respectively Edwards served his responses thereto As explained more fully below Edwardss objections to Epsteins Requests are legally insufficient as a matter of law and as such said objections must be stricken and production compelled Additionally the information sought in Epsteins Interrogatories and Requests for Production is germane to this litigation is the subject of matters put at issue by Edwards in his Counterclaim and his prayer for Punitive Damages and cannot be obtained in any other way thereby mandating its disclosure Accordingly these relevant responsive documents must be turned over to Epstein SUMMARY OF THE ARGUMENT In his responses to Epsteins Interrogatories and Requests for Production that are at issue in this Motion Edwards raises in one form or another three impermissible and/or improper objections that must be stricken to wit relevance privilege and economic right to privacy As explained more fully in the Memorandum of Law below each of these objections as plead is insufficient as a matter of law mandating that this Court compel responses from Edwards MEMORANDUM OF LAW INTRODUCTION Florida Law permits litigants ample latitude in discovery Rule of the Florida Rules of Civil Procedure memorializes this broad scope and provides that Parties may obtain discovery regarding any matter not privileged that is relevant to the subject matter of the pending action whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party including the existence description nature custody condition and location of any books documents or other tangible things and the identity and location of persons having knowledge of any discoverable matter It is not ground for objection that the information sought will be inadmissible at the There were several other discovery requests and responses filed and responded to but this Motion deals exclusively with those delineated above The other outstanding discovery is addressed in a separate Motion Tonja Haddad P.A SE th Street Fort Lauderdale FL trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence FLA R.CN emphasis added As such as long as the discovery requested is relevant to the cause of action as to any claim or defense and is not otherwise subject to a privilege it is discoverable The first of Edwardss objections Epstein seeks to strike in this Motion are the blanket objections It is well-established law that blanket objections such as relevance overbroad and not likely to lead to the discovery of admissible evidence are legally impermissible Such objections must be set forth with specificity See Christie Hixson So 2d Fla 4th DCA Discovery responses containing bare-boned objections without more are stricken as a matter of course Id See also Murray Van Storage Inc Murray So 2d Fla 4th DCA stating that an objection to discovery claiming that the sought-after information is not reasonably calculated to lead to discovery of admissible evidence is a legally insufficient reason to prevent discovery In fact the concept of relevancy is broader in the discovery context than in trial context a party may be permitted to discover relevant evidence that would be inadmissible at trial if it may lead to the discovery of relevant evidence Allstate Ins Co Langston So 2d Fla As provided in detail below Edwardss objections to Epsteins Discovery contain nothing more than the forbidden language and as such must be stricken and responses compelled Next Epstein seeks to strike the objections improperly made by Edwards by his assertion of privilege Rule of the Florida Rules of Civil Procedure delineates the requisites one must follow when claiming a privilege to information requested in discovery and provides When a party withholds information otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material the party shall make the claim expressly and shall describe the nature of the Tonja Haddad P.A SE th Street Fort Lauderdale FL documents communications or things not produced or 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.Clv 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 Johnson So 2d Fla 4th DCA Moreover Florida Rule of Civil Procedure permits discovery of fact work product where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means Vesta Fire Ins Corp Figueroa So 2d Fla 5th DCA Ashemimry Ba Nafa So 2d Fla 5th DCA Accordingly this production should be compelled Finally although the general rule in Florida is that personal financial information is not discoverable this rule is not without exceptions The pertinent exception here is that personal financial material is discoverable in cases where such information is relevant to subject matter of the pending litigation Friedman Heart Institute of Port St Lucie Inc So 2d Fla Epstein Epstein So 2d Fla 3d DCA When a party voluntarily puts his personal financial information at issue courts will compel production of personal financial information Friedman So 2d at A partys finances if relevant to the disputed issues of the underlying action are not excluded from discovery and courts will compel production of personal financial documents and information if shown to be relevant by the requesting party Florida Gaming Corp of Delaware American Jai-Alai Inc So 2d Fla 4th DCA holding that the financial information at issue was relevant to the calculation of damages under the cause of action and as such financial discovery was proper See also Friedman Heart Institute of Port St Lucie Inc So.2d Fla In the Tonja Haddad P.A SE th Street Fort Lauderdale FL case at hand it is irrefutable that Edwardss financial information is relevant in fact it was he who put it at issue in his claims for damages The damages allegedly suffered by Edwards are not only a contested issue in this case but also a requisite element to his cause of action Moreover discovery relating to Edwardss financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRAs