Epstein Secrets

er way, it does not apply where there is no common interest to be promoted by a joint consultation and the parties meet on a purely adversary basis. Volpe v. Conroy Simberg, 720 So. 2d 537 (Fla. 4th DCA 1998). A mere hope or expectation that the person 12 EFTA00805378 to whom privileged materials a

documents waived the privilege. § 90.507, Fla. Stat. (2006). Id. Notably, Edwards is already familiar with this basic principle. Specifically, in Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014), it was Edwards who argued that the United States failed to confer with his clients before en

plaintiff had the right to examine the investigation materials to determine if O'Quinn's reliance upon them was reasonable. Stern also relied upon Volpe v. U.S. Airways, Inc. 184 F.R.D. 672 (M.D. Fla. 1998), where the plaintiff sued defendant U.S. Airways for sexual harassment. U.S. Airways asserted

tered on FLSD Docket 08/25/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR FINDING OF WAIVER OF WO

plaintiff had the right to examine the investigation materials to determine if O'Quinn's reliance upon them was reasonable. Stern also relied upon Volpe v. U.S. Airways, Inc. 184 F.R.D. 672 (M.D. Fla. 1998), where the plaintiff sued defendant U.S. Airways for sexual harassment. U.S. Airways asserted

tered on FLSD Docket 08/25/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR FINDING OF WAIVER OF WO

.1996); Tribune Co. v. Purcigliotti, 1997 WL 10924, *6 (S.D.N.Y. Jan. 10, 1997)). As an illustration of how the doctrine operates, this Court cited Volpe v. U.S. Ainvays, Inc., 184 F.R.D. 672 (M.D.Fla.1998). As this Court explained, in Volpe, the plaintiff sued the defendant, alleging employment disc

Document 414 Entered on FLSD Docket 08/11/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S MOTION FOR FINDING OF WAIVER OF WORK PRODUCT AND SIMILAR