Epstein Secrets

.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

ng it relevant to the case; and (3) application of the protection would deny the opposing party access to information vital to its defense. Stern v. O'Quinn, 253 F.R.D. 663, 676 (S.D. Fla. 2008) (citing Granite Partners, L.P. v. Bear, Stearns & Co., Inc., 184 F.R.D. 49, 55 (S.D.N.Y.1999) (citing Heani v

d — indeed, such protection can be waived "impliedly." A very thorough review of the relevant caselaw is found in this Court's decision in Stern v. O'Quinn, 253 F.R.D. 663, 676-77 (S.D. Fla. 2008). As this Court explained, under the doctrine of implied waiver of work product protection, "a party waives

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

rning its internal deliberations while making representations regarding those deliberations to obtain summary judgment." D.E. 414 at 1. In Stern v. O'Quinn 253 F.R.D. 663 (S.D.Fla. 2008), the district court identified two ways in which the attorney work-product doctrine could be waived. An "implied wai

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

rning its internal deliberations while making representations regarding those deliberations to obtain summary judgment." D.E. 414 at 1. In Stern v. O'Quinn 253 F.R.D. 663 (S.D.Fla. 2008), the district court identified two ways in which the attorney work-product doctrine could be waived. An "implied wai