Epstein Secrets

o use their best judgment in prosecuting ... a lawsuit without fear of having to defend their actions in a subsequent civil action for misconduct." Echevarria, McCalla, Raymer, Barrett & &apple?. v. Cole, 950 So. 2d 380, 384 (Fla. 2007). It is also crucial that these e-mails be available to the jury as the

in reliance on Edwards' previous waiver and agreement to produce the same, these e-mails must be deemed not protected by Edwards' clear waiver. See Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014)(held that Epstein's former counsel had waived the work-product privilege with respect to docum

ss and malicious prosecution claims, and also finding that Levin, Middlebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994), Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), and Wolfe provided "binding precedent in this area of law." (R. 1203).2 Fi

ge female plaintiff. To augment his concocted story, Rothstein invited D3 to his office to view the thirteen banker's boxes of actual case files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real. In particular, Rothstein cla

ards filed a civil sot against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, LM. v. Epstein, (Exhibit “V”). 3 47. Jane Doe’s federal complaint indicated that she sought damages of more than $50,000,000. Listing the amount of damages sought in the complaint was in accord wit

nesses, and counsel as well. id. The litigation privilege applies in all causes of action, whether for common- law torts or statutory violations. See Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007). Defamatory statements made by lawyer while interviewing a witness in prepar