Epstein Secrets

ions with Jaffe Are Privileged "An attorney-client relationship is established where there is an explicit undertaking to perform a specific task." Pellegrino v. Oppenheimer a Co., 49 A.D.3d 94, 99, 851 N.Y.S.2d 19 (2008). Defendant has sworn that she hired Jaffe in 2009 to represent her in connection wit

l defense interest, which cloaks related communications in privilege, and a common problem, to which the privilege does not apply. Cgiazaryan, 290 F.R.D. at 434 (citing Finkeiman v. Klaus, 2007 WL 4303538, at *4 (N.Y.Sup.Ct. Nov. 28, 2007)). "IA] limited common purpose (that) necessitates disclosure"

Id. For the "experience-and-logic" approach, courts employ a two-pronged inquiry. Doe, 2019 U.S. Dist. LEXIS 36605, at *4; Hartford Courant Co. v. Pellegrino, 380 F.3d 83, 92 (2d Cir. 2004). First, courts must consider "whether the place and process have historically been open to the press and general pu

ore difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.') (quoting In re EPDM, 255 F.R.D. at 319). Since the Protective Order does not address specific deposition testimony or exhibit documents, the parties do not have demonstrated relian

Id. For the "experience-and-logic" approach, courts employ a two-pronged inquiry. Doe, 2019 U.S. Dist. LEXIS 36605, at *4; Hartford Courant Co. v. Pellegrino, 380 F.3d 83, 92 (2d Cir. 2004). First, courts must consider "whether the place and process have historically been open to the press and general pu

ore difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.') (quoting In re EPDM, 255 F.R.D. at 319). Since the Protective Order does not address specific deposition testimony or exhibit documents, the parties do not have demonstrated relian