Epstein Secrets

ttorney's Office—regarding the subject of the lawsuit or Jeffrey Epstein? A. Same objection and instruction. Q. All right. Did you ever speak with Marie Villafana during the pendency of that litigation which is still pending today? SCAROLA: Are you asking whether such conversations occurred that were relevan

re. SCAROLA: Then the instruction remains the same. The objection remains the same. Q. So, even if, do you - even if you talked about it with Mrs. Villafana, even if your client Mr. Edwards spoke with Mrs. Villafana about a scheduling issue, it's your position that its what, work-product? A. SCAROLA: T

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.

Jeffrey Epstein? Id. at page 101-102; line 24-6. MR. SCAROLA: Same objection and instruction. Id. at page 102; line?-8. Q: Did you ever speak with Marie Villafana during, during the pendency of that litigation which is still pending today? Transcript of Deposition dated March 23, 2010, page 102-03; line 24-1.

dad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799406 Q: So, even if; do you — even if you talked about it with Mrs. Villafana, even if your client Mr. Edwards spoke with Mrs. Villafana about a scheduling issue, it's your position that that is what, work-product? Id. at pag

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

12 13 14 15 16 17 18 19 20 21 22 23 24 25 Judge, next we're at page 11. The subject matter turns to Mr. Edwards' communications with Maria Villafana, who is the United States attorney -- assistant United States attorney involved in the Epstein cases. Question: My question is only did you spea

- what specifically are the questions that you believe need to be answered? Discussions that Mr. Edwards may have had with respect to or with Ms. Villafana, the U.S. attorney, I don't know what that has to do with this particular case, other than to suggest that if in fact Mr. Edwards was pursuing th

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

Jeffrey Epstein? Id. at page 101-102; line 24-6. MR. SCAROLA: Same objection and instruction. Id. at page 102; line?-8. Q: Did you ever speak with Marie Villafana during, during the pendency of that litigation which is still pending today? Transcript of Deposition dated March 23, 2010, page 102-03; line 24-1.

ction remains the same. The objection remains the same. Id. at page 103; line 14-16.4 Q: So, even if; do you — even if you talked about it with Mrs. Villafana, even if 'The objection is: "If that is information that you obtained in the course of your responsibilities in representation of any client I woul

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