Epstein Secrets

/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake Cit UT 84112-0730 Limited Intervenor Co-Counsel for M , E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for n, E.W. and Jane Doe 14

to even assertedly privileged documents in any context other than at trial is completely nonsensical. Even a privilege log required under Florida's Rules of Civil Procedure as a condition to withhold documents on the basis of privilege must sufficiently identify the specific documents withheld with enough detail to fac

ff/Comter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 Limited Intervenor Co-Counsel for M, E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for M, E.W. and Jane Doe 14

to even assertedly privileged documents in any context other than at trial is completely nonsensical. Even a privilege log required under Florida's Rules of Civil Procedure as a condition to withhold documents on the basis of privilege must sufficiently identify the specific documents withheld with enough detail to fac

in reliance on Edwards' previous waiver and agreement to produce the same, these e-mails must be deemed not protected by Edwards' clear waiver. See Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014)(held that Epstein's former counsel had waived the work-product privilege with respect to docum

dwards' failure to comply with the Court's Order. Because Edwards blatantly disregarded the Court's Order, as well as the requirements of Florida's Rules of Civil Procedure and the TIG case, the February 23, 2011 privilege log remains for any number of wholly deficient and worse - misleading. The privilege log misstate