Epstein Secrets

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

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

[email protected] Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan

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

the building." Bloomberg says Trump argued Rep. Eric Swalwell's (D-CA) lawsuit "unfairly seeks to hold

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

the building." Bloomberg says Trump argued Rep. Eric Swalwell's (D-CA) lawsuit "unfairly seeks to hold

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

or Roy Black, Intervenor: Jacqueline Perczek, Roy Eric Black, Black Srebnick Kornspan & Stumpf, Miami,

(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)