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uring those negotiations against either party. BACKGROUND The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental
of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Ja
gotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Inte
by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by
6, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to the Securities and Exchange Commission and the Justice Department during their investigations of Westingh
/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF SUPPLEMENTAL AUTHORITY IN SUPPORT OF HIS SUPPLEMENT TO MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS, ETC
and/or Waiver of Attorney-Client Privilege and Attorney Work Product With Regard to Sealed Documents, Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), respectfully submits the attached Opinion in the case of Jane Doe No. 1 v. United States, 749 F.3d 999 (11th Cir. 2014), attached to this Notice
OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT
eving that Bill Clinton was on the airplane with Mr. Epstein and these young woman ..." (18:24- 19:7.) • "I
tatement with the following authorities: See, e.g., Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414, 1429 (3d Cir. 1991) (Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adv
uring those negotiations against either party. BACKGROUND The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental
of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Ja
gotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Inte
by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by
6, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to the Securities and Exchange Commission and the Justice Department during their investigations of Westingh
HE NEWS Federal Prosecutors Release Details Of Ghislaine Maxwell's Arrest. ABC World News TonightVi (7/13, story 4, 1:30, Muir, 7.15M) reported "on Jeffrey Epstein's alleged co-conspirator, Ghislaine Maxwell. Authorities now revealing details over her arrest in New Hampshire. The FBI breaking through the door, a
and it was not clear if they are living in the US." Fox News (7/13, Casiano, 27.59M) reports, "Maxwell, 58, faces six charges for conspiring with Epstein in a multi-state sex trafficking ring involving three unnamed minors between 1991 and 1997. A hearing is scheduled Tuesday where a judge will decide
i (7/13, story 4, 1:30, Muir, 7.15M) reported "on Jeffrey Epstein's alleged co-conspirator, Ghislaine Maxw
$9 billion nuclear fraud" case. In his position with SCANA, Byrne "has admitted to knowingly engaging with others in fraud during construction of 2 Westinghouse AP100 reactors" as part of the VC Summer nuclear project. Federal officials "are believed to have offered him a deal to testify against fellow execu
ice arranging a highly unusual and secretive non-prosecution agreement. The victims have already explained at length why the correspondence between Epstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane
able here because it would, at most, bar admissibility of the correspondence into evidence "against the defendant who made the plea" — i.e., against Jeffrey Epstein. But the victims intend to obtain and use the correspondence to seek relief from the Government. Accordingly, the Rule cannot be used to bar the vic
ughly litigated by the defense attorneys' client (Jeffrey Epstein) more than a year ago, and Epstein's arg
Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adv
/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this M
FENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this Memorandum of Law as to the Doctrines of Waiver of Attorney-Client and Work Product protections as claimed by Edwards and at issue
OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT
etely, thereby exposing the documents to civil discovery in litigation between the discloser and a third party." Id. at 1417. There, the defendant, Westinghouse, disclosed documents generated during an internal investigation to the SEC and DOJ to cooperate with those agencies' respective investigations. The
s Polk Dentons Dickinson Wright Dudley Topper Epstein Becker Green EFTA00032976 --- PAGE BREAK ---
Page: EFTA00032976 →ses, but was told to refine a commitment agreement for $300 million in second-lien financing for its proposed Chapter 11 exit. Read full article » Westinghouse WARN Plaintiffs Split Over Court Jurisdiction The bitter, monthslong debate over what to do with two putative WARN Act class actions against Westin
Page: EFTA00032977 →Entities connected to both Jeffrey Epstein and Westinghouse

Marc Rich
PERSONLeon Black
PERSON
John F. Kennedy
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Condoleezza Rice
PERSON
Newark
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSON
Prince Charles
PERSONSouthern District
LOCATIONJane Doe
PERSON
Michael Cohen
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON