Epstein Secrets

you may respond. Id. at p.100; line 15-22. THE WITNESS: I cannot respond. Id. at page 100; line 23. Q: Prior to the filing of the lawsuit against Jane Doe 1 and Jane Doe 2 against the United States Government, did you learn from any source, maybe a document, maybe a telephone call or a conversation that

a version of the testimony which has been edited or glossed by the deponent's lawyer." Quantrachrome Corpage v. Micrometrics Instrument Corp., 189 F.R.D. 697, 701 (S.D. Fla. 1999). Rule 1.310(c) of the Florida Rules of Civil Procedure governs depositions upon oral examination and states, in relevant part:

ing these protections meaningless in attempting EFTA00222075 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page 2 to assert and argue the factual basis for the additional objections and privileges. See part ILA. herein. I. Defendant E

ly, the privileges recognized under state law apply to this action under Rule 501. See, for example, 1550 Brickell Associates v. Q.B.E. Ins. Co. 253 F.R.D. 697, 699 (S.D. Fla. 2008)("Attorney-client privilege is governed by state law in diversity actions."). §90.503(2), Fla. Stat., provides — (2) A patie

you may respond. Id. at p.100; line 15-22. THE WITNESS: I cannot respond. Id. at page 100; line 23. Q: Prior to the filing of the lawsuit against Jane Doe 1 and Jane Doe 2 against the United States Government, did you learn from any source, maybe a document, maybe a telephone call or a conversation that

a version of the testimony which has been edited or glossed by the deponent's lawyer." Quantrachrome Corpage v. Micrometrics Instrument Corp., 189 F.R.D. 697, 701 (S.D. Fla. 1999). Rule 1.310(c) of the Florida Rules of Civil Procedure governs depositions upon oral examination and states, in relevant part: