Epstein Secrets

CRITTON, et al. 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Jay Howell, Esq. Jay Howell & Assoc. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 EFTA00725382

Circuit has recently refused to extend the act of production doctrine to facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecutors sought information about possible crimes committed by a defense attorney in the course of representing a defendant in a

West Palm Beach FL 33401-5012 Co-Counsel Attorneys for Plaintiff Bradley JaMes Edwards ler Ft. Lauderdale, FL 33301 Lead Counsel Pro Hao Vice Jacksonville , FL 32211 14 Page 14 of 14 EFTA00201258

ries Inflicted by Epstein. In general, "The compensation and remedy due a civil plaintiff should not be delayed? Gordon v. FDIC, 427 F.2d 578, 560 (D.C. Cir. 1970). Epstein has not discussed Jane Doe's interest in prompt compensation — much less demonstrated that his alleged interests• in a stay somehow

ds, LEAD ATTORNEY, Farmer Jaffe Weissing Edwards Fistos & Lehrman PL, Fort Lauderdale, FL; Jay C. Howell, PRO HAC VICE, Jay Howell & Associates PA, Jacksonville, FL; Paul G. Cassell, PRO HAC VICE. For United States of America, Respondent: Ann Marie C. Villafana, LEAD ATTORNEY, United States Attorney's Offi

e level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401, 244 U.S. App. D.C. 11 (D.C. Cir. 1985) (exception to attorney- client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis