e theory of the requestor's case, or to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA 2003). In addition, Florida Rule of Civil Procedure 1.280(b)(3), does allow discovery of fact work product where the requesting party can show need and the inability to obtain the substantia

So.2d 293, 296 (4th DCA 2006). "A party is required to file a log only if the information is `otherwise discoverable!" Gosman at 296 (referring to Florida Rule of Civil Procedure 1.280(b)(5)). Before a written objection to a discovery request is ruled upon, the documents are not "otherwise discoverable". Gosman at

stricken from the trial calendar, pleadings may be stricken, and other sanctions may be imposed. D. Any party opposing mediation may proceed under Florida Rule of Civil Procedure 1,700(b). IV. NONCOMPLIANCE NONCOMPLIANCE WITH ANY PORTION OF THIS ORDER MAY RESULT IN THE STRIKING OF THE CASE, WITNESSES, OR EXHIBITS

ement. If a settlement is reached, it shall be the responsibility of the attorneys or parties to reduce the agreement to writing and to comply with Florida Rule of Civil Procedure 1.730(b), unless waived. B. The Plaintiff's attorney shall be responsible for scheduling mediation. The parties should agree on a mediat

se No. 502009CA040800XXXXMBAG NOTICE OF TAKING DEPOSITION BY VIDEO TO: All Counsel of Record PLEASE TAKE NOTICE that the undersigned, pursuant to Florida Rule of Civil Procedure 1.310(b)(4), will take the deposition of: NAME DATE AND TIME PLACE Scott Rothstein FRIDAY_1 November 19, 2010 10:00 M. Turner Guilf

COTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant. MOTION FOR PROTECTIVE ORDER L.M., pursuant to Florida Rule of Civil Procedure 1.280(c), hereby files this Motion for Protective Order to prevent the depositions of any private investigators who are working on or hav

s do not appear for, participate, or complete mediation, this Court may impose sanctions. If a party opposes mediation, that party may proceed under Florida Rule of Civil Procedure 1.700(b). O. Noncompliance, Noncompliance with any portion of this order may result in the striking of the case, witnesses, or exhibits,

ndant, REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGESI BRADLEY J. EDWARDS, by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and things described below for the purpose of inspection, copying,

ONSE TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS' REOUESTS FOR ADMISSION Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), pursuant to Florida Rule of Civil Procedure 1.370, responds to Defendant/Counter-Plaintiff Bradley J. Edwards' ("Edwards") February 6, 2018, Requests for Admission as follows: I. T

ify them on his Exhibit List. Edwards has provided not a single reason why this Court should expedite its careful review and enforce the mandate of Florida Rule of Civil Procedure 1.440 (Petition for Writ of Mandamus) and determine if the severance of the interrelated and dependent actions should continue to one jur

Edwards filed his motion to set case for trial, 7 EFTA00793699 the case was not at issue, and thus, the scheduled trial may not proceed based on Florida Rule of Civil Procedure 1440.5 (App. 15). Upon receiving Edwards' Supplement to his Motion for Separate Trials, Epstein's counsel immediately researched the Rule

time Edwards filed his motion to set case for trial, the case was not at issue, and thus, Epstein's case against Rothstein may not proceed based on Florida Rule of Civil Procedure 1.440. (App. 15). Rule 1.440 provides: (a) When at Issue. An action is at issue after any motions directed to the last pleading served

BECAUSE THE CIRCUIT COURT MUST REMOVE THE CASE FROM THE TRIAL DOCKET IN ORDER TO COMPLY WITH THE MANDATE SET FORTH IN RULE 1.440. In violation of Florida Rule of Civil Procedure 1.440, this case was not "at issue" when Edwards filed his Motion to Set Case for Trial. Therefore, the circuit court's ensuing Order set

otion filed by 5 By KARA BERARD ROCKENBACH, ESQUIRE Epstein to remove the case from the trial 6 By SCOTT J. LINK, ESQUIRE ^ docket relative to Florida Rule of Civil 9 For Defendant/Counter-Plaintiff: Procedure 1.440 first. SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Yo

ivilege log that this Court's predecessor, The Honorable David Crow, found to be insufficient on its face and not-compliant with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)7 and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Edwards has claimed that none of the documents on the dis

ils), Edwards clearly waived any work-product protection he may have had by — among other compelling reasons -- his complete failure to comply with Florida Rule of Civil Procedure 1.280(b)(6). With Epstein's citation in his motion to the Fourth District Court of Appeal's controlling case of General Motors Corp v. Mc

AND ADJU follows: 1. Non-party Fannyr Jaffe consents to the jurisdiction of this Court solely for purposes of participating medi&ion. 2. t to Florida Rule of Civil Procedure 1.720, Edwards, Epstein and a repr m Farmer Jaffe who has the full authority to settle without further consultation shall app at the me

participate in mediation subject to this Agreed Mediation Confidentiality Order. The Court, hereby ORDERS AND ADJUDGES as follows: I. Pursuant to Florida Rule of Civil Procedure 1.720, Edwards, Epstein, and representatives from Fowler White and Farmer Jaffe who have the full authority to settle without EFTA0079591

Include "at issue" argument 03/03/18 KBR Work on preparations for trial; work on Motion to 7.30 Remove Case from Trial Docket in compliance with Florida Rule of Civil Procedure 1.440; work on Response to B. Edwards' Motion to Severe; conduct legal research on appellate vehicle should the Court grant B. Edwards'

tment Record Custodian (collectively 'Town of Palm Beach Police Officers"), hereby move to quash the subpoena or for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) directing that discovery sought by the civil subpoenas for deposition issued by Plaintiff, B.B , and the cross-notices with subp