Epstein Secrets

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

opposing party's case while 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 unilatera

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

pposing party's case while 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). CONCLUSION The Court should direct the Government to produce to the victims all documents that it previously withheld based on work-produc

009 WL 2567831, fn. I (E.D. Cal. Aug. 18, 2009). U.S.' Zane, 2009 WL 2567832, fn.l (E.D. Cal. Aug. 18 2009). As to the meaning of "actual damages," the Eleventh Circuit in McMillian i t F.D.I.C., 81 F.3d 1041, 1055 (I I th Cir.1996)3, succinctly explained: 3 In McMillian the I 1th Circuit was faced with the task of

pstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 31. Epstein 2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 41. Epstein, 2009 WL 383286 (S.D. Ha. Feb. 12, 2009); and Doe No. 5I. Epstein, 2009 WI, 383383 (S.D. Fla. Feb. 12, 2009); see also U.S. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.