Epstein Secrets

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

ed communication directly into the litigation, as necessary to prove an element of a claim or defense." Id. See also, e.g., GAB Bus. Sews., Inc. v. Syndicate 627, 809 F.2d 755 (11th Cir. 1987) ("If 627 introduces evidence as to the strength of JDA Farms' case-as 627 must to prevail—it cannot hide behind the s

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

vilege. The Government does not dispute that the same implicit waiver can be made of the attorney client privilege. See GAB Business Servs., Inc. v. Syndicate 627, 809 F.2d 755, 762 (11th Cir.1987) (discussing the implied waiver concept in the context of the attorney-client privilege). Indeed, the Government

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

hen considering any assertion of attorney-client privilege, which can likewise be explicitly or implicitly waived. See GAB Business Servs., Inc. v. Syndicate 627, 809 F.2d 755, 762 (11th Cir.1987) (discussing the concept in the context of the attorney-client privilege); Baratta v. Homeland Housewares, LLC, 24