Epstein Secrets

in, 495 So. 2d at 262; Alachua Gen. Hosp. v. Zimmer USA, Inc., 403 So. 2d 1087, 1088 (Fla. 1st DCA 1981) (privilege continues after case concludes); United States v. International Business Machs. Corp., 66 F.R.D. 154, 178 (S.D.N.Y.1974) (privilege applies only if the work product was gathered in anticipation o

ion of Jeffrey Epstein? MR. SCAROLA: Same objection [work-product, attorney-client privilege]. Id., at 201. Q. [D]id you ever authorize or direct Ken Jenne to perform any investigation on the Epstein files? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and instruction. 12. Co

Q: Have the only conversations that you have had with Ms. Marie Villfana or Villafana, have they only been in the context of Jane Doe 1 and 2 versus United States of America, only in the context of that case? Id. at page 216; line 9-13. 11 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223

uld not respond on the basis of privilege. Id. at page 288; line 15-21. A: Privilege. Id. at page 288; line 22. Counsel for Epstein then discusses Ken Jenne: Q: Did Mr. Jenne, did you ever direct Mr. Jenne to do any investigation on the Epstein cases? Transcript of Deposition dated March 23, 2010, at pa

Q: Have the only conversations that you have had with Ms. Marie Villfana or Villafana, have they only been in the context of Jane Doe 1 and 2 versus United States of America, only in the context of that case? Id. at page 216; line 9-13. MR. SCAROLA: Same objection. Id. at page 216; line 14. Q: And I will separate out th

uld not respond on the basis of privilege. Id. at page 288; line 15-21. A: Privilege. Id. at page 288; line 22. Counsel for Epstein then discusses Ken Jenne: Q: Did Mr. Jenne, did you ever direct Mr. Jenne to do any investigation on the Epstein cases? Transcript of Deposition dated March 23, 2010, at pa

104 1 2 3 4 on behalf of his clients. MR. CRITTON: So, any question that I ask you with regard to conversations that Mr. Edwards had with the U.S.A.O.'S office, whether it was Mrs. Villafana or anyone else 6 from the time, with regard to the Jane Doe 1 7 and Jane Doe 2 versus U.S.A. case, you w

any area where 14 those files were located. I believe so. 15 Q. Okay. Well, during the time you were 16 there did an individual by the name of Ken Jenne 17 work there? 18 A. Yes. 19 Q. Okay. Did an individual by the name of 20 Mike Fisten work for the firm -- 21 A. Yes. 22 Q. -- for RRA