Epstein Secrets

t the victims had been encouraged by the FBI or the Office to overstate their victimization for monetary compensation. • On July 3, 2008, attorney Edwards contacted me to discuss how the Epstein matter had been resolved and to raise concerns regarding that resolution. I shared the concerns that attorn

EFTA00799870 Case 9:08-cv-80736-KAM Document 414 Entered on FLSD Docket 08/11/2017 Page 10 of 11 Respectfully Submitted, /5/ Sal, P. Eeitualua Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. Florida 33301 Telephon Facsimile E

n for monetary compensation. • On July 3, 2008, attorney Edwards contacted me to discuss how the Epstein matter ha

n be waived — indeed, such protection can be waived "impliedly." A very thorough review of the relevant caselaw is found in this Court's decision in Stern v. O'Quinn, 253 F.R.D. 663, 676-77 (S.D. Fla. 2008). As this Court explained, under the doctrine of implied waiver of work product protection, "a p

PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/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

, 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 Memorandum of Law as to the Do

as impliedly waived it through his own affirmative conduct. Pitney-Bowes, Inc. v. Mestre, 86 F.R.D. 444 (S.D. Fla. 1980) (emphasis added); see also Stern v. 0 'Quinn, 253 F.R.D. 663 (S.D. Fla. 2008). "Implied waiver of the attorney-client privilege can occur where a party voluntarily injects either a

9:08-cv-80736-KAM Document 422 Entered on FLSD Docket 09/01/2017 Page 11 of 12 DATED: September 1, 2017 Respectfully Submitted, AI taut 9. Samna Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-28

D Docket 09/01/2017 Page 11 of 12 DATED: September 1, 2017 Respectfully Submitted, AI taut 9. Samna Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mai

oth the victims and the Government agree that the relevant legal standard governing the question of waiver of work-production protections comes from Stern v. O'Quinn, 253 F.R.D. 663, 676-77 (S.D. Fla. 2008), which held that "a party waives work-product privilege protection when (1) assertion of the pr

ssistant United States Attorney 9 EFTA00601690 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 10 of 11 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954 524-2820• Fa

90 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 10 of 11 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954 524-2820• Fax: 954 524-2822 E-mail: Paul G. C

trine in this case does not "deny the opposing party access to information vital to its defense." Stern, 253 F.R.D. at 676. In that case, plaintiff Stern was suing defendant O'Quinn, and O'Quinn's law firm, for defamation. O'Quinn had instituted an investigation of plaintiff Stern, which was conducted

ssistant United States Attorney 9 EFTA00799972 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 10 of 11 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro H

72 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 10 of 11 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac Vice S.J. Quinney College of La

trine in this case does not "deny the opposing party access to information vital to its defense." Stern, 253 F.R.D. at 676. In that case, plaintiff Stern was suing defendant O'Quinn, and O'Quinn's law firm, for defamation. O'Quinn had instituted an investigation of plaintiff Stern, which was conducted

onstitutional basis for precluding trial of criminal case by injunction. Melvin L. Klafter, Leonard R. Harten- feld, Chicago, Ill., for appellant. Edward,. Hanrahan, U. S. Atty., John Peter Lulinski, Thomas W. James, Asst. U. S. Attys., Chicago, Ill., William W. Goodrich, Asst. Gen. Counsel, Joanne

ill be reversed. The order of the District Court granting sum- mary judgment on Counts Four and Seven will be affirmed as to all appellees, except Stern, with respect to whom the order will be reversed. The District Court's dismiss- al of Count Five on statute of limitations grounds will be affirmed

g the grant of summary judgment.”); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under R

characterised as a ‘slap on the wrist’ for him, and ended up serving 13 months of his sentence, much of it in a liberal work-release programme Lawyer Brad Edwards, who represented several of Epstein’s victims, said: ‘Rather than punish him the way they would an average Joe, they sent a clear message that with e

Fort Lauderdale, FL 33301 wae SS Name and Title: Bradley J. Edwards, Director Name and Title: on Sulte2 Fort Lauderda

Atleast 40 girls aged 13 to 17 heve come borward with similar stories, sere saying Epstein sexually assaulted trem during the massage, According to Brad Edwards, a lawyer for some of the acousers, Epstein was molesting under-age girls every day he was ie Palm Beach. Police, who had wanted te pursue possib/e

eitfeldlaw.com) It is my pleasure to report that Bradley J. Edwards, Paul G. Cassell, and Alan M. Dershowitz have res

ying amendment where “addition of more plaintiffs .. . would not have affected the issues underlying the grant of summary judgment.”’); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under Rule 15, “courts have held that leave to amend to assert a claim already at issue in [another lawsuit

Avenue, Suite 2, Fort Lauderdale, FL 33301, By: Bradley J. Edwards, Esq., S.J. QUINNEY COLLEGE OF LAW, UNIVERSITY OF UTAH

issue in the exercise of Article III judicial power" and "the resultant value of such information to those monitoring the federal courts." See id.; Stern v. Cosby, 529 F.Supp.2d 417, 420 (S.D.N.Y. 2007) (internal citations omitted) ("the court must determine the weight of the presumption, that is, whe