illicit activities is most certainly relevant to Edwards allegations in this case and Epsteins defense of the same Accordingly the financial information sought must be turned over SPECIFIC DISCOVERY REQUESTS AND RESPONSES I Epsteins Discovery Requests to Edwards dated April In response to Epsteins Interrogatories dated April Edwards made the following impermissible objections to wit Identify in detail the amount of all costs including photocopies telephone fax research investigation travel expenses deposition related costs expert costs etc that were incurred by you in the representation of you and/or your law firm in representing Jane Doe L.M and E.W prior to joining RRA ANSWER Objection relevance not reasonably calculated to lead to the discovery of admissible evidence and is protected by the work product privilege Identify in detail the amount of all costs including photocopies telephone fax research investigation travel expenses deposition related costs expert costs etc that were incurred by RRA in its representation of Jane Doe L.M and E.W during the time you were employed by RRA or that is being claimed by the trustee in bankruptcy for RRA Segregate by each of your clients ANSWER Objection relevance not reasonably calculated to lead to the discovery of admissible evidence and is protected by the work product privilege During the time you were employed/associates with RRA state the names of all attorneys at the RRA firm with whom you discussed potential deponents or who participated in any decision to depose witnesses in the Jane Doe L.M or E.W cases ANSWER Objection work product privilege and attorney client privilege During the time you were employed/associates with RRA state the names of all paralegals or investigators at the RRA firm with whom you discussed the Tonja Haddad P.A SE th Street Fort Lauderdale FL potential deponents or who participated in any decision to depose witnesses in the Jane Doe L.M or E.W cases ANSWER Objection work product privilege and attorney client privilege Edwards first objects to Interrogatories numbered five and six on the purported grounds of relevance not reasonably calculated to lead to the discovery of admissible evidence However an objection to discovery claiming that the sought-after information is not reasonably calculated to lead to discovery of admissible evidence is a legally insufficient reason to prevent discovery Murray Van Storage Inc Murray So 2d Fla 4th DCA Discovery responses containing bare-boned objections without more are stricken as a matter of course as such objections must be plead with specificity Christie Hixson So 2d Fla 4th DCA Furthermore the concept of relevancy is broader in the discovery context than in trial context a party may be permitted to discover relevant evidence that would be inadmissible at trial if it may lead to the discovery of relevant evidence Allstate Ins Co Langston So 2d Fla As such Epstein submits that these objections be stricken and answers compelled Moreover because a causal connection between the information sought from Edwards and its possible relevance to issues in the pending action is readily apparent production of the requested information is required Calderbank Cazares So.2d Fla 5th DCA Specifically Edwards has sued Epstein for Malicious Prosecution and as a result is claiming damages including punitive damages in the instant case In support of his claim Edwards asserts that he was not involved with the fraudulent Ponzi scheme at RRA that the litigation he conducted in the Epstein cases both before and after joining RRA was appropriate and that Epstein was aware of this when Epstein filed suit against him However the allegations made by the Federal Government and the attorneys who filed the Razorback Complaint the expenditures Tonja Haddad P.A SE th Street Fort Lauderdale FL on improper pleadings discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel as well as a subsequent Federal court order characterizing one of those motions as entirely without merit all of which are discussed in detail in Epsteins Motion for Summary Judgment make Epsteins request for information about such expenditures as well as the rationale for engaging in same relevant See also Behm Cape Lumber Co So 2d Fla 2d DCA stating that proper discovery includes records and information that are relevant to the calculation of damages emphasis added This request is narrowly tailored to include only the three cases Edwards was prosecuting against Epstein while he was a partner at RRA which is the crux of this litigation something put at issue by Edwards in his Counterclaim Accordingly Edwards should be compelled to respond Next Edwards asserts that the remainder of the requested information in Interrogatories five and six and all of the information requested in Interrogatories eight and nine is protected by the work product privilege This contention fails for two reasons First Edwards failed to properly assert the privilege as mandated by Rule of the Florida Rules of Civil Procedure and prevailing case law see TIG Insurance Corp of America Johnson So 2d Fla 4th DCA stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the privilege and second Florida Rule of Civil Procedure permits discovery of fact work product where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means Vesta Fire Ins Corp Figueroa So 2d Fla 5th DCA Ashemimry Ba Nafa So 2d Fla 5th DCA Here Edwards failed to create a proper privilege log in response to the above-referenced requests Additionally the alleged work product costs Tonja Haddad P.A SE th Street Fort Lauderdale FL and expenses incurred in prosecuting cases against Epstein is not only necessary to assert the alleged cause of action but also to properly assess the alleged damages suffered by Edwards Finally neither the information nor its substantial equivalent