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erroneous. Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settl
, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E
erroneous. Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settl
, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E
erroneous. Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settl
, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E
Entities connected to both Evaluation Program Litig and Penman

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATION
Bradley Edwards
PERSONthe Southern District
LOCATIONLeon Black
PERSONRoy Black
PERSONPerlman
PERSONFederal Rule of Evidence 410
ORGANIZATIONJaffee
PERSON
George W. Bush
PERSONChrysler Motors Corp.
ORGANIZATION
Southern District of New York
ORGANIZATIONKrane
PERSON
Ghislaine Maxwell
PERSONDickson
PERSONLoan Corp.
ORGANIZATION
Carpenter
PERSON
Michael Cohen
PERSON
Julie K. Brown
PERSON