3
Shared Docs
3
Same-Page
4 / 3
Mentions
torney Sloman sent an e-mail to Jay Leflcowitz„ a copy of which is attached hereto as Exhibit _.Bpsteinls—eriminal—defense eeunselr explaining that the Justice Department's Child Exploitation Obscenity Seotion (CEOS) had-agreeil-te-review-Bpstein1/2 -ehjeetiens-te-the--prepese4-plea-agFeement-that-hed-heen-reaehed with
on with the defendant sex offender and. niter he raised objections. slopped making notilleatIons.* Epstein sought 'a higher level of review' within the Department of Justice the motion says. 'A reasonable inference Irons the evidence is that Epstein used his sirlicani pol.lical and social connections to kitty the Justic
ed, for example, the work product argument: Disclosure of work-product materials to an adversarywaives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the com
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
"Disclosure to an adversary waives the work product protection as to items actually disclosed, even where disclosure occurs in settlement." In re Chrysler Motors Corp. Overnight Evaluation Program Litigation, 860 F.2d 844, 846 (8th Cir. 1988). Thus, "[c]ourts will imply waiver when a party In Jane Doe v. Epstein,
ll Clinton pal who just left jail after completing a sentence for soliciting sex with a minor, may be headed back soon: The Daily Beast reports that the Justice Department is investigating him for child trafficking. Epstein, famous for being rich, being friends ‘v ith Bill Clinton having an egg-shaped penis. and being
e plea discussions are not confidential: Disclosure of work-product materials to an adversary• waives the work-product privilege. See. e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig.. 86012.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073. 1081-82 (4th Cir. 1981). Even if it shared the com
Entities connected to both Department of Justice and Chrysler Motors Corp.

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Alexander Acosta
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATIONFBI
ORGANIZATIONLeon Black
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
Michael Cohen
PERSON