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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
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
mas & LoCicero PL, Tampa, FL. JUDGES: KENNETH A. MARRA, United State District Judge. OPINION BY: KENNET
ami, FL. For The Palm Beach Post, Palm Beach Daily News, Intervenors: Rachel Elise Fugate, LEAD ATTORNEY, Thomas & LoCicero PL, Tampa, FL. JUDGES: KENNETH A. MARRA, United State District Judge. OPINION BY: KENNETH A. MARRA OPINION OPINION AND ORDER This cause is before the Court on various discovery related
(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)
UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U
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
UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U
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
Entities connected to both Kenneth Marra and O'Quinn

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
United States
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Prince Andrew
PERSONFBI
ORGANIZATION
Dexter Lee
PERSON
Virginia Giuffre
PERSON
Donald Trump
PERSON
Salt Lake City
LOCATION
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATIONChambers
PERSON
United States District Court
ORGANIZATION