This document is a legal reply filed by Jane Doe 1 and Jane Doe 2 in support of their motion for a finding that the Government has waived work production protections. The reply argues that the Government has used its internal deliberations as a basis for ruling on pending cross-motions for summary judgment, thus waiving work-product privilege. The document discusses various legal standards and cases, including Stern v. O'Quinn, and argues that the Government's motivations and internal deliberations are central to the case. The reply also addresses issues related to the CVRA and prosecutorial discretion, and argues for the production of documents previously withheld by the Government.
documents/EFTA00600116.pdf
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