Epstein Secrets

rosecutorial discretion." 818 F.3d at 742. The 2 Presumably, U.S. Airways was relying upon the affirmative defense identified in Faragher v. City of Boca Raton 524 U.S. 775 (1998), where an employer avoids liability under Title VII if: (I) it exercised reasonable care to prevent and correct promptly any se

rning its internal deliberations while making representations regarding those deliberations to obtain summary judgment." D.E. 414 at 1. In Stern v. O'Quinn 253 F.R.D. 663 (S.D.Fla. 2008), the district court identified two ways in which the attorney work-product doctrine could be waived. An "implied wai

rosecutorial discretion." 818 F.3d at 742. The 2 Presumably, U.S. Airways was relying upon the affirmative defense identified in Faragher v. City of Boca Raton 524 U.S. 775 (1998), where an employer avoids liability under Title VII if: (I) it exercised reasonable care to prevent and correct promptly any se

rning its internal deliberations while making representations regarding those deliberations to obtain summary judgment." D.E. 414 at 1. In Stern v. O'Quinn 253 F.R.D. 663 (S.D.Fla. 2008), the district court identified two ways in which the attorney work-product doctrine could be waived. An "implied wai

R.cf;;?N(F I DENTIAL DB-SONY-0022376 EFTA_00170102 EFTA01296770 Page 46 No. Full Name Address/Phone (212) 570-6082 6845 WILLOW WOOD DR APT BOCA RATON. FL 33434-3528 3.E. 4. EPSTEIN. LESLIE A 780 GREENWICH ST APT 6F NEW YORK, NY 10014-5930 • AKA ESPTEIN. LESLIE DOB:2/1966 (Age: 51) 455 SCHU

(See DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O'Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within pleading to decide application of work product privilege)