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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
ed communication directly into the litigation, as necessary to prove an element of a claim or defense." Id. See also, e.g., GAB Bus. Sews., Inc. v. Syndicate 627, 809 F.2d 755 (11th Cir. 1987) ("If 627 introduces evidence as to the strength of JDA Farms' case-as 627 must to prevail—it cannot hide behind the s
ile simultaneously brandishing it as a shield from disclosure of any Achilles heels." Stern v. O'Quinn, 253 F.R.D. 663, 677 (S.D. Ha. 2008). Or, as the Eleventh Circuit has articulated the principle, a litigant "can no more advance the work-product doctrine to sustain a unilateral testimonial use of work-product [pr
vilege. The Government does not dispute that the same implicit waiver can be made of the attorney client privilege. See GAB Business Servs., Inc. v. Syndicate 627, 809 F.2d 755, 762 (11th Cir.1987) (discussing the implied waiver concept in the context of the attorney-client privilege). Indeed, the Government
r protections. I. Work-Product Protection, as Well as Attorney-Client Privilege, Can Be Explicitly or Impliedly Waived. Case law from this Court, the Eleventh Circuit, and the Supreme Court all make clear that work product protection can be waived — indeed, such protection can be waived "impliedly." A very thorou
hen considering any assertion of attorney-client privilege, which can likewise be explicitly or implicitly waived. See GAB Business Servs., Inc. v. Syndicate 627, 809 F.2d 755, 762 (11th Cir.1987) (discussing the concept in the context of the attorney-client privilege); Baratta v. Homeland Housewares, LLC, 24
Entities connected to both the Eleventh Circuit and Syndicate 627

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATION
Bradley Edwards
PERSONLeon Black
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
S.J. Quinney College of Law
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION
the University of Utah
ORGANIZATION
Dexter Lee
PERSON
Eric Trump
PERSONJacqueline Perczek
PERSON
Stern
PERSONRoy Eric Black
PERSONBlack Srebnick Komspan & Stumpf
ORGANIZATIONVolpe
PERSONO'Quinn
PERSONS.D. Ha
ORGANIZATIONF.R.D. 444
ORGANIZATION