Epstein Secrets

ion of Jeffrey Epstein? MR. SCAROLA: Same objection [work-product, attorney-client privilege]. Id., at 201. Q. [D]id you ever authorize or direct Ken Jenne to perform any investigation on the Epstein files? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and instruction. 12. Co

s to confidential communications made in the rendition of legal services to the client. Section 90.502, Fla. Stat.; Southern Bell Tel. & TeL Co. v. Deason, 632 So. 2d 1377 (Fla.1994). Section 90.502 codifies the attorney-client privilege which protects those confidential communications between attorney

of whether they pertain to confidential communications between attorney and client. F1a.R.Civ.P. 1.280(b)(2). See Southern Bell TeL & Tel. Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). The privilege may also protect an attorney's mental impressions which may be disclosed through testimony. Hamilton v.

uld not respond on the basis of privilege. Id. at page 288; line 15-21. A: Privilege. Id. at page 288; line 22. Counsel for Epstein then discusses Ken Jenne: Q: Did Mr. Jenne, did you ever direct Mr. Jenne to do any investigation on the Epstein cases? Transcript of Deposition dated March 23, 2010, at pa

e the same or similar information is available through ordinary investigative techniques and discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga

tic) -- purpose of the conversation with this officer. No answer, yet he's listed on the witness list at this time. Then the conversation turns to Ken Jenne, former Sheriff who worked at RRA during the time in question. THE COURT: What page are you on? MS. HADDAD COLEMAN: I'm at the top of page 15. S

ng this 518 Southern And again, the was quoted by the Florida Supreme Court in 1994 in the Southern Bell Telephone and Telegraph Company versus Deason. Frankly, Judge, if the Court wants me to go through the other objections that were raised in deposition that have no basis in law in a depositio

uld not respond on the basis of privilege. Id. at page 288; line 15-21. A: Privilege. Id. at page 288; line 22. Counsel for Epstein then discusses Ken Jenne: Q: Did Mr. Jenne, did you ever direct Mr. Jenne to do any investigation on the Epstein cases? Transcript of Deposition dated March 23, 2010, at pa

ques and 19 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585412 discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga