Epstein Secrets

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

Court is governed by the basic mantra that the work-product doctrine is not absolute. Even the seminal case establishing the work-product doctrine, Hickman v. Taylor, recognized the doctrine's limits: We do not mean to say that all written materials obtained or prepared by an adversary's counsel with an eye tow

d by the government are subject to a protective order prohibiting their disclosure. In the related case 9:08-CV-80893 (the case where Jane Doe 1 and Jane Doe 2 sued Mr. Epstein for money), the Magistrate Judge prohibited Jane Doe I and Jane Doe 2 EFTA00205542 Case 9:08-cv-80736-KAM Document 160 Entered on

litigation.' United States v. Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman v. Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawyer is bou

ver his strenuous objection, to produce documents given to him by the government during the course of his settlement/plea negotiations with it. See Jane Doe #2 v. Epstein, No. 08-80119-MARRA, Doc. 462. In response to that order, settlement negotiation correspondence authored by government prosecutors (

rials prepared by an attorney `acting for his client in anticipation of litigation,"' United States v. Nobles, 422 U.S. 225, 237-38 (1975), quoting Hickman v. Taylor, 329 U.S. 495, 508 (1947), which applies in both civil and criminal litigation: Although the work-product doctrine most frequently is asserted as a

ury and justice shall be administered without sale, denial or delay. Art. I, §21, Fla. Const.; 10A Fla. Jur. 2d, Constitutional Law, §360. 15. If Jane Doe's name is not disclosed and identified, Mr. Epstein will not be afforded his fundamental right to fairly litigate this dispute and prepare for trial.

So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing, Hickman v. Taylor, 329 U.S. 495, 501, 507 (1947). 14. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes, Inc. v. Brandsmart U.S

00059568 CONFIDENTIAL - PURSUANT TO FED. R.WANI(E IDENTIAL DB-SDNY-0022392 EFTA_00I7Ol 18 EFTA01296786 Page 62 2015 U.S. Dist. LEXIS 87203, * JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. CASE NO.:08-CV-80736-KAM UNITED STATES DISTRICT COURT FOR THE SOUTHERN DIS

"it is essential that a lawyer work with a certain r 161 degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510, 67 S. Ct. 385, 91 L. Ed. 451 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a part

AM Document 330 Entered on FLSD Docket 07/06/2015 Page 1 of 51 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-KAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. I OPINION AND ORDER This cause is before the Court on various discove

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

M Document 330 Entered on FLSD Docket 07/06/2015 Page 1 of 51 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. OPINION AND ORDER This cause is before the Court on various discovery re

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an