can be obtained by any other means thereby satisfying Rule of the Florida Rules of Civil Procedure II Epsteins Discovery Requests to Edwards dated April In response to Epsteins Request to Produce dated April Edwards made the following impermissible objections to wit Any and all fee agreements that exist or have existed between the following a Any Plaintiff and Bradley Edwards or any entity with which he has been associated Any Plaintiff and the law firm RRA ANSWER a Objection relevance not reasonably calculated to lead to the discovery of admissible evidence None All fee sharing agreements between Bradley Edwards RRA or Scott Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiffs case ANSWER Objection relevance not reasonably calculated to lead to the discovery of admissible evidence vague overbroad without waiving objection there are no fee agreements with any investor All documents evidencing the Costs and payment of any bill or Costs in each Plaintiffs case against Jeffrey Epstein and the source for said payments of any Costs ANSWER Objection relevance not reasonably calculated to lead to the discovery of admissible evidence All documents received by you or your current firm where in the Trustee of RRA has asserted a lien for attorneys fees or Costs arising out of work done and Costs incurred related to the Plaintiffs cases during the time Plaintiffs were represented by RRA ANSWER Objection relevance not reasonably calculated to lead to the discovery of admissible evidence All documents related to the amount of all Costs that were incurred by you in the representation of you and/or your law firm in representing Jane Doe L.M and E.W prior to joining RRA ANSWER Tonja Haddad P.A SE th Street Fort Lauderdale FL Objection relevance not reasonably calculated to lead to the discovery of admissible evidence All documents setting forth to the amounts of Costs were incurred by RRA in its representation of Jane Doe L.M and E.W during the time you were employed by RRA or that is being claimed by the Trustee ANSWER Objection relevance not reasonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege The written fee agreement with Searcy Denney firm for their representation of you in this case ANSWER Objection Edwards objects to the above-cited Requests to Produce on the purported grounds of relevance not reasonably calculated to lead to the discovery of admissible evidence when he bothers stating grounds at all However an objection to discovery claiming that the sought-after information is not reasonably calculated to lead to discovery of admissible evidence is a legally insufficient reason to prevent discovery Murray Van Storage Inc Murray So 2d Fla 4th DCA Discovery responses containing bare-boned objections without more are stricken as a matter of course as such objections must be plead with specificity Christie Hixson So 2d Fla 4th DCA As such as long as the discovery requested is relevant to the cause of action as to any claim or defense and is not otherwise subject to a privilege it is discoverable In fact the concept of relevancy is broader in the discovery context than in trial context a party may be permitted to discover relevant evidence that would be inadmissible at trial if it may lead to the discovery of relevant evidence Allstate Ins Co Langston So 2d Fla In support of his Malicious Prosecution claim against Epstein Edwards asserts that he was not involved with the fraudulent Ponzi scheme at RRA that the litigation he conducted in the Epstein cases both before and after joining RRA was appropriate and that Epstein was aware of this when Epstein filed suit against him In order for Epstein respond to and defend against these assertions a comparison of the litigation Edwards Tonja Haddad P.A SE th Street Fort Lauderdale FL conducted in the Epstein cases both before and after he joined the lawfirm that was using those same cases to perpetuate the Ponzi scheme is certainly relevant and appropriate One significant aspect of that comparison involves an analysis of the amount of funds expended in connection with Edwardss prosecution of cases against Mr Epstein before and after Edwards joined RRA Epsteins requests are relevant to these issues and Epstein submits that these objections are improper and should be stricken and that answers should be compelled Moreover it is legally impermissible to object to a discovery request then provide a response without waiving the objection This kind of response fails to either object or respond to the Request and is deemed an incomplete or evasive answer Rule a of the Florida Rules of Civil Procedure provides that for purposes of this subdivision an evasive or incomplete answer shall be treated as a failure to answer FLA R.Clv Accordingly the responding party must either object to or agree to produce each item or category of items requested Failure to do so can subject the party to sanctions under Rule a of the Florida Rules of Civil Procedure Consequently Edwards must respond I Epsteins Discovery Requests to Edwards dated December In response to Epsteins Interrogatories dated December Edwards made the following impermissible objections to wit State the amount of gross income that you received from providing services as a lawyer for each of the years and and identify the source of that income including the payor of the same ANSWER Objection Irrelevant immaterial not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards right to economic privacy State the amount of gross income that you received from the provision of goods or services other than while acting as a lawyer for each of the years and and identify the source of that income including the payor of the same ANSWER Tonja Haddad P.A SE th Street Fort Lauderdale FL Objection Irrelevant immaterial not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards right to economic pnvacy State the