Epstein Secrets

ions, as well as other privileges and protections, over its internal deliberations in connection with the non- prosecution agreement it reached with Epstein and related discussions about victim notifications. As the Court is aware, the victims have previously-filed a substantial motion for summary judgm

nt Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua II EFTA00799872 Case 9:08-cv-80736-KAM Document 414-1 Entered on FLSD Docket 08/11/2017 Page 1 of 1 UNITED STATES DISTRICT

uite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua II EFTA00799872

hen considering any assertion of attorney-client privilege, which can likewise be explicitly or implicitly waived. See GAB Business Servs., Inc. v. Syndicate 627, 809 F.2d 755, 762 (11th Cir.1987) (discussing the concept in the context of the attorney-client privilege); Baratta v. Homeland Housewares, LLC, 24

/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

ed communication directly into the litigation, as necessary to prove an element of a claim or defense." Id. See also, e.g., GAB Bus. Sews., Inc. v. Syndicate 627, 809 F.2d 755 (11th Cir. 1987) ("If 627 introduces evidence as to the strength of JDA Farms' case-as 627 must to prevail—it cannot hide behind the s

nt argues that its internal deliberations led to a decision not to notify victims because the line prosecutor wanted to avoid the possibility that "Epstein's counsel would impeach the victims and my credibility by asserting that I told victims they could receive money for implicating Epstein." DE 403-10

ick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 305-371-6421 Fax: 358-2006 Email: [email protected] Attorneys for Jeffrey Epstein Is/ &ale. p. 5cloanda 1 I EFTA00600127

2006 Email: [email protected] Attorneys for Jeffrey Epstein Is/ &ale. p. 5cloanda 1 I EFTA00600127

vilege. The Government does not dispute that the same implicit waiver can be made of the attorney client privilege. See GAB Business Servs., Inc. v. Syndicate 627, 809 F.2d 755, 762 (11th Cir.1987) (discussing the implied waiver concept in the context of the attorney-client privilege). Indeed, the Government