Epstein Secrets

stions as well: Q. What connection, if any, did Ghislaine Maxwell have to [your three clients]? MR. SCAROL

uct privilege. Id. at 126-127. Edwards wrongfully claimed the work product privilege for these questions as well: Q. What connection, if any, did Ghislaine Maxwell have to [your three clients]? MR. SCAROLA: Objection, work product. Instruct you not to answer. Id. at 155.6 Q. Who did [Mike Fisten] go to Califo

by this time already put considerable allegations concerning the answer to this question into the records. Obviously, his clients' interaction with Maxwell was not intended to be kept in confidence. 7 EFTA00606632 Q. Who other than Mr. Fisten from an investigator, from an internal investigator at

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.

407 A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: Q: Do you, is she neither would you agree that neither Jane Doe nor L.M. have testified to any, that they had any connection whatsoever with Ghisl

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

e the same or similar information is available through ordinary investigative techniques and discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga

-23. A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: 6 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• EFTA00585399 Q: Do you, is she neither would you agree that neither Jane D

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

ques and 19 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585412 discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga

ut I am just going through the questions that refused to be answered at this time. Next it discusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she neither -- would you agree that neither Jane Doe nor LM" -- who are, again, Mr. Edwards' two clients

scusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she ne

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