amount of hours that you have devoted to pro bono work for the years and and substantiate your answer with the names of the cases or causes for which you provided such service ANSWER Objection Irrelevant immaterial and not reasonably calculated to lead to the discovery of admissible evidence State each instance in which you have spoken to or communicated with the press or any other media representative relating to Plaintiff Jeffrey Epstein Provide the identity of each contact the date of the contact and a description of the communication ANSWER Objection Attorney work product privilege except to the extent that Bradley Edwards is identified as a source of information in published reports which are as easily available to Jeffrey Epstein as to Bradley Edwards through internet searches Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein Identify contacts with government/law enforcement media other attorneys or anyone else from which you claim to form this belief including the names dates substance of communication etc ANSWER Objection Attorney work-product and statutorily restricted communications with law enforcement and prosecutorial authorities Irrelevant immaterial and not reasonably calculated to lead to the discovery of admissible evidence Identify the basis for your claim that others still persist in prosecuting claims against the Plaintiff/Counter-Defendant Jeffrey Epstein Identify the persons still prosecuting claims against the Plaintiff/Counter-Defendant or with knowledge of the persons still prosecuting claims against him including names dates of contact with such persons substance of communication etc ANSWER Objection Attorney work-product and statutorily restricted communications with law enforcement and prosecutorial authorities Irrelevant immaterial and not reasonably calculated to lead to the discovery of admissible evidence Identify all third parties non-clients who received or made payments in connection with the client cases or purported client cases against the Plaintiff/Counter-Defendant Jeffrey Epstein and with specificity I explain the relationship of such third parties list the payments made to or by each and list the date of payments and purpose of payments Your answer should include without limitation all investigators witnesses referring persons referring attorneys outside counsel outside experts It should also include any and all payments made to or by investors in any of the client cases against the Tonja Haddad P.A SE th Street Fort Lauderdale FL Plaintiff/CounterDefendant Jeffrey Epstein or payments made by or to any other person in connection with the client cases ANSWER Objection Irrelevant immaterial and not reasonably calculated to lead to the discovery of admissible evidence First Edwards objects to the above-cited Interrogatories numbered fourteen fifteen sixteen twenty-four twenty seven twenty-eight and thirty one on the purported grounds of relevance not reasonably calculated to lead to the discovery of admissible evidence The law is clear that an objection to discovery claiming that the sought-after information is not reasonably calculated to lead to discovery of admissible evidence is a legally insufficient reason to prevent discovery Murray Van Storage Inc Murray So 2d Fla 4th DCA Discovery responses containing bare-boned objections without more are stricken as a matter of course as such objections must be plead with specificity Christie Hixson So 2d Fla 4th DCA Furthermore the concept of relevancy is broader in the discovery context than in trial context a party may be permitted to discover relevant evidence that would be inadmissible at trial if it may lead to the discovery of relevant evidence Allstate Ins Co Langston So 2d Fla As such Epstein submits that these objections be stricken and answers compelled Moreover because a causal connection between the information sought from Edwards and its possible relevance to issues in the pending action is readily apparent production of the requested information is required Calderbank Cazares So.2d Fla 5th DCA Specifically Edwards has sued Epstein for Malicious Prosecution and as a result is claiming damages and indeed must prove damages as an essential element of his claim Edwards is also asserting a punitive damages claim against Epstein in this case In support of his claim Edwards asserts that he was not involved with the fraudulent Ponzi scheme at RRA that the litigation he Tonja Haddad P.A SE th Street Fort Lauderdale FL conducted in the Epstein cases both before and after joining RRA was appropriate and that Epstein was aware of this when Epstein filed suit against him In order for Epstein respond to and defend against these assertions a comparison of the litigation Edwards conducted in the Epstein cases both before and after he joined the lawfirm that was using those same cases to perpetuate the Ponzi scheme is certainly relevant and appropriate One significant aspect of that comparison involves an analysis of the amount of funds expended in connection with Edwardss prosecution of cases against Mr Epstein before and after Edwards joined RRA especially when many of the tactics engaged in by RRA relative to the Epstein cases was questionable to many including the Federal court As such the above-referenced requests are on their face relevant to the instant cause of action mandating that the information be provided See also Behm Cape Lumber Co So 2d Fla 2d DCA stating that proper discovery includes records and information that are relevant to the calculation of damages emphasis added Next Edwards mistakenly objects to Interrogatories numbered fourteen fifteen and sixteen which request his financial information on the grounds of economic right to privacy Although the general rule in Florida is that personal financial information is not discoverable this rule is not without exceptions The