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

ng it relevant to the case; and (3) application of the protection would deny the opposing party access to information vital to its defense. Stern v. O'Quinn, 253 F.R.D. 663, 676 (S.D. Fla. 2008) (citing Granite Partners, L.P. v. Bear, Stearns & Co., Inc., 184 F.R.D. 49, 55 (S.D.N.Y.1999) (citing Heani v

d — 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 party waives

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

ictims 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 protection re

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

rning its internal deliberations while making representations regarding those deliberations to obtain summary judgment." D.E. 414 at 1. In Stern v. O'Quinn 253 F.R.D. 663 (S.D.Fla. 2008), the district court identified two ways in which the attorney work-product doctrine could be waived. An "implied wai

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

rning its internal deliberations while making representations regarding those deliberations to obtain summary judgment." D.E. 414 at 1. In Stern v. O'Quinn 253 F.R.D. 663 (S.D.Fla. 2008), the district court identified two ways in which the attorney work-product doctrine could be waived. An "implied wai

DDITIONAL PERSONAL INFORMATION SSN DOB Gender LexID(sm) 090-44-XXXX 111953 Male 000752546965 (Age 64) Subject Summary Name Variations 1: EDWARDS. JEFFERY 2: EPSTEIN, J 3: EPSTEIN, JEFFERY 4: EPSTEIN, JEFFERY E 5: EPSTEIN, JEFFREY 6: EPSTEIN. JEFFREY E 7: EPSTEIN. JERRERY 8: EPSTI

nal version, responsive, chain, grand jury, crime victims, federal government, non-prosecution, investigative COUNSEL: Mi For Jane Doe, Petitioner: Bradley James Edwards, LEAD ATTORNEY, Farmer Jaffe Weissing Edwards Fistos & Lehrman PL, Fort Lauderdale, FL; Jay C. Howell, PRO HAC VICE, Jay Howell & Associates PA, Ja

(See DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O'Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within pleading to decide application of work product privilege)

ellon Foundation," and Hazel Ruth EFTA00148339 Edwards, who chairs the Department of Architecture at How

related charges, the Elizabeth City Police Department said in a statement. Investigators said they're also looking into the possibility of deeming O'Quinn's actions a hate crime." The AP adds, "The women who were struck, both 42, were treated at a hospital and released, police said. They were part of a

at the Andrew Mellon Foundation," and Hazel Ruth Edwards, who chairs the Department of Architecture at Ho

d related charges, the Elizabeth City Police Department said in a statement. Investigators said they're also looking into the possibility of deeming O'Quinn's actions a hate crime." The AP adds, "The women who were struck, both 42, were treated at a hospital and released, police said. They were part of