Epstein Secrets

ranscript at 50, 54, 91, 100-104, 114, 126,-127, 155, 170, 181, 184-187, 192, 198-202, 205-206, 208-210, 212, 215-217; Exhibit 1. Forty years ago, the Florida Supreme Court, in Surf Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), gave this general definition of work product saying what it is and what it is no

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.

12 13 14 15 16 17 18 19 20 21 22 23 24 25 -- the case had basically not been actively prosecuted in this court until June 2017 when the Florida Supreme Court issued its final ruling. So should the Court grant our motion, we did preserve the right to redepose Mr. Edwards on these issues. We feel not onl

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

ed in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), explained what is covered by the work product privilege: [T]hose documents, pictu

f whether they pertain to confidential communications between attorney and client. Fla. R. Civ. P. 1.280(b)(2). See Southern Bell Tel. & TeL Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). Work product is a qualified immunity from discovery. See DeBartolo-Aventura, Inc. v. Hernandez, 638 So. 2d 988 (Fla.