This document is a notice of hearing and a motion filed by Jeffrey Epstein in the Circuit Court of the 15th Judicial Circuit in Palm Beach County, Florida. The notice sets a hearing for April 1, 2011, regarding Epstein's motion to overrule objections and compel Bradley J. Edwards to answer questions and appear for further deposition. The motion argues that Edwards improperly invoked attorney-client and work-product privileges during his deposition, preventing Epstein from obtaining necessary information related to a lawsuit involving an alleged pyramid scheme by Scott Rothstein and Edwards. The document includes a legal memorandum supporting the motion, citing relevant case law and arguing against the validity of the objections raised by Edwards and his counsel.
documents/EFTA01069498.pdf
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