Epstein Secrets

gain prior to the - let me start again. EXHIBIT "A" 2 EFTA00606648 Prior to the filing of the lawsuit against Jane Doc 1 and Jane Doe 2 against the United States Government, did you learn from any source, maybe a document, maybe a telephone call or a conversation that you had with a third party separate from your clien

EFTA00606629 1.) For example, Edwards's attorney instructed him when Edwards was asked how one plaintiff, E.W., came to contact referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that

referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that to you." Id. 9. Edwards in one instance when asked what his client E.W. told him on the phone, himself claimed privilege. Id. a

ilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, or deemed to be a victim by the United States Attorney's Office? Transcript of Depositio

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

ilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, or deemed to be a victim by the United States Attorney's Office? Transcript of Depositio

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

d 20 Ms. 21 A. No. 22 Q. I think you told me at the time that the 23 complaint was filed or at the time that the Jane Doe 24 1 and 2 sued the United States Government which was 95 in early July, it was July 8th of '08, you don't PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA00599760 Page 100 recall

RA, if those cases had resolved 11 during that time period, RRA, you would have paid 12 RRA that portion to which you were been entitled and 13 Howell and a Cassell would have gotten their 14 percentage? 15 A. Correct. 16 Q. And with regard to, with the new firm, the 17 Farmer, Jaffe firm,

ose cases there was a, 13 there is also another lawyer that was involved -- 14 well, let me strike that. In one or more of those 15 cases is Mr. Howell involved, or was he at the time 16 you were a solo practitioner? 17 A. What do you mean by involved? 18 Q. Involved, was he a referring lawye