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Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 23 of 40 Ex. 6 at 3. As the briefing on the issue continued, in an October 26, 2015 response filing, Dershowitz argued that Ms. Giuffre’s public statements waived the privilege,’ along with actions by her attorneys Cassell and Edwards. Ex. 8 at 5-8.’ After all these arguments were fully briefed, the Florida court (Lynch, J.) rejected Dershowitz’s arguments that any waiver of the attorney-client privilege had taken place. McCawley Decl., Ex. 10 at 1 (“Defendant/Counterclaim Plaintiff's Motion to Compel Production of documents and complete responses to interrogatories is hereby denied.”). Ina December 8, 2015, order, Judge Lynch provided a short explanation of his reasoning and entered an order denying Dershowitz’s waiver motion. Jd. In her pending motion to compel, Defendant recycles the same arguments that Dershowitz made, such as the claim that Cassell and Edwards waived privilege by filing suit (Mot. Compel at 10), that her March 2011 interview with Scarola and Edwards was a waiver (id. at 10), and other similar claims (id. at 11-13). But Dershowitz already litigated these issues a few months ago in the Dershowitz case — and his claims were rejected by the Florida court. Defendant is now collaterally estopped from relitigating these identical issues here, because Dershowitz had a full and fair opportunity to litigate those issues and Defendant was in a “common interest” agreement with Dershowitz at the time. The doctrine of collateral estoppel protects litigants — and the courts — from relitigating identical issues and promotes efficiency by barring unnecessary litigation. See Parklane Hosiery Co., Inc. v. Shore, 439 U.S. 322, 326 (1979). As this Court has explained, for collateral estoppel to apply, there must have been a full " Dershowitz specifically listed the following public statements by Ms. Giuffre as illustrations of how she had waived her privilege: (1) Ms. Giuffre’s March 5, 2011, interview with the Daily Mail; (2) Ms. Giuffre’s April 7, 2011, recorded telephone interview with attorneys Jack Scarola and Brad Edwards; (3) the January 2015 release of Ms. Giuffre’s diary by Radar Online; (4) Ms. Giuffre’s statements to “numerous other third parties,” including former boyfriends and the FBI; and (5) Ms. Giuffre’s filing of this suit against Defendant. Ex. 6 at 6-8. "° Dershowitz specifically argued that (among other illustrations) Cassell’s answers to interrogatories and testimony at his deposition in the case had waived privilege. Ex. 6 at 11-12. 16