Epstein Secrets

he 47 exhibits are protected by any privilege. The 3The Court incorrectly referenced 45 exhibits. Edwards claimed it is 49 exhibits, but two of the Bates numbers he referenced were pages contained within another exhibit, making the total 47 exhibits which are in dispute. 3 EFTA00808674 Court expre

valuation of and challenges to the privileges asserted therein. TIG Ins. Cap. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001); Abbott Laboratories v. Alpha Therapeutic Corp., No. 97-C-1292, 2000 WL 1863543 (N.D. III. Dec. 14, 2000). Moreover, none of the general references for which Edwards would have Epstein sanctioned

biting any reference to or use of the exhibits at the trial. (3/18/18 Aft. Tr. 75:24-76:6.) This, 3Edwards claimed it is 49 exhibits, but two of the Bates numbers he referenced were pages contained within another exhibit, making the total 47 exhibits which are in dispute. 3 EFTA00808660 of course,

valuation of and challenges to the privileges asserted therein. TIG Ins. Cap. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001); Abbott Laboratories v. Alpha Therapeutic Corp., No. 97-C-1292, 2000 WL 1863543 (N.D. III. Dec. 14, 2000). Had the Court issued the expansive prohibition sought by Edwards, it would have effectiv

fficult since the items do not appear to be in date order or bates number order. 2. Each page of the Log contains six columns which consist of the Bates number, the date of the item, the sender, the recipient, the so-called "description" of the item, and the nature of the objection. The Log does not

h as 'letter re claim,' analysis of claim,' or report in anticipation of litigation' . . . will be insufficient." Id. (citing Abbott Laboratories v. Alpha Therapeutic Corp., 2000 U.S. Dist. LEXIS 20834, 2000 WL 1863543 fl III. Dec. 14, 2000). 4. In this Log, there is no identification whatsoever of the type of docume