pertinent exception here is that personal financial material is discoverable in cases where such information is relevant to subject matter of the pending litigation Friedman Heart Institute of Port St Lucie Inc So 2d Fla Epstein Epstein So 2d Fla 3d DCA When a party voluntarily puts his personal financial information at issue courts will compel production of personal financial information Friedman So 2d at Woodward Berkery So 2d Fla 4th DCA A partys finances if relevant to the disputed issues of the underlying action are not excepted from discovery and courts will compel production of personal financial Tonja Haddad P.A SE th Street Fort Lauderdale FL documents and information if shown to be relevant by the requesting party Florida Gaming Corp of Delaware American Jai-Alai Inc So 2d Fla 4th DCA holding that the financial information at issue was relevant to the calculation of damages under the cause of action and as such financial discovery was proper In the case at hand it is irrefutable that Edwardss financial information is relevant in fact it was he who put it at issue in his claims for damages The damages allegedly suffered by Edwards are not only a contested issue in this case but also a requisite element to his causes of action Moreover Edwards financial remuneration after joining RRA are relevant to any motives he may have had after he joined RRA to cooperate with Rothstein in the use of the Epstein cases at RRA to perpetrate the Ponzi scheme Accordingly the financial information sought must be turned over Third Edwards asserts attorney work-product and statutorily restricted communications with law enforcement and prosecutorial authorities as an objection to Interrogatories numbered twenty-seven and twenty-eight Edwards cites no authority for the alleged statutorily restricted communications with law enforcement and prosecutorial authorities and indeed there is no such privilege provided for in the law Accordingly a response to these Interrogatories is required If this information were in fact attorney work product as asserted by Edwards he failed to provide a privilege log as legally required by Rule of the Florida Rules of Civil Procedure and prevailing case law see TIG Insurance Corp of America Johnson So 2d Fla 4th DCA stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the privilege Moreover Florida Rule of Civil Procedure permits discovery of work product where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means Vesta Fire Ins Corp Figueroa So 2d Fla 5th DCA Ashemimry Ba Tonja Haddad P.A SE th Street Fort Lauderdale FL Nafa So 2d Fla 5th DCA Here the alleged work product communications between Edwards and the press assuming it is even work product cannot be obtained through any other means thereby satisfying Rule of the Florida Rules of Civil Procedure Finally Edwards asserts in his objection to Interrogatory numbered twenty-four that the information requested communications with the press is attorney work product privilege This is not a legal or proper response and as such Edwards should be compelled to provide a proper response to this Interrogatory In response to Epsteins Request to Produce dated December Edwards made the following impermissible objections to wit Each and every document that tends to support the claim in your Second Amended Counterclaim that you have suffered damage to your reputation as a result of the filing of this action against you ANSWER Objection The identification of documents that tend to support a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege Each and every document that tends to support the claim in your Second Amended Counterclaim that you have suffered damage as a result of interference in your professional relationships ANSWER Objection The identification of documents that tend to support a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege Each and every document that tends to support any claim you are making for special damages including loss of income this request specifically shall include but not be limited to production of your federal income tax returns for and records of income in ANSWER Objection The identification of documents that tend to support a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege Each and every document that tends to support the claim in your Second Amended Counterclaim that you have suffered money damages resulting from the loss of the value of your time diverted from your professional responsibilities this request specifically shall include but not be limited to the production of all your time and billing records calendars and diaries from through the date on which you respond to this request Tonja Haddad P.A SE th Street Fort Lauderdale FL ANSWER Objection The identification of documents that tend to support a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege Each and every document including but not limited to invoices and statements that tends to support the claim in your Second Amended Counterclaim that you have paid money or incurred obligations to pay money for your defense in this lawsuit ANSWER Objection The identification of documents that tend to support a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege Each and every document reflecting gross collections received from your providing services as a lawyer for each of the years and ANSWER Objection Overly broad not reasonably calculated to lead to the discovery of admissible evidence privileged pursuant to Bradley Edwards right and the rights of his clients law partners and associates to economic privacy and in some circumstances subject to contractual confidentiality provisions Each and every document reflecting the identity of the confidential source listed on your Privilege Log dated February ANSWER Objection Attorney work product privilege Each and every document reflecting the legal authority that