Epstein Secrets

2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah6 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile:

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

required to make the same initial disclosures that are part and parcel of civil suits. He would also presumably be subject to deposition. See Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1305 (11th Cir. 2008) (affirming denial of motion to intervene because of delay that would be involved in deposing the intervenors)

, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. 1 Telepho Facsimil Florida Bar No.: 542075 E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah° 332 S. 1400 E. Salt Lake • Telephone Facsimile: E-Mai Attorneys for Jane

l Florida Bar No.: 542075 E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

required to make the same initial disclosures that are part and parcel of civil suits. He would also presumably be subject to deposition. See Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1305 (11th Cir. 2008) (affirming denial of motion to intervene because of delay that would be involved in deposing the intervenors)

stify the privilege claim. A similar undated letter was invented for Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman (FJW), P.L, and co-counsel, Paul G. Cassell, Esq. Menninger Decl., Ex. L. It states: Again, while the letter is conveniently and purposefully undated, it and therefore must have been created

Communications and Attorney Work Product (Doc. # 164), Plaintiff waived her attorney-client and work product privileges with attorneys Edwards and Cassell. She cannot, therefore, revive those privileges by over-laying some novel "common interest" agreement with her own attorneys. Furthermore, Jack Sca

ions of the agreement were prepared in anticipation of litigation and therefore fall within the definition of attorney work product."); Oklahoma v. Tyson Foods, Inc., No. 05-CV-329, 2007 WL 3128422, at • (N.D. Okla. Oct. 24, 2007). 10 EFTA00618143 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 13 of 1