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Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 35 of 40 voluntary disclosure of confidential information effectively waives the privilege as to all conversations, or the whole breadth of discussion which may have taken place.” Procacci v. Seitlin, 497 So. 2d 969, 969-70 (Fla. Dist. Ct. App. 1986) (citing Goldman, Sachs & Co. v. Blondis, 412 F.Supp. 286, 288 (N.D.IL1.1976)). Instead, waiver by disclosure is confined to “that specific subject during that particular conversation.” Procacci, 497 So. 2d at 970 (quoting Perrignon v. Bergen Brunswig Corp., 77 F.R.D. 455, 461 (N.D. Cal.1978)).” As with her attorney-client privilege argument, Defendant has not even cited Florida law on waiver of work-product protection, much less explained how she meets its demanding requirements. Moreover, the illustrations she provides do not prove any general waiver of work- product protection. For example, Defendant relies on the claim that Cassell and Edwards have waived work-product protection by disclosing a transcript of a portion of a 2011 telephone interview with Ms. Giuffre by attorneys Jack Scarola and Brad Edwards. But that recorded interview was never a confidential communication between Mr. Giuffre and the lawyers, but rather (as the transcript of the call itself makes clear) a communication that could be presented “to any jury that might ultimately have to hear these facts.”. McCawley Decl., Ex. 15 at 1, transcript of Scarola/Edwards interview on April 7, 2011 (emphasis added). In other words, the recorded call was simply the functional equivalent of an affidavit — and affidavits are routinely disclosed with waiving work product protections, under the law of Florida and elsewhere. Defendant also argues that Cassell and Edwards waived work-product protection by filing a summary judgment motion in the Dershowitz case which contained supporting exhibits (e.g., flight logs, sworn testimony by third-party witnesses, and other evidence). Mot. to Compel 22 New York state law is to the same effect. See Charter One Bank, F.S.B. v. Midtown Rochester, L.L.C., 191 Misc. 2d 154, 159, 738 N.Y.S.2d 179, 186 (Sup. Ct. 2002) (“ The disclosure of a document protected by the work-product tule does not result in a waiver of the privilege as to other documents.”). 28