justifies your refusal to disclose the identity of the person identified as a confidential source in your Privilege Log dated February ANSWER Objection Attorney work product privilege All closing statements for all clients who you represented that brought claims against the Plaintiff and all other documents with respect to such clients reflecting amounts paid to such clients or to you your time ref erring attorneys and amounts paid to the same advance costs and payments to any other person or entity ANSWER Objection Overly broad not reasonably calculated to lead to the discovery of admissible evidence privileged pursuant to Bradley Edwards right and the rights of his clients law partners and associates to economic privacy and in some circumstances subject to contractual confidentiality provisions All records of your contacts with the press or other media outlets ANSWER Objection Attorney work product privilege except to the extent that Bradley Edwards is identified as a source of information in published reports which are as easily available to Jeffrey Epstein as to Bradley Edwards through internet searches Tonja Haddad P.A SE th Street Fort Lauderdale FL In these responses Edwards is asserting a work product privilege when asked about the specific information upon which he relies in asserting his claims against Epstein information that is crucial to his prosecution of the case and Epsteins defense of same It is also information that Edwards himself put at issue in this case Rule of the Florida Rules of Civil Procedure delineates the requisites one must follow when claiming a privilege to information requested in discovery and provides When a party withholds information otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material the party shall make the claim expressly and shall describe the nature of the documents communications or things not produced or 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 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 or the privilege is waived See TIG Insurance Corp of America Johnson So 2d Fla 4th DCA stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the privilege Here because Edwards repeatedly asserted privilege response to each of the above-cited Requests to Produce and failed to provide a privilege log he has waived his right to the privilege and production should be compelled Furthermore Florida Rule of Civil Procedure permits discovery of work product where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means Vesta Fire Ins Corp Figueroa So 2d Fla 5th DCA Ashemimry Ba Nafa So 2d Fla 5th DCA Here the alleged work product is the very information the proof upon which Edwards is relying to prosecute this cause of action against Epstein As such this information cannot be Tonja Haddad P.A SE th Street Fort Lauderdale FL obtained through any other means thereby satisfying Rule of the Florida Rules of Civil Procedure and requiring that Edwards respond Finally Edwards asserts his economic right to privacy and that of others as grounds for his failure to provide responses to Requests to Produce numbered eleven and eighteen However it is well-settled law that personal financial material is discoverable in cases where such information is relevant to subject matter of the pending litigation Friedman Heart Institute of Port St Lucie Inc So 2d Fla Epstein Epstein So 2d Fla 3d DCA When a party voluntarily puts his personal financial information at issue such as Edwards has done in the instant case courts will compel production of personal financial information Friedman So 2d at A partys finances if relevant to the disputed issues of the underlying action are not excepted from discovery and courts will compel production of personal financial documents and information if shown to be relevant by the requesting party Florida Gaming Corp of Delaware American Jai-Alai Inc So 2d Fla 4th DCA holding that the financial information at issue was relevant to the calculation of damages under the cause of action and as such financial discovery was proper In the case at hand it is irrefutable that Edwardss financial information is relevant in fact it was he who put it at issue in his claims for damages The damages allegedly suffered by Edwards are not only a contested issue in this case but also a requisite element to his cause of action Moreover Edwards financial remuneration after joining RRA are relevant to any motives he may have had after he joined RRA to cooperate with Rothstein in the use of the Epstein cases at RRA to perpetrate the Ponzi scheme Accordingly the financial information sought must be turned over Finally Epstein certifies that he in good faith has conferred or attempted to confer with Tonja Haddad P.A SE th Street Fort Lauderdale FL the person or party failing to make the discovery in an effort to secure the information or material without court action FLA R.CIV CONCLUSION Accordingly for all of the reasons delineated above and in reliance upon the applicable law cited herein Plaintiff Jeffrey Epstein respectfully requests that this Court enter an Order striking Bradley Edwards Objections to the Discovery requests delineated above compelling him to respond in full to Epsteins Discovery requests and such other and further relief as this Court deems proper WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service to all parties on the attached service list this September Isl Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE th Street Suite Fort Lauderdale Florida facsimile Tonja TonjaHaddad.com Efiling Tonjahaddad.com Attorneys for Epstein Tonja Haddad P.A SE th Street Fort Lauderdale FL SERVICE LIST CASE NO Jack Scarola Esq sx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews A venue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com SE 7th Street Suite Fort 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