Epstein Secrets

400 ISM Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stu

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

usdoj.zov Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stu

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

or Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Biscayne Boule

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

or Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Biscayne Boule

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

course about Israel in Washington, the U.S. media and other institutions." As pro-Palestinian posts have "spread across social media in recent days, Black, Armenian, liberal Jewish and other social justice organizers have helped Palestinians push their message both online and in the streets." That mer

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

course about Israel in Washington, the U.S. media and other institutions." As pro-Palestinian posts have "spread across social media in recent days, Black, Armenian, liberal Jewish and other social justice organizers have helped Palestinians push their message both online and in the streets." That mer

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

the planet. • Riot-Makers-R-Us: Whether it's the Black Lives Matter rioters, the Occupy Wall Street rio

(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)