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r should have known that Rothstein was scrupulously marketing alleged Epstein settlements based upon the lawsuits filed by three (3) Jane Does (Le., Jane Doe, LM and EW). Jane Doe is filed in the Southern District of Florida, and LM and EW are both filed in the Circuit Court in and for Palm Beach county,
ilege attached to the topics outlined in Mr. Fisten's Affidavit, same no longer exists as the affidavit is now being used for testimonial purposes. Kailas v. Carnival Corporation, 2008 WL 2222152 at *4-6 (S.D. Fla. 2008); Montana Land and Mineral Owners Assoc., Inc. v. Devon Energy Corporation, 2006 W
r should have known that Rothstein was scrupulously marketing alleged Epstein settlements based upon the lawsuits filed by three (3) Jane Does (Le., Jane Doe, LM and EW). Jane Doe is filed in the Southern District of Florida, and LM and EW are both filed in the Circuit Court in and for Palm Beach county,
ilege attached to the topics outlined in Mr. Fisten's Affidavit, same no longer exists as the affidavit is now being used for testimonial purposes. Kailas v. Carnival Corporation, 2008 WL 2222152 at *4-6 (S.D. Fla. 2008); Montana Land and Mineral Owners Assoc., Inc. v. Devon Energy Corporation, 2006 W
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
ile simultaneously brandishing it as a shield from disclosure of any Achilles heels." Stern v. O'Quinn, 253 F.R.D. 663, 677 (S.D. Fla. 2008) (citing Kailas v. Carnival Corp., 2008 WL 2222152, *5 n. 1 (S.D.Fla. May 27, 2008) (citing Pitney—Bowes, Inc. v. Mestre, 86 F.R.D. 444 (S.D.Fla.1980); Hollinger I
Entities connected to both Jane Doe and Kailas

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONLeon Black
PERSONScott Rothstein
PERSONJack Scarola
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Weissing
PERSONJaffe
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONLuttier & Coleman
ORGANIZATION
Eric Trump
PERSON
Michael Jackson
PERSON