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eir work product waived any claim of privilege. Id. at 1008 (emphasis added). Indeed, Edwards' clients made this argument in their Answer Brief to the Eleventh Circuit! See Excerpt of Ans. Br. in Jane Doe I v. United States, Exhibit at pp. 35-36. Edwards' contrary legal argument now is nothing more than presently
Disclosure to Adversary Constitutes Waiver As a threshold basis for waiver, it is undisputed that the law firm of Conrad Scherer, through attorney William Scherer, represented investors in (e.g., victims of) Rothstein Rosenfeldt & Adler's Ponzi scheme, in the Razorback litigation. These investors were unquesti
dwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the Eleventh Circuit held that Epstein's former counsel had waived the work- product privilege with respect to documents sought by Edwards' clients, after having voluntar
osenfeldt Adler, P.A., United States Bankruptcy Court, Southern District of Florida, Case No. 09- 34791-BKC-RBR, The following are statements made by William Scherer, Razorback's counsel. • "[I]n November we filed a lawsuit in State Court and we alleged that as part of Mr. Rothstein and the firm, and the firm's
ssary . . . to prevent a client from committing a crime."). Following earlier precedent in Parrott v. Wilson, 707 F.2d 1262, 1271 (11th Cir. 1983), the Eleventh Circuit affirmed the part of the district court's order determining that the crime-fraud exception may be applied because an attorney's illegal or fraudulen
uments identified on his 159-page privilege log. In addition, Edwards' counsel suggested that Link & Rockenbach received the evidence from attorney William Scherer (Razorback's counsel). Although that is inaccurate, it demonstrates that any potential work-product protection has been waived by virtue of producti
Entities connected to both the Eleventh Circuit and William Scherer

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Paul Cassell
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
A. Marie Villafana
PERSONRoy Black
PERSONScott Rothstein
PERSON
Prince Andrew
PERSONRobert D. Critton
PERSONFISTOS & LEHRMAN
ORGANIZATION
Donald Trump
PERSON