Epstein Secrets

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

examination of communications otherwise protected by the attorney-client privilege loses that privilege." DE 421 at 7 (citing Cox v. Administrator, U.S. Steel & Carnegie, 17 F.3d 1386, 1422 (11th Cir. 1994)). The Government has clearly injected its deliberations into the case, and fairness requires that the Court fi

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

airness requires an examination of communications otherwise protected by the attorney-client privilege loses that privilege." Cox v. Administrator. U.S. Steel & Carnegie 17 F.3d 1386, 1422 (11th Cir. 1994. The subject matter waiver doctrine does not apply since the government's assertion that the decision not to tel

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

airness requires an examination of communications otherwise protected by the attorney-client privilege loses that privilege." Cox v. Administrator. U.S. Steel & Carnegie 17 F.3d 1386, 1422 (11th Cir. 1994. The subject matter waiver doctrine does not apply since the government's assertion that the decision not to tel