Epstein Secrets

orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume

unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

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

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.

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:

-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.

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: