Giuffre_Maxwell_Batch1_p00477.png

Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 30 of 40 support his extreme assertion that Ms. Giuffre waived her privilege simply by allowing an affidavit to be filed in a court proceeding. Defendant also claims Cassell, at his deposition in the Dershowitz case, waived attorney- client privilege by discussing factual information related to his investigation of Ms. Giuffre’s allegations (for example, flight log information). Cassell’s deposition testimony did not constitute a waiver of Ms. Giuffre’s attorney-client privilege. Indeed, Ms. Giuffre’s own separate attorney (undersigned counsel, Ms. McCawley, from the law firm of Boies, Schiller & Flexner, LLP) raised a standing objection to Cassell answering any question that would require divulging any attorney/client communications. McCawley Decl., Ex. 14, deposition excerpt of Paul Cassell, Volume I, dated Oct. 16, 2015, at 39:24 — 40:2 (“Virginia Roberts does not waive her attorney/client privilege with her lawyers, and they are not entitled to testify as to information that she intended to be confidential that she communicated to her lawyers.”).'” Defendant also argues that because Cassell said at some (unspecified) point in his deposition that he “knew” some (unidentified) information about Ms. Giuffre, he must have been revealing attorney-client communications. Mot. to Compel at 17 (“Of course, the information [Cassell and Edwards] “knew” about [Ms. Giuffre was a direct result of her attorney-client communications with them... .”). But Cassell knew a vast amount of information about Ms. Giuffre from the factual record in the case, such as the flight logs demonstrating flights that she took with Epstein and Defendant on Epstein’s jet. Defendant’s logic is simply incorrect. E. Ms. Giuffre Will Not Seek to Use Confidential Attorney-Client Communications in her Action Here. For all the reasons just explained, Ms. Giuffre has not waived her attorney-client privilege through events that occurred in the Dershowitz case. But one additional point bears '° In her “excerpts” from Cassell’s deposition, Defendant has not included this portion. See Menninger Dec., Ex. L. 23