Epstein Secrets

han happy 13 to do it, because it sounds like you all know more 14 about it than I -- but I'm happy to get affidavits 15 from Mr. Pincus, Judge Stern, everybody else about 16 what happened with this hearing today, because 17 know very little about it. But my representations 18 are what they a

ith a vibrator, or digitally penetrating the girl's vagina. 14. Consistent will the foregoing plan, scheme, and/or enterprise, Ms. Robson recruited Jane Doc to give Epstein a massage for monetary compensation. Ms. Robson brought Jane Doe to Epstein's mansion in Palm Beach. Jane was introduced to Sarah Ke

15151 Date 5129/200812.09:; A IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA JANE DOE, by and through JANE DOE'S MOTHER as parent and natural guardian, • Plaintiffs, V . JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants, 962118 a 0 065 9 6,0000

essage and told her to sit on top of him. Out of fear and trepidation she complied As Jane rubbed Epstein's chest Epstein began to use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane Doe's vagina. Ai tits same time, with his other hand, Epstein

as impliedly waived it through his own affirmative conduct. Pitney-Bowes, Inc. v. Mestre, 86 F.R.D. 444 (S.D. Fla. 1980) (emphasis added); see also Stern v. 0 'Quinn, 253 F.R.D. 663 (S.D. Fla. 2008). "Implied waiver of the attorney-client privilege can occur where a party voluntarily injects either a

documents waived the privilege. § 90.507, Fla. Stat. (2006). Id. Notably, Edwards is already familiar with this basic principle. Specifically, in Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014), it was Edwards who argued that the United States failed to confer with his clients before en

oth the victims and the Government agree that the relevant legal standard governing the question of waiver of work-production protections comes from Stern v. O'Quinn, 253 F.R.D. 663, 676-77 (S.D. Fla. 2008), which held that "a party waives work-product privilege protection when (1) assertion of the pr

Document 422 Entered on FLSD Docket 09/01/2017 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S REPLY IN SUPPORT OF MOTION FOR FINDING OF WAIVER OF WORK

take positions during the investigation and negotiation of this matter that has led to unprecedented federal overreaching. In fact. Judge I lerben Stern's states " . . Alta federal authorities inappropriately involved themselves in the investigation by the state authorities and employed highly irregu

partner in the former firm of Herman, Mermelstein, filed five lawsuits, each asking for S50 million, against Mr. Epstein. Each lawsuit is entitled "Jane Doc # vs. Jeffrey Epstein," despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Feder

trine in this case does not "deny the opposing party access to information vital to its defense." Stern, 253 F.R.D. at 676. In that case, plaintiff Stern was suing defendant O'Quinn, and O'Quinn's law firm, for defamation. O'Quinn had instituted an investigation of plaintiff Stern, which was conducted

tered on FLSD Docket 08/25/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR FINDING OF WAIVER OF WO

trine in this case does not "deny the opposing party access to information vital to its defense." Stern, 253 F.R.D. at 676. In that case, plaintiff Stern was suing defendant O'Quinn, and O'Quinn's law firm, for defamation. O'Quinn had instituted an investigation of plaintiff Stern, which was conducted

tered on FLSD Docket 08/25/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR FINDING OF WAIVER OF WO

n be waived — indeed, such protection can be waived "impliedly." A very thorough review of the relevant caselaw is found in this Court's decision in Stern v. O'Quinn, 253 F.R.D. 663, 676-77 (S.D. Fla. 2008). As this Court explained, under the doctrine of implied waiver of work product protection, "a p

Document 414 Entered on FLSD Docket 08/11/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S MOTION FOR FINDING OF WAIVER OF WORK PRODUCT AND SIMILAR

e proposed amendment itself, in which all four victims simply allege the same general facts.”)). As the Does argue at length in their Rule 15 Motion, Jane Doe 1’s original petition “specifically allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims.

ying amendment where “addition of more plaintiffs .. . would not have affected the issues underlying the grant of summary judgment.”’); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under Rule 15, “courts have held that leave to amend to assert a claim already at issue in [another lawsuit

g the grant of summary judgment.”); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under R

to trial. She was just 15 years old when she was drawn into Epstein’s exploitative world in 1998. In her civil writ against him, under the pseudonym Jane Doe 102’ she alleged that her duties included being ‘sexually exploited by Epstein’s adult male peers including royalty’. Now, horrified by the evidence