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al decision, strategy or tactic regarding bail, release, plea, sentencing, or parole." Id. at 424(citation omitted). Similarly, in United States v. Thetford 935 F.Supp.2d 1289 (N.D.Ala. 2013), Jack and Shirley Winslett had their boat stolen by Michael Thetford. A third party subsequently purchased the W
289 (N.D.Ala. 2013), Jack and Shirley Winslett had their boat stolen by Michael Thetford. A third party subsequently purchased the Winslett's boat. Thetford was criminally charged and entered into a plea agreement with the Government. The Winsletts sought to reopen the plea under § 3771(d), complaining
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
al decision, strategy or tactic regarding bail, release, plea, sentencing, or parole." Id. at 424(citation omitted). Similarly, in United States v. Thetford 935 F.Supp.2d 1289 (N.D.Ala. 2013), Jack and Shirley Winslett had their boat stolen by Michael Thetford. A third party subsequently purchased the W
289 (N.D.Ala. 2013), Jack and Shirley Winslett had their boat stolen by Michael Thetford. A third party subsequently purchased the Winslett's boat. Thetford was criminally charged and entered into a plea agreement with the Government. The Winsletts sought to reopen the plea under § 3771(d), complaining
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
ution. The provision confirms that crime victims do not have "the right to dictate government strategy or demand who to prosecute." United States v. Thetford, 935 F.Supp.2d 1289 (N.D. Ala. 2013) (citing In re W.R. Huff Asset Mgt. Co., 409 F.3d 555, 564 (2d Cir. 2005)). But as the Court knows, from the ve
ictims 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 protection re
Entities connected to both Thetford and O'Quinn

Jeffrey Epstein
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Bradley Edwards
PERSONLeon Black
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United States
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Paul Cassell
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Dexter Lee
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Kenneth Marra
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ORGANIZATIONthe Eleventh Circuit
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S.J. Quinney College of Law
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A. Marie Villafana
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ORGANIZATIONBENJAMIN G. GREENBERG
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Eric Trump
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