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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00384933: Darren Indyke, Privilege and Deposition (DS9)

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This document is email correspondence dated August 27, 2013, among attorneys including Darren Indyke, Lesley Groff, Jack Goldberger, Tonja Haddad, and Fred Haddad regarding litigation strategy. Topics include attorney-client privilege arguments, trial exhibits, witness lists, expert witnesses, and a motion to compel regarding deposition questions, with references to Edwards and Scherer.

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PersonKeyword
Excerpt 1
Attorney/client **privilege** argument 2. Trial Exhibit and Witness list from Edwards 3. Do we have an expert? Are we going to call Scherer? 4.
Excerpt 2
Motion to Compel re: **Deposition** Questions a. if we are moving to exclude certain things and/or prevent Edwards from using them I do not want to compel
Excerpt 3
From: Lesley Groff To: Jack Goldberger >, Tonja Haddad >, , Fred Haddad Cc: **Darren** **Indyke** Subject: 1:30 Conf. Call THurs.

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