Epstein Secrets

rth Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: [email protected] And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile:

822 E-mail: [email protected] And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

07) (internal quotations omitted). The Federal Rules of Civil Procedure are broadly written and "strongly favor full discovery whenever possible." Farnsworth I Procter and Gamble Co., 758 F.2d 1545, 1547 (11th Cir.1985). Thus, as this Court has previously ruled in this case, the bottom line is that "[d]is

not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03638-03641 09/08/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pr

he admissible evidence; protected by privacy rights 02633-02646 05/01/2009 Paul Cassell Bradley Edwards Response to Motion to Consolidate + Cassell strategy Memo for Jay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admiss

Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Marys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evid

3-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 03550-03574 09/09/2009 Attorneys at RRA Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pr

he admissible evidence; protected by privacy rights 02633-02646 05/01/2009 Paul Cassell Bradley Edwards Response to Motion to Consolidate + Cassell strategy Memo for Jay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admiss

Fistos & Lehrman BATES DATE LQ FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Macys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evid