Epstein Secrets

age 5 attached Exhibit "A", Affidavit of Jack A. Goldberger, a board certified criminal defense attorney who

e copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger EFTA00222107 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 34 of 37 Jane Doe No. 2 v. Epstein Page 33 Clearly, t

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

so those questions are still objected to, unresolved. So, we'll stoppage We will go from there, see what happens. Id. at page 98; lines 13-18. MR. GOLDBERGER: Well, wait a minute. Just one thing... So if we had asked the same questions, he would have raised the same objections, so not only are we going t

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:

so those questions are still objected to, unresolved. So, we'll stoppage We will go from there, see what happens. Id. at page 98; lines 13-18. MR. GOLDBERGER: Well, wait a minute. Just one thing... So if we had asked the same questions, he would have raised the same objections, so not only are we going t

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: