ummaries of statements made by the plaintiffs and witnesses and/or inducements given to the plaintiffs or witnesses would be discoverable under both the Florida Rules of Civil Procedure and the Federal Rules of Civil Procedure because they are relevant to an issue in dispute and are reasonably likely to lead to discoverab

ES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth Interrogatories to Jeffrey Epstein: I. Wha

ES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth Interrogatories to Jeffrey Epstein: I. Wha

ES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth Interrogatories to Jeffrey Epstein: I. Wha

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

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

mended Exhibit and Witness Lists AMM Analyze case law in support of our Supplemental Motion for 1.10 434.50 Continuance pursuant to Rule 1.460 of the Florida Rules of Civil 395.00/hr Procedure AMM Conduct research re how do we authenticate website articles and 2.10 829.50 website postings 395.00/hr AMM Prepare me

king of Epstein's affidavit is warranted. Edwards does not contend that Epstein failed to comply with a court order as contemplated by Rule 1.380 of the Florida Rules of Civil Procedure; nor does Edwards assert that Epstein's affidavit contains material that should be stricken from a pleading as delineated in Rule 1.140 o

ust 25, 2011, Epstein served an Offer of Judgment on Edwards in the amount of three hundred thousand dollars ($300,000.00) pursuant to Rule 1.442 of the Florida Rules of Civil Procedure and §768.79 of the Florida Statutes (the "Offer"). A true and correct copy of same is attached hereto as "Exhibit A." Edwards failed to a

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

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

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