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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:
201; line 4-6. MR. SCAROLA: Same objection, same instruction. Id. at page 201; line 7-9. Q: If you're unaware of the existence of the entity called Blue Line Research and Development, LLC, would it be a correct statement that you have never authorized anyone from Blue Line Research and Development, LLC, to conduc
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
201; line 4-6. MR. SCAROLA: Same objection, same instruction. Id. at page 201; line 7-9. Q: If you're unaware of the existence of the entity called Blue Line Research and Development, LLC, would it be a correct statement that you have never authorized anyone from Blue Line Research and Development, LLC, to conduc
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. at 90. Later, when asked "for what purpose did Ms. L.M. originally hire you?," his attorney o
orm any investigation on the Epstein files? A. SCAROLA: Same objection and instruction. Q. If you're unaware of the existence of the entity called Blue Line Research and Development, LLC, would it be a correct statement that you have never authorized anyone from Blue Line Research to conduct any investigation of
Entities connected to both E.W. and Blue Line Research

George W. Bush
PERSON
Jeffrey Epstein
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSONJane Doe
PERSONJack Goldberger
PERSONJack Scarola
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
Donald Trump
PERSON
United States
LOCATION
Bill Clinton
PERSON
David Copperfield
PERSON
Marc Rich
PERSON
Michael Fisten
PERSONAtterbury
ORGANIZATIONPalm Beach Lakes Blvd
LOCATION
Alfredo Rodriguez
PERSON
Ghislaine Maxwell
PERSON