for you involving two Ivy League Directors of Cardiology, one of whom is Manhattan based, their Cayman Islands hedge fund whose largest investor is Abbott Labs (who happens to own Heartmate) and $150M in cash from Colombia paid for seed research clinical trials (with focus in cardiology) completed in 2015,

for you involving two Ivy League Directors of Cardiology, one of whom is Manhattan based, their Cayman Islands hedge fund whose largest investor is Abbott Labs (who happens to own Heartmate) and $150M in cash from Colombia paid for seed research clinical trials (with focus in cardiology) completed in 2015,

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00076105 Case 9:08-c 3fi-19464-0CtailltdReta 2ffeeurEenteea o if iractsarmatket GRAB/80131.5Page 8

for you involving two Ivy League Directors of Cardiology, one of whom is Manhattan based, their Cayman Islands hedge fund whose largest investor is Abbott Labs (who happens to own Heartmate) and $150M in cash from Colombia paid for seed research clinical trials (with focus in cardiology) completed in 2015,

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00095908 Case 9:08-c 3fi-19464-0CtailltdReta 2ffeeurEenteea o if iractsarmatket GRAB/80131.5Page 8

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00100343 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 8 of 20 see

for you involving two Ivy League Directors of Cardiology, one of whom is Manhattan based, their Cayman Islands hedge fund whose largest investor is Abbott Labs (who happens to own Heartmate) and $150M in cash from Colombia paid for seed research clinical trials (with focus in cardiology) completed in 2015,

e issues for judicial decision, and (2) the hardship to the panics of withholding court consideration.- ' (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136. 149 (1967))); 6 EFTA00205159 see also, e.g., Association For Children for Enforcement of Support, Inc. v. Conger. 899

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00208800 see also, e.g., Association For Children for Enforcement of Support, Inc. v. Conger, 899

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs... Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00209774 see also, e.g., Association For Children for Enforcement of Support, Inc.t Conger, 899 F.2

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00795156 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 8 of 20 see

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00799480 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 8 of 20 see

ls, do not permit Epstein or the Court to begin to evaluate the applicability of the privileges claimed by Epstein. TIG, 799 So. 2d at 341 (quoting Abbott Labs, 2000 U.S. Dist. LEXIS 20834, at *13)("[D]escriptions such as 'letter re claim', 'analysis of claim' or 'report in anticipation of litigation'. . .

ee also Glen- mede Trust Co.!. Thompson, 56 F.3d 476, 486 (3d Cir.19 5) (finding broad waiver i where advice of counse defense had been asserted); Abbott Labs. . Baxter Travenol Labs., Inc., 676 F. upp. 831, 832 (N.D.I11.1987) (same). Enforcing a prospective waiver in such a case makes sense: once

14 Ameriprise Financial, Professional Course Training, Minneapolis, MN, April 23-24, 2014 EFTA00073038 Park Dietz, M.D., M.P.H., Ph.D. Page 93 Abbott Labs, Webinar: Assessing and Managing Threats, July 17, 2014 Abbott Labs, Webinar: Intimate Partner Violence, August 5, 2014 American Express, Webinar