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ement. The documents contain only the text of communications by government attorneys, but they were not 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
Epstein and the U.S. Attorney's Office regarding plea negotiations; (2) internal communications between attorneys at the U.S. Attorney's Office and the Justice Department and among the prosecution team; and (3) internal communications among attorneys for Jeffrey Epstein and among the defense team. Internal communicati
orney's Office during pre-indictment presentations and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit
Epstein and the U.S. Attorney's Office regarding plea negotiations; (2) internal communications between attorneys at the U.S. Attorney's Office and the Justice Department and among the prosecution team; and (3) internal communications among attorneys for Jeffrey Epstein and among the defense team. Internal communicati
ement. The documents contain only the text of communications by government attorneys, but they were not 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
orney's Office during pre-indictment presentations and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit
ines, 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 adversaries." Id. at 1429. This holding makes sense, because it is ha
pre-indictment presentations and ongoing plea negotiations." Gov't Resp. at 8 (citing In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (1st Cir. 2003)). But the case the Government cites stands for no such broad proposition. Rather, that case involved a situati
Entities connected to both Department of Justice and XYZ Corp.

Jeffrey Epstein
PERSON
United States
LOCATION
Alexander Acosta
PERSONSouthern District
LOCATIONFBI
ORGANIZATIONLeon Black
PERSON
George W. Bush
PERSON
Virginia Giuffre
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Scarlett Johansson
PERSON
Michael Cohen
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSONMartin Weinberg
PERSON
A. Marie Villafana
PERSON