Epstein Files Search

EFTA00802139Dataset 9

2010-04-0521p6,734w

…disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. FLA. R.Civ. P 1.280(5) (emphasis added). As such, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Florida Rule of Civil…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00802139.pdf

EFTA00603030Dataset 9

2011-02-252p260w

…Rothstein, Rosenfeldt Adler.. U.S. Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division; Case No. 09-34791-BKC-RBR Our File NO. 80743 Dear Judge Carney: We have the following objections to the form of the Privilege Log produced by Farmer, Jaffe based on the standards set forth in TIG Insurance Corporation ofAmerica, 799 So. 2d 339, (Fla. 4th DCA 2001). We request until the close of business on Tuesday, March 1, 2011 to supplement these objections, if necessary…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00603030.pdf

EFTA00592983Dataset 9

2011-03-305p1,009w

…Fla. Stat. § 90.5015. Therefore, Epstein would like to set for hearing a motion to compel the identification of Edwards' "Confidential Source." (b) The Privilege Log does not identify the recipients of an alleged privileged communication with "Confidential Source," "RRA Staff," and "RRA Personnel." Such identifications violate a court order requiring compliance with the requirements for a Privilege Log set forth in TIG Insurance Corporation of America (TIG) v. Johnson, 799 So.2d 339 (Fla. 4th -2- EFTA00592984 Epstein v…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00592983.pdf

EFTA00800173Dataset 9

2010-04-0519p6,165w

…disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. FLA. R.Civ. P 1.280(5) (emphasis added). As such, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Florida Rule of Civil…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00800173.pdf

EFTA00799381Dataset 9

2010-04-0521p6,732w

…in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. FLA. R.Civ. P 1.280(5) (emphasis added). As such, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Moreover, Florida Rule of Civil…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00799381.pdf

EFTA00603027Dataset 9

2011-02-253p777w

…the date of the item, the sender, the recipient, the so-called "description" of the item, and the nature of the objection. The Log does not contain the information required by Rule 1.280(b)(5) of the Florida Rules of Civil Procedure as that Rule has been interpreted by the Fourth District Court of Appeal. 3. In TIG Insurance Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001), the court denied a writ of certiorari sought from…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00603027.pdf

EFTA01158259Dataset 9

2011-02-252p252w

…Adler,P.A. U.S. Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division; Case No. 09-34791-BKC-RBR Our File NO. 80743 Dear Judge Carney: We have the following objections to the form of the Privilege Log produced by Farmer, Jaffe based on the standards set forth in TIG Insurance Corporation ofAmerica, 799 So. 2d 339, (Fla. 4th DCA 2001). We request until the close of business on Tuesday, March 1, 2011 to supplement these objections, if necessary…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01158259.pdf

EFTA01069460Dataset 9

2011-02-252p251w

…Adler,P.A. U.S. Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division; Case No. 09-34791-BKC-RBR Our File NO. 80743 Dear Judge Carney: We have the following objections to the form of the Privilege Log produced by Farmer, Jaffe based on the standards set forth in TIG Insurance Corporation ofAmerica, 799 So. 2d 339, (Fla. 4th DCA 2001). We request until the close of business on Tuesday, March 1, 2011 to supplement these objections, if necessary…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01069460.pdf

EFTA01112378Dataset 9

2011-03-305p1,044w

…Fla. Stat. § 90.5015. Therefore, Epstein would like to set for hearing a motion to compel the identification of Edwards' "Confidential Source." (b) The Privilege Log does not identify the recipients of an alleged privileged communication with "Confidential Source," "RRA Staff," and "RRA Personnel." Such identifications violate a court order requiring compliance with the requirements for a Privilege Log set forth in TIG Insurance Corporation of America (TIG) v. Johnson, 799 So.2d 339 (Fla. 4th -2- EFTA01112379 Epstein v…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01112378.pdf

EFTA01158262Dataset 9

2011-02-253p775w

…the date of the item, the sender, the recipient, the so-called "description" of the item, and the nature of the objection. The Log does not contain the information required by Rule 1.280(b)(5) of the Florida Rules of Civil Procedure as that Rule has been interpreted by the Fourth District Court of Appeal. 3. In TIG Insurance Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001), the court denied a writ of certiorari sought from…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01158262.pdf

EFTA01069462Dataset 9

2011-02-253p776w

…the date of the item, the sender, the recipient, the so-called "description" of the item, and the nature of the objection. The Log does not contain the information required by Rule 1.280(b)(5) of the Florida Rules of Civil Procedure as that Rule has been interpreted by the Fourth District Court of Appeal. 3. In TIG Insurance Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001), the court denied a writ of certiorari sought from…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01069462.pdf

EFTA00283060Dataset 9

2011-02-253p987w

…Rosenfeldt Adler. U.S. Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division; Case No. 09-34791-BKC-RBR Our File NO. 80743 Dear Judge Carney: We have the following objections to the form of the Privilege Log produced by Farmer, Jaffe based on the standards set forth in TIG Insurance Corporation of America, 799 So. 2d 339, (Fla. 4th DCA 2001). We request until the close of business on Tuesday, March 1, 2011 to supplement these objections, if necessary…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00283060.pdf

EFTA00613622Dataset 9

2011-03-305p960w

…for a private party with a confidential informant in civil cases. Therefore, Epstein would like to set for hearing a motion to compel the identification of Edwards' "Confidential Source." (b) The Privilege Log often does not identify the recipients of an alleged privileged communication other than "Confidential Source," "RRA Staff," and "RRA Personnel." Such identifications violate the requirements set forth in TIG Insurance Corporation of America -2- EFTA00613623 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG (TIG) v…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00613622.pdf

EFTA00802391Dataset 9

2010-04-0520p6,559w

…disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. FLA. R.Civ. P 1.280(5) (emphasis added). As such, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Florida Rule of Civil…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00802391.pdf

EFTA00208185Dataset 9

2012-05-0822p5,666w

Subject: Re: Epstein discovery

From: Jack Scarola

…identifying such documents." See Exhibit B. Edwards failed to either provide the items requested or a privilege log as to his communications with all listed entities/persons, other than Sarnoff.2 It is well-settled law that if a party alleges that information requested from it is protected by privilege, then a privilege log must be prepared and attached to the response, or the privilege is waived See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00208185.pdf

EFTA01069480Dataset 9

2010-04-1218p3,993w

…and requests an order compelling the production of those records. 13. Paragraph 24 seeks emails exchanged between Mr. Edwards and a number of named individuals relating to Mr. Epstein. The objections are based on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01069480.pdf

EFTA00585373Dataset 9

2010-04-0521p6,735w

…disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. FLA. R.Civ. P 1.280(5) (emphasis added). As such, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Florida Rule of Civil…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00585373.pdf

EFTA01085233Dataset 9

2012-04-1016p3,608w

…identifying such documents." See Exhibit B. Edwards failed to either provide the items requested or a privilege log as to his communications with all listed entities/persons, other than = 2 It is well-settled law that if a party alleges that information requested from it is protected by privilege, then a privilege log must be prepared and attached to the response, or the privilege is waived. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01085233.pdf

EFTA00585352Dataset 9

2010-04-0521p6,736w

…in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection. FLA. R.Civ. P 1.280(5) (emphasis added). As such, if a party alleges that information requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Moreover, Florida Rule of Civil…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00585352.pdf

EFTA00606606Dataset 9

2010-04-1218p4,032w

…and requests an order compelling the production of those records. 13. Paragraph 24 seeks emails exchanged between Mr. Edwards and a number of named individuals relating to Mr. Epstein. The objections are based on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00606606.pdf