Epstein Secrets

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

ion. § 90.507, Fla. Stat. In plain English: "When a party himself ceases to treat the matter as confidential, it loses its confidential character." Delap v. State, 440 So. 2d 1242, 1247 (Fla. 1983). See also Tucker v. State, 484 So. 2d 1299, 1301 (Fla. 4th DCA 1986) ("The law is clear that once communications

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 MOTION FOR AN IN CAMERA INSPECTION OF 30 E-MAILS Counter-De

es to them. Following this Court's in camera review, Epstein seeks a ruling from this Court that these 30 e-mails, which were improperly withheld by Edwards, an officer of the court, on the false bases of irrelevancy, attorney-client privilege and inapplicable basis of work product3, should be unsealed,

th attorney-client and work product) to Conrad, Scherer, an adversarial party's counsel, Edwards waived those privileges. See § 90.507, Fla. Stat.; Delap v. State, 440 So. 2d 1242, 1247 (1983). See also Tucker v. State, 484 So. 2d 1299, 1301 (Fla. 4th DCA 1986) ("The law is clear that once communications prot

ISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT BRADLEY EDWARDS

gh his undersigned counsel, hereby respectfully seeks the entry of an Order compelling Defendant Bradley Edwards to produce the documents listed in Edwards' privilege log, or, in the alternative, the entry of an Order compelling Edwards to serve a privilege log that fully complies with Fla. R. Civ. P. 2

x-wife). The attorney-client privilege is waived if the client voluntarily discloses the substance of the communication. See § 90.507, Fla. Stat.; Delap v. State, 440 So. 2d 1242, 1247 (Fla. 1983) ("[W]hen a party himself ceases to treat the matter as confidential, it loses its confidential character."). Edw