Epstein Secrets

in, possesses the power to move forward with its criminal prosecution against EPSTEIN. EPSTEIN entered into a Non-Prosecution Agreement ("NPA") with United States Attorney General's Office for the Federal Southern District of Florida. The terms and conditions of the NPA also entailed EPSTEIN entering into a Pl

name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2. All documents referring or relating to the United States' agreement with Defendant to defer federal prosecution subject to certain conditions, including without limitation, the operative agreement between

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

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

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:

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

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: