Epstein Secrets

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

outh, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Br .acHe .LEc .b ls, Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 333

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

outh, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Br .acHe .LEc .b ls, Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 333

in this case, Jack Scarola ("Scarola"), for their flagrant violation of the confidentiality agreements between Epstein and Edwards's clients L.M., E.W., and Jane Doe, as well as enter an Order of entitlement to costs and attorneys' fees in favor of Epstein and against Edwards and Scarola. In support

South, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL

to have dealt with this issue head on because of the apparent implications of same." Hearing Trans. at 60:20-61:14. 33. Counsel for victims L.M., E.W., and Jane Doe also asked Judge Hafele to order Fowler White to explain who they had distributed the confidential materials to. Judge Hafele indicat

ments contained on the discs with Bates numbers added, and provide a set of copied, stamped documents to the Special Master and an identical set to Fanner Jaffe Weissing Edwards Fistos & Lehrman ("Fanner Jaffe"). The Fanner Jaffe attorneys were to then use their set to create its privilege log. [DE 1194]. II. The Court, re

n related costs, expert costs, etc.) that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and is protected by

Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. I East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Br ...da! Es Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301

n related costs, expert costs, etc.) that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and is protected by

Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. I East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Br ...da! Es Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301