f the party asserting the privilege to “explain how the act of producing documents would pose a real danger of incrimination.” Bear Sterns & Co. v. Wyler, 182 F.Supp. 2d 679, 681 (N.D. Ill. 2002). Defendant’s reliance on United States v. Hubbell, 530 U.S. 27 (2000), is inadequate. In Hubbell, it

LLC 961687 Gateway Blvd Suite 201-1 Fernandina Beach, Fl. 32034 Re: CA Florida Holdings, LLC v. Dave Aronberg et al. Case No, 2019-CA-014681 Dear Mr. Wyler: We are in receipt ofyour letter ofJune 8,2020 with your proposed Fla. Stat, section 57.105 motion. In your letter and your proposed motion, you asse

equires a court order before the records 6 are unsealed. 7 THE COURT: Exactly. Exactly. 8 All right. Let me hear from Mr. Aroriberg's 9 attorney, Mr. Wyler. 10 MR. WYLER: Thank you, your Honor. May it 11 please the Court- 12 THE COURT: Good morning, Sir. 13 MR. WYLER: Good morning. 14 Your Honor, I just

has been electronically filed with the Florida E-File Portal for e-service on all parties of record herein. JACOBS SCHOLZ & WYLER, LLC /s/Douglas A, Wyler Arthur I. Jacobs, Esq. Fla. Bar No,: 10249 Richard J. Scholz, Esq. Fla. Bar No.: 0021261 Douglas A. Wyler, Esq. Fla. Bar No.: 119979 961687 Gateway B

ate of fee, customarily charged in the locality for legal services of a comparable or similar nature The base fees consisting of $425.00/hour for Mr. Wyler’s services and $475.00/hour for Mr. Jacobs’ services are reasonable for lawyers in their respective communities possessing equal experience and skill

)thcfee,orratcoflee, customarilychargcdinthc localityforlcgalscrviccs bfacdrilparableofsimilar nature The base fees consisting of $425.00/hour forMr, Wyler’s services and $475.00/hour for Mr, Jacobs’ services are reasonable. for lawyers in their respective communities, possessing equal expcricnccandskill

ht. Let me hear from Mr. Aronberg's attorney, Mr. Wyler. MR. 'WYLER: Thank you, your Honor. May it please

able from those here. “[I]n Hubbell, the incriminatory nature of the production of the documents sought was obvious.” Bear Stearns & Co., Inc. v. Wyler, 182 F.Supp. 2d 679, 683 (N.D.Ill. 2002). Specifically, production of the documents at issue in Hubbell, concerning the Whitewater investigation, w