSONJack Scarola
PERSONAtterbury
ORGANIZATIONPalm Beach Lakes Blvd
LOCATIONMarc Nurik
PERSONTonja Haddad Coleman
PERSONFred Haddad
PERSONSearcy Denney Scarola
PERSONTHE CIRCUIT COURT
ORGANIZATIONW. Chester Brewer
PERSON
Chris Christie
PERSON
Searcy Denney
PERSON