Epstein Secrets

xhibit B, at 35-36. Edwards supported this last statement with the following authorities: See, e.g., Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414, 1429 (3d Cir. 1991) (Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived

eyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product protection was waived by [party] via production" of the documents in question); In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289, 302 (6th Cir. 2002) (attorney client/work product privilege was "never designed to protect conversation

g plea bargaining waives all work product protection. The Government acknowledges, for example, that Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure of work product materials to the

Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question); In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289, 302 (6th Cir. 2002) (attorney client/work product privilege was "never designed to protect conversation

sed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 450 F.3d 1179 (10'" Cir. 2006); Westinghouse Electric Corp. v Republic of Philippines, 951 F.2d 1414, 1428-31 (3d Cir. 1991); In re Subpoena Duces Tecum, 738 F.2d 1367, 1372 (D.C. Cir. 1984). Finally, the court rejects the intervenor

prosecutorial authorities investigating allegations against Epstein at that time, any work product protection was necessarily lost. See e.g. In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289 (6th Cir. 2002), cert. dismissed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 4

sed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 450 F.3d 1179 (10ih Cir. 2006); Westinghouse Electric Corp. v Republic of Philippines, 951 F.2d 1414, 1428-31 (3d Cir. 1991); In re Subpoena Duces Tecum, 738 F.2d 1367, 1372 (D.C. Cir. 1984). Finally, the court rejects the intervenor

prosecutorial authorities investigating allegations against Epstein at that time, any work product protection was necessarily lost. See e.g. In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289 (6ih Cir. 2002), cert. dismissed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 4