Epstein Secrets

d privilege for "fact" work product - factual information concerning the client's case and prepared or gathered in connection with its preparation. Wal-Mart Stores, Inc. v. Weeks, 696 So. 2d 855, 856 (Fla. 2d DCA 1997) (trial judge did not depart from essential requirements of by not protecting materials from discov

you represented Jane Doe. .. whether she was considered a victim by the U.S. Attorney's Office?" and then re-phrased: ". . .[D]id you learn whether [Jane Doe 1] was listed as a, or deemed to be a victim by the U.S. Attorney's Office?" Id. at 100-104. Although contrary to law, Mr. Scarola's stated position

ROLA: I am going to object. That calls for attorney-client privilege. 100/9-14 Q. At the time do you know whether, at the time that you represented Jane Doe 1, do you know whether her name, whether she was considered a victim by the United States Attorney's Office? 100/15-23 A. SCAROLA: If that informati

preclusion of all documents and discussion of the Jane Doe 102 case, including the settlement of those claim

eeneees 22 Chnapkova v. Koh, 985 F.2d 79, 82 (2d Cir. 1993) oes cecccsscessecseeceseesseeseeeseceseesseesseeeseeeeeeseeeseeees 22 Daniels by Glass v. Wal-Mart Stores, Inc., 634 So.2d 88, 93 (Miss. 1993) .....cescesesseeseeeteeeseeeees 4 DeVaul v Carvige ing. 526 N.Y 8.20 483 (2d Dept 1988 cos savesowussnsseneesessens sm

ceceseccecusececusseccsssecesssseescsseeeceseesenssseeestsssessnsaseess 25 17. The Parties agree to preclusion of all documents and discussion of the Jane Doe 102 case, including the settlement of those claims (Motion in Limine 17) ................0005 26 18. The Cassell/Edwards v. Dershowitz litigation is

... eee 22 Chnapkova v. Koh, 985 F.2d 79, 82 (2d Cir. 1993) ....cccccccccccccccesecsessesseesscesseessecssesseesssesseeeaeenes 22 Daniels by Glass v. Wal-Mart Stores, Inc., 634 So.2d 88, 93 (Miss. 1993) ......cccccccecseteeteeteees 4 DeVaul v Carvigo Inc., 526 N.Y.S.2d 483 (2d Dept. 1988)... ccc cece cece cs eeteeeteeee