This memorandum of law is submitted by Jeffrey Epstein in the case against Scott Rothstein and Bradley J. Edwards. Epstein argues that Edwards has waived attorney-client and work-product protections for 47 emails that are central to Edwards' malicious prosecution claim against Epstein. The memorandum outlines four reasons for the waiver: voluntary disclosure to an adversary, issue injection, the crime-fraud exception, and the inapplicability of work-product protection. Epstein seeks the court's ruling on the admissibility of these emails and requests an in camera review.
documents/EFTA00805367.pdf
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