Epstein Secrets

nvestigating the-ease Epstein. See Declaration of Bradley J. Edwards, Esq. at ¶¶ 1-2 (hereinafter "Edwards Declaration").

agreed-to-seek no mere less than $150,000 in damages against Epstein — an amount that Epstein argued later was limited to no more than $50,000). See Edwards Declaration, Exhibit "C" (copy of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel, as well as the U.S. At

ht the Importance of Vi.. Page 3 of 3 Lauderdale, Florida 33301 and may be reached at (800)400-1098 or (964) 624- 2820 Additional information about Brad Edwards or Farmer, Jaffe, Welssing, Edwards, Fistos 8 Lehrman. P.L. may be obtained from the fires webalte at swAv palhlotustIce com. FAQ4 I Contact Us I

iem-at—II—Ph AUSA Villafafia strongly encouraged Attorney Edwards and his client to attend and address the Court a

ue lacl hither •"(psardrrerSoUng corn •-•"" Source : BARD WrIrerlog Cit/Town Fon La, deroale • SlouilA - Muted SLISIC 111OUSPt : Loser Tags : Brae Edwards. Jeffrey Epstein. Cruno V•ctrus Rights, Ulmer one urasono shortcut : prlog oriel 2313086 0111C111111111: 1$$ UOI1 011110 ;1101.. 101041.US are SI.

ed, for example, the work product argument: Disclosure of work-product materials to an adversarywaives 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 F2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the com

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

s not 6 EFTA00805372 clearly 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 c

October 10. 2011 25 EFTA00205752 Case 9:08-cv-80736-KAM Document 106 Entered on FLSD Docket 10/10/2011 Page 26 of 27 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.

26 of 27 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, ED

"Disclosure to an adversary waives the work product protection as to items actually disclosed, even where disclosure occurs in settlement." In re Chrysler Motors Corp. Overnight Evaluation Program Litigation, 860 F.2d 844, 846 (8th Cir. 1988). Thus, "[c]ourts will imply waiver when a party In Jane Doe v. Epstein,

all rational means for ascertaining truth. Fed.Rules Evid.Rule 501, 28 U.S.C.A. Paul Cassell, University of Utah College of Law, Salt Lake Cty, UT, Bradley James Edwards, Farmer Jaffe Weissing Edwards Fistos & Lehman, PL, Fort Lauderdale, FL, Jay C. Howell, J. Howell & Associates, Jacksonville, FL, for Plaintiffs-App

College of Law, Salt Lake Cty, UT, Bradley James Edwards, Farmer Jaffe Weissing Edwards Fistos & Lehman, P

voluntarily States during the plea negotiations is not 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 com

21 at 9:41 am On Friday the 1 1 th Circuit ruled that discovery can move forward in an important Crime Victims' Rights Act case that my co-counsel, Brad Edwards, and I are pursuing. The narrow issue before the court was whether prosecutors and defense attorneys could assert some sort of "privilege" to preve

agreement and that the pleas would bar a federal prosecution. As a result, the victims did not attend the state court proceedings. On July 7, 2008, Edwards and I filed a petition alleging that Jane Doe No. 1 was a victim of federal sex crimes committed by Epstein and that the United States had wrongful

use plea discussions are not confidential: 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 co

lionaire sex offender Jeffrey Epstein link Epstein and Jean Luc Brunel. owner of modeling agency MC2. The documents say MC2 employees told attorney Brad Edwards that Epstein's condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women

e documents say MC2 employees told attorney Brad Edwards that Epstein's condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women claiming to be victims of sex abuse by Epstein, was told MC2 brought underage girls in from all ove

e plea discussions are not confidential: 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.. 86012.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073. 1081-82 (4th Cir. 1981). Even if it shared the com

ONEYWELL,* District Judge. * Honorable Charlene Edwards Honeywell, United States District Judge for the M

lea negotiations is not clearly 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 co

ONEYWELL,* District Judge. * Honorable Charlene Edwards Honeywell, United States District Judge for the M

lea negotiations is not clearly 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 co

ONEYWELL,* District Judge. * Honorable Charlene Edwards Honeywell, United States District Judge for the M

lea negotiations is not clearly 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 co

ONEYWELL,* District Judge. * Honorable Charlene Edwards Honeywell, United States District Judge for the M

lea negotiations is not clearly 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 co