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eyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product protection was waived by [party] via production" of the documents in question); In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289, 302 (6th Cir. 2002) (attorney client/work product privilege was "never designed to protect conversation
ary. The United States Attorneys' office, at that juncture, was reviewing evidence relating to Epstein's sexual crimes against minor females within the Southern District of Florida and deliberating the filing of relevant federal charges; while Epstein's counsel clearly hoped to avoid any actual litigation between th
prosecutorial authorities investigating allegations against Epstein at that time, any work product protection was necessarily lost. See e.g. In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289 (6th Cir. 2002), cert. dismissed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 4
rsary. The United States Attorneys' office, at that juncture, was reviewing evidence relating to Epstein' sexual crimes against minor females within the Southern District of Florida and 6 EFTA00600059 Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 7 of 11 deliberating the filing of rele
prosecutorial authorities investigating allegations against Epstein at that time, any work product protection was necessarily lost. See e.g. In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289 (6ih Cir. 2002), cert. dismissed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 4
rsary. The United States Attorneys' office, at that juncture, was reviewing evidence relating to Epstein' sexual crimes against minor females within the Southern District of Florida and 6 EFTA00602812 Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 7 of 11 deliberating the filing of rele
Entities connected to both Columbia/HCA Healthcare Corp. and the Southern District

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONLeon Black
PERSONJack Goldberger
PERSON
Southern District of New York
ORGANIZATION
Scarlett Johansson
PERSON
Paul Cassell
PERSON
Donald Trump
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSONMartin Weinberg
PERSONScott Rothstein
PERSON
Salt Lake City
LOCATIONWeiss
PERSONJack Scarola
PERSONthe Eleventh Circuit
ORGANIZATION