Epstein Secrets

ided this % day of January 2010 via U.S. Mail and email transmittal to all those on the attached service list. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 By: BRADLEY J. EDWARDS Florida Bar No.: 542075 EFTA00725381 SERVICE LIST Robert D. Critton, Jr. BURMAN, C

production of a personal calendar "would require mere surrender of the calendar, and not testimony" (internal quotation omitted)); United States v. Clark, 847 F.2d 1467, 1473 (10th Cir. 1988) (accounting records not subject to act of production protection; in producing records the defendant would not

9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 10 of 11 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954 524-2820• Fax: 954 524-2822 E-mail: Paul G. Cassell Pro Hac Vi

and Don Clark. One of O'Quinn's defenses to the defamation claim was that he reasonably relied upon the investigations conducted by Vicedomine and Clark. Id. at 677-78. Because of this reliance, the court found that an implied waiver of work product protection occurred as to the investigation materi

9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 10 of 11 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universi

and Don Clark. One of O'Quinn's defenses to the defamation claim was that he reasonably relied upon the investigations conducted by Vicedomine and Clark. Id. at 677-78. Because of this reliance, the court found that an implied waiver of work product protection occurred as to the investigation materi

ST ORSEOC 21 25 Wen Hagler Street SAC 800 22 Moe: 23 (Via one) 24 25 9 BRADLEY J. EDWARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS 10 FISTOS & LEHRMAN, P.L. 425 Rath Anikens Avenue 11 Stile 2 1 2 Fat 33301 Maw 13 On behalf ace a I Drench 8. 14 JESSICA ARDOUR. ESQUIRE MERMELS1131N k HOR

Was there a memorandum to the town 8 that was issued as a result of this incident? 9 A. I know that Captain Frick spoke with 10 Mr. Epstein at Clark and South Ocean, Clark Avenue and 11 South Ocean in the Town of Palm Beach. And I understand 12 that Captain Frick spoke with, I don't know her f