Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 16 of 34
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, et al., Plaintiffs / Counterclaim Defendants, V.
DERSHOWITZ,
Defendant / Counterclaim Plaintiff. /
DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ’S OBJECTIONS AND RESPONSES TO PLAINTIFFS’ INITIAL REQUESTS FOR PRODUCTION
Defendant/Counterclaim Plaintiff Alan M. Dershowitz (“Defendant”) submits the following objections and responses to the Plaintiffs’ Initial Request for Production (“Document Requests”) propounded by Plaintiffs/Counterclaim Defendants Bradley J. Edwards and Paul G. Cassell (“Plaintiffs”).
PRELIMINARY STATEMENT
These responses and objections reflect the current state of Defendant’s knowledge regarding the matters discussed herein. Defendant has not completed his discovery or trial preparation in this matter. Accordingly, Defendant reserves the right to revise, correct, clarify, supplement, or amend his objections and responses to reflect information hereafter discovered or acquired. These responses and objections are provided without prejudice to the rights of Defendant to use or rely upon subsequently discovered information or documents at any time,
including at trial. The fact that a Document Request has been complied with in part shall not be
construed as a waiver of all or any part of any objection that Defendant might or could make to
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