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Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 13 of 40 by bringing this defamation action placing at issue the truthfulness of Jane Doe No. 3’s allegations against Dershowitz... .” Jd. at 3-5. In his motion and reply pleading (McCawley Decl., Exhibit 8, Reply in Support of Motion to Compel), Dershowitz argued that Cassell and Edwards’ actions throughout the case constituted a waiver of attorney-client privilege. Cassell and Edwards responded, arguing that Ms. Giuffre was not a party of the defamation action and that she was the only person who could waive her privilege. McCawley Decl., Exhibit 7 at 4-6, Response in Opposition to Motion to Compel. Cassell and Edwards also argued that there had been no waiver because confidential attorney-client communications with Ms. Giuffre were not “at issue” in the defamation case. Jd. at 6-9. Cassell and Edwards also later filed a sur-reply, further elaborating on the argument that Ms. Giuffre had not waived any attorney-client privilege by publicly discussing her sexual abuse by Epstein and his associates. McCawley Decl., Exhibit 9, Sur-Reply in Support Opposition to Motion to Compel. Cassell and Edwards also explained that communications with Ms. Giuffre were protected not only beginning in March 2014, but even earlier than that date when Ms. Giuffre understood that she was obtaining legal services from Cassell and Edwards. Jd. at 1. Following this extensive briefing on waiver issues,° on December 8, 2015, the Florida Court (Lynch, J.) ruled, denying Dershowitz’s argument that attorney-client privilege had been waived. McCawley Decl., Exhibit 10, Order Denying Motion to Compel. Specifically, the Court denied the motion to compel, explaining “Pre March 2014 communications are protected by the work product privilege and the witness has not waived the communications that were protected by the attorney-client privilege. Also, there was no waiver by the [Cassell and Edwards] by filing suit.” Id. at 1. ° And following the filing of Cassell and Edwards’ summary judgment motion, filed on November 26, 2015. 6