Epstein Secrets

Who did [Mike Fisten] go to California to interview? MR. SCAROLA: That is work product and I instruct you not to answer. Id. at 170. Q. Did Mr. Fisten interview a person by the name of Michael Sanka? MR. SCAROLA: That is work product and I instruct you not to answer. Q. Did Mr. Fisten interview a

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.

sition dated March 23, 2010 at page169; line 19-21. A: If you want an exclusive list, I don't know. Id. at page 169; line 22. Q: Did you direct Mr. Fisten to do investigations in California? Id. at page 170; line 8-9. A: I directed Mr. Fisten to interview people and ultimately it was learned that they

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

name that topic?" Mr. Scarola: "Work product, instruct you not to answer." It goes on. "Who" -- at the bottom of page seven. "Who other than Mr. Fisten from an investigator -- from an internal investigator and RRA employee worked on doing investigations on the Epstein files?" Mr. Scarola: "Same o

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

sition dated March 23, 2010 at page169; line 19-21. A: If you want an exclusive list, I don't know. Id. at page 169; line 22. Q: Did you direct Mr. Fisten to do investigations in California? Id. at page 170; line 8-9. A: I directed Mr. Fisten to interview people and ultimately it was learned that they

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