Filing # 31897743 E-Filed 09/10/2015 12:44:35 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S MOTION FOR FINDING OF WAIVER BASED ON PLAINTIFFS' FAILURE TO PROVIDE A PRIVILEGE LOG OR, IN THE ALTERNATIVE, TO COMPEL PLAINTIFFS TO PROVIDE AN ITEMIZED PRIVILEGE LOG Defendant/Counterclaim Plaintiff ALAN M. DERSHOWITZ ("Dershowitz") respectfully moves this Court for entry of an Order ruling that Plaintiffs BRADLEY J. EDWARDS ("Edwards") and PAUL G. CASSELL ("Cassell") (together, "Plaintiffs") have waived any privilege or protection that may have otherwise applied to documents and information that are responsive to Dershowitz's discovery requests. In the alternative, Dershowitz requests that the Court enter an Order compelling Plaintiffs to provide an itemized privilege log by a date certain. On February 11, 2015, Dershowitz served his First Sets of Document Requests and First Sets of Interrogatories on each of the Plaintiffs, individually (collectively, the "Initial Discovery Requests"). On March 13, 2015, Plaintiffs served their responses to the Initial Discovery Requests, which asserted that many of the documents and much of the information sought by Dershowitz are protected by the attorney-client privilege and/or the work product doctrine. See EFTA00608894