Epstein Secrets

EFTA00606629 1.) For example, Edwards's attorney instructed him when Edwards was asked how one plaintiff, E.W., came to contact referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that

referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that to you." Id. 9. Edwards in one instance when asked what his client E.W. told him on the phone, himself claimed privilege. Id. a

101/20 101/21-22 101/24-25 - 102/1-6 102/7-8 102/24-25 - 103/9-16 A. SCAROLA: Same objection and instruction. Q. Same question with regard to L.M. Miller. A. SCAROLA: Same objection and instruction. Q. And same question with regard to Jane Doe. A. Same objection and instruction. Q. Prior to your f

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

ey's Office? Id. at page 101; line 5-12. MR. SCAROLA: Same objection and instruction. Id. at page 101; line 13-14. Q: Same question with regard to L.M. Miller. Id. at page 101; linel6. MR. SCAROLA: Same objection and instruction. Id. at page 101; line 21-22. Q: Prior to your filing the lawsuit with United

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

ey's Office? Id. at page 101; line 5-12. MR. SCAROLA: Same objection and instruction. Id. at page 101; line 13-14. Q: Same question with regard to L.M. Miller. Id. at page 101; linel6. MR. SCAROLA: Same objection and instruction. Id. at page 101; line 21-22. Q: Prior to your filing the lawsuit with United