Epstein Secrets

Submitted, AI taut 9. Samna Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

examination of communications otherwise protected by the attorney-client privilege loses that privilege." DE 421 at 7 (citing Cox v. Administrator, U.S. Steel & Carnegie, 17 F.3d 1386, 1422 (11th Cir. 1994)). The Government has clearly injected its deliberations into the case, and fairness requires that the Court fi

Page 10 of 11 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

airness requires an examination of communications otherwise protected by the attorney-client privilege loses that privilege." Cox v. Administrator. U.S. Steel & Carnegie 17 F.3d 1386, 1422 (11th Cir. 1994. The subject matter waiver doctrine does not apply since the government's assertion that the decision not to tel

Page 10 of 11 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

airness requires an examination of communications otherwise protected by the attorney-client privilege loses that privilege." Cox v. Administrator. U.S. Steel & Carnegie 17 F.3d 1386, 1422 (11th Cir. 1994. The subject matter waiver doctrine does not apply since the government's assertion that the decision not to tel

d by facsimile (561) 802-1787, and U.S. mail to: Maria Villifana, Esq., U.S. Attorney's Office, 500 uth

erial prepared by agents for the attorney as well as those prepared by the attorney himself. 422 U.S. at 238-39; see also See Cox v. Administrator U.S. Steel & Carnegie, 17 F.3d 1386, 1422 (11th Cir.), modified on other grounds, 30 F.3d 1347 (11i° Cir. 18 Black. Srebnick. Kornspan 8( Stumpf 201 S. Biscayne Boulev

etitioner: Bradley James Edwards, LEAD ATTORNEY, Farmer Jaffe Weissing Edwards Fistos & Lehrman PL, Fort

Such "opinion work product enjoys a nearly absolute immunity and can be discovered only in very rare and extraordinary circumstances." Cox v. Adm'r U.S. Steel & Carnegie, 17 F.3d 1386, 1422 (11th Cir. 1994). For internal use only SDNY_GM_00059575 CONFIDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SONY-0022399 EF

ATE OF SERVICE I HEREBY CERTIFY that on July 17, 2007, a true and correct copy of the forging motion was furnished by facsimile and U.S. mail to: Maria , Esq., U.S. Attorney's Office, 500 uth Australian Avenue, Suite 400, West Palm Beach, FL 33401. By: ROY BLACK, ESQ Counsel for Jeffrey Epstein

erial prepared by agents for the attorney as well as those prepared by the attorney himself. 422 U.S. at 238-39; see also See Cox v. Administrator U.S. Steel & Carnegie, 17 F.3d 1386, 1422 (11i6 Cir.), modified on other grounds, 30 F.3d 1347 (11th Cir. 18 Black Srebnick, Komspan &St ro n 20I S. Biscayne Boulevard

1 and 2' United States, Case No. 08-80736-C1V-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Wcissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-

, 959 F. Supp. 1529, 1536-37 (S.D. Fla. 1997) ("a highly particularized showing" is required to overcome a claim of privilege); Cox v. Administrator U.S. Steel & Carnegie, 17 F.3d 1386, 1422 (11th Cir. 1994) ("Opinion work product enjoys a nearly absolute immunity and can be discovered only in very rare and extraordi