Epstein Secrets

viduals. Mr. Scarola agreed. Id. at 203, 0 4-16. 13 Epstein's counsel proceeded to other areas of inquiry. He asked if Edwards had ever spoken to Alfredo Rodriguez during the hiatus between the deposition sessions with Rodriguez. A claim of work product privilege was made. Id. At 205-206. Edwards refused to 10

roceeded to other areas of inquiry. He asked if Edwards had ever spoken to Alfredo Rodriguez during the hiatus between the deposition sessions with Rodriguez. A claim of work product privilege was made. Id. At 205-206. Edwards refused to 10 EFTA00606635 answer any questions about his communications wit

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.

t Mr. Rodriguez completed his deposition on August 7th of 2009, did you have an occasion to speak with either the FBI, well, with the FBI regarding Alfredo Rodriguez?/d. at page 20; line 11-15. MR. SCAROLA: Same objection, same instruction. Id. at page 210; line 16-17. Q: Did you after Mr. Rodriguez's completion of

e 16. The subject matter of the deposition turned to Alfredo Rodriguez. Counsel for Epstein attempts to discuss the two separate dates on which Mr. Rodriguez was deposed in the Epstein cases and seeks to determine the scope of Mr. Edwards's knowledge of Mr. Rodriguez: Q: Between those two dates, that is

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

iles?" "Same objection." Judge, you can go through again, that goes to -- Mr. Scarola objects to every question asked. Then the subject turns to Alfredo Rodriguez. Mr. Epstein's attorney attempted to ask on two separate dates about Mr. Rodriquez in the deposition. And again, the first question, Judge -- you

ts to every question asked. Then the subject turns to Alfredo Rodriguez. Mr. Epstein's attorney attempted to ask on two separate dates about Mr. Rodriquez in the deposition. And again, the first question, Judge -- you can look at he dates and see how germane these issues Palm Beach Reporting Service,

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

t Mr. Rodriguez completed his deposition on August 7th of 2009, did you have an occasion to speak with either the FBI, well, with the FBI regarding Alfredo Rodriguez?/d. at page 20; line 11-15. MR. SCAROLA: Same objection, same instruction. Id. at page 210; line 16-17. Q: Did you after Mr. Rodriguez's completion of

e 16. The subject matter of the deposition turned to Alfredo Rodriguez. Counsel for Epstein attempts to discuss the two separate dates on which Mr. Rodriguez was deposed in the Epstein cases and seeks to determine the scope of Mr. Edwards's knowledge of Mr. Rodriguez: Q: Between those two dates, that is

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