of 13 Page8 have the same exact goal. Epstein cannot defend this matter with the element of unfair and prejudicial "surprise" is ever so present. Schearbrook Land and Livestock Company v. U.S. et. al, 124 F.R.D. 221 (M.D. Fla. 1988). 11. In an effort to move these cases forward and obtain meaningful discovery, Epstein filed

n any evidence in defense of his case. Epstein cannot defend this matter when the element of unfair and prejudicial "surprise" is ever so present. Schearbrook Land and Livestock Company v. U.S. et. al, 124 F.R.D. 221 (M.D. Fla. 1988}. Plaintiff's trial by ambush tactics should not be tolerated. 16. Accordingly, this court sh