23 b. Work Product Privilege has been Waived In 2011, Scarola acted as Edward’s attorney in a case captioned Epstein v. Edwards, Case No. 502009CA040800XXXMB, in the Circuit Court for the Fifteenth Judicial

20 05 CIV. 8360(NRB), 2008 WL 2073934, at *6 (S.D.N.Y. May 8, 2008) (in suit for damages against tax advisor for negligence in providing tax advice, reliance and causation could only be assessed through

17 In addition to the Motion for Summary Judgment, Mr. Cassell in his deposition spent more than 50 pages detailing the investigations and assessment of all of the evidence used as a factual basis for

13 Menninger Decl., Ex. H at 205:15-206:10. This testimony directly placed Plaintiff’s attorney-client communications and work product at issue in the Dershowitz Case. Edwards and Cassell took the affirmative

9 After a party voluntarily discloses attorney-client communications or work-product information “to an adversary in one proceeding, it cannot withhold the same documents on the basis of privilege in a

5 Following the Joinder Motion, Dershowitz made numerous public appearances in which he vigorously denied the allegations, stated that Edwards and Cassell “are lying deliberately,” and that if Cassell

1 Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Motion to Compel All Attorney-Client Communications and Attorney Work Product Placed At Issue By Plaintiff and Her Attorneys (“Motion”), and as

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. 15-cv-07433-RWS

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. 15-cv-07433-RWS

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