Epstein Secrets

ldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach. FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 [email protected] Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Jay Howell Jay

laintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730

mpany's disclosure of documents to the SEC during criminal investigation waived work product protections); Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product protection was waived by [party] via production" of the documents in question); In re Columb

Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Salt Lake City, UT 84112 Attorneys for Jane Doe #1 and Jane Doe #2 26 EFTA0

.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

mpany's disclosure of documents to the SEC during criminal investigation waived work product protections); Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question); In re Columbia

ubmitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. E-mail: [email protected] and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 4 The defense attorneys' also propose to file a motion for a protective order if their mot

.L. E-mail: [email protected] and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane

e government is no longer confidential — and therefore no longer protected by the work-product doctrine. See Grace United Methodist Church City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question). Because no con

red on FLSD Docket 05/02/2011 Page 28 of 29 EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit UT 84112 Attorneys for Jane Doe #1 and Jane Doe

. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's g

government is no longer confidential — and therefore no longer protected by the work-product doctrine. See Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question). Because no con