Epstein Secrets

tatement with the following authorities: See, e.g., Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414, 1429 (3d Cir. 1991) (Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adv

With Regard to Sealed Documents, Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), respectfully submits the attached Opinion in the case of Jane Doe No. 1 v. United States, 749 F.3d 999 (11th Cir. 2014), attached to this Notice as Exhibit A, and Edwards' clients' Appellee Brief filed in that cas

Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe 6 EFTA00806658

6, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to the Securities and Exchange Commission and the Justice Department during their investigations of Westingh

obtained from the U.S. Attorney's Office or the U.S. Department of Justice. Rather, they were obtained from counsel for Jeffrey Epstein pursuant to Jane Doe # 1 's civil suit against Mr. Epstein, to which the United States was not a party. Thus, the United States has never had the opportunity to litigat

etely, thereby exposing the documents to civil discovery in litigation between the discloser and a third party." Id. at 1417. There, the defendant, Westinghouse, disclosed documents generated during an internal investigation to the SEC and DOJ to cooperate with those agencies' respective investigations. The

documents waived the privilege. § 90.507, Fla. Stat. (2006). Id. Notably, Edwards is already familiar with this basic principle. Specifically, in Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014), it was Edwards who argued that the United States failed to confer with his clients before en

6, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to the Securities and Exchange Commission and the Justice Department during their investigations of Westingh

obtained from the U.S. Attorney's Office or the U.S. Department of Justice. Rather, they were obtained from counsel for Jeffrey Epstein pursuant to Jane Doe # 1 's civil suit against Mr. Epstein, to which the United States was not a party. Thus, the United States has never had the opportunity to litigat

Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adv

pstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane Doe #1 and Jane Doe #2's Response to Motion to Intervene (DE 78) at 4-6. Perhaps recognizing the strength of the victims' response, the defense attorne