Epstein Secrets

d discussions about victim notifications. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this day of August, 2017. KENNETH A. MARRA United States District Judge EFTA00799873

Florida, this day of August, 2017. KENNETH A. MARRA United States District Judge EFTA00799873

n be waived — 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 p

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U

trine in this case does not "deny the opposing party access to information vital to its defense." Stern, 253 F.R.D. at 676. In that case, plaintiff Stern was suing defendant O'Quinn, and O'Quinn's law firm, for defamation. O'Quinn had instituted an investigation of plaintiff Stern, which was conducted

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U

trine in this case does not "deny the opposing party access to information vital to its defense." Stern, 253 F.R.D. at 676. In that case, plaintiff Stern was suing defendant O'Quinn, and O'Quinn's law firm, for defamation. O'Quinn had instituted an investigation of plaintiff Stern, which was conducted

t 06/30/2008 Page 1 of 35 CASE NO.: 08-CV-80119-MARRA/JOHNSON EXHIBIT A EFTA00222254 Case 9:08-cv-8

he pre than .ply 13 to do it, inane it ware ism you all now an 14 *boot It than 1 -- but L'S happy to got alfl aaaaaa 15 from At. liners. Judge Stern, everybody *toe teboet 16 Pot barlignoll with this hearing today. POPP 17 cow vedy tittle *bout tt. but ay reptooriktiOno le as• what they ate

g the grant of summary judgment.”); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under R

r Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016). 7. Attached as

Florida, this 6" day of April, 2015. ea fo “in KENNETH A. MARRA United States District Judge 10 GIUFFRE002853

r Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016). I declare under

ying amendment where “addition of more plaintiffs .. . would not have affected the issues underlying the grant of summary judgment.”’); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under Rule 15, “courts have held that leave to amend to assert a claim already at issue in [another lawsuit

16, 39, and 49. " DE 293, in its entirety. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6" day of April, 2015. KENNETH A. MARRA United States District Judge 10 HOUSE_OVERSIGHT_014856