Epstein Secrets

ached to this Notice as Exhibit A, and Edwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the Eleventh Circuit held that Epstein's former counsel had waived the work- product privilege with respect to documents sought by Ed

F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for federal offenses, and the intervenors' disclosure of their work product waiv

tatement with the following authorities: See, e.g., Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414, 1429 (3d Cir. 1991) (Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adv

109, 116 (2d Cir.2005) (emphases The express language of Rule 410 also makes clear that "derivative evidence" is never excluded from a proceeding. See United States v. Ruhkowsi, 814 F.2d 594, 599 (11th Cir. 1987). 8 EFTA00205735 Case 9:08-cv-80736-KAM Document 106 Entered on FLSD Docket 10/10/2011 Page 9 of 2

ary of Enclosures" and justified the privilege by characterizing the documents as "attorney-client communication[s]" without explanation.") (citing United States v. Constr. Prods. Research, Inc., 73 F.3d 464, 473 (2d Cir.1996)).8 Once the Government has cataloged the documents in its privilege log, it then bea

Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adv

In the Court's Order of September 26, 2011, granting in part the Petitioners' Motion for finding violations of the CVRA, the Court did not address the United States' argument that there is no remedy available for the Petitioners due in part to their failure to seek a prompt resolution of the case. However, in li

6, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to the Securities and Exchange Commission and the Justice Department during their investigations of Westingh

familiar with this basic principle. Specifically, in Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014), it was Edwards who argued that the United States failed to confer with his clients before entering a non-prosecution agreement with Epstein. Edwards' clients had sought to discover correspondence b

etely, thereby exposing the documents to civil discovery in litigation between the discloser and a third party." Id. at 1417. There, the defendant, Westinghouse, disclosed documents generated during an internal investigation to the SEC and DOJ to cooperate with those agencies' respective investigations. The

In the Court's Order of September 26, 2011, granting in part the Petitioners' Motion for finding violations of the CVRA, the Court did not address the United States' argument that there is no remedy available for the Petitioners due in part to their failure to seek a prompt resolution of the case. However, in li

6, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to the Securities and Exchange Commission and the Justice Department during their investigations of Westingh

13, Bekiempis, 4.19M) reports, "Maxwell is a citizen of France, prosecutors pointed out, saying that the country 'does not extradite its citizens to the United States pursuant to French law'. Maxwell also has US and UK passports. The filing added that 'the defendant has not only the motive to flee, but the means t

$9 billion nuclear fraud" case. In his position with SCANA, Byrne "has admitted to knowingly engaging with others in fraud during construction of 2 Westinghouse AP100 reactors" as part of the VC Summer nuclear project. Federal officials "are believed to have offered him a deal to testify against fellow execu

r, because “today’s young people...seem happy with the frankness of the left and the wholesomeness of the right.” As a result, he is optimistic about the United States’ social stability, which he considers to be “in the middle of an amazing moment of improvement and repair.” Brooks also broke with many in the conser

P. Sloan Foundation Research Fellowship, a National Science Foundation Young Investigator Award, a DOE Outstanding Junior Investigator Award, and the Westinghouse Science Talent Search. Randall is an Honorary Member of the Royal Irish Academy and an Honorary Fellow of the British Institute of Physics. In 2003,