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From: Mail Delivery Subsystem To: [email protected] Subject: Delivery Status Notification (Delay) Date: Thu, 22 Aug 2013 13:57:08 +0000 This is an automatically generated Delivery Status Notification THIS IS A WARNING MESSAGE ONLY. YOU DO NOT NEED TO RESEND YOUR MESSAGE. Delivery to the following recipient has been delayed: Message will be retried for 2 more day(s) Technical details of temporary failure: The recipient server did not acce t our re uests to connect. Learn more at [(0) [63.175.28.164]:25: Connection timed out] Original message DKIM-Si ature: v=1; a=rsa-sha256; c=relaxed/relaxed; d ;s=20120113; h=mime-version:in-reply-to:references:date:message-id:subject:from:to :content-type; bh=b/10x2814ZhgtuRNr9uaM/A4yInZhs3do89dDzVRWJI=; b=HJ22D1zIOVaPH1G2m314DSFErgcW0iDr5FPkKYmThvuBPrZSayFVR8ze+TqBDZGXQ7 BywK1A+AEdp6c005ZYWodBi/U4TbICZALIE5F3KcOWErFtPluBZzD9Nrn/Q/vDGayuWEre I LmVEFqH/xU7d/d4MKank+reJ3 qd9+4aGP5CCHzS8yUlc116136MWLJDvgyyKvkiuF5U3 N5Rx 1 IceUns8MFippkVpeaa9YL+qdlIc2jOLdPj6vRgNWttvfBebhF14Kd3JMOY/Hab0 c5BeUeNTedjEKYw9rdGICALIDW2zBf+5GE4EtDoE3HrmV7xSiaBI9I+sFu+liftSglOr b+tw= MIME-Version: 1.0 X-Received: by 10.66.162.167 with SMTP id yb7mr9878260pab.16.1377092294623; Wed, 21 Aug 2013 06:38:14 -0700 (PDT) Received: by 10.68.31.196 with HTTP; Wed, 21 Aug 2013 06:38:14 -0700 (PDT) In-Reply-To: <DE2418EDDlED41B78BCC50D7EC880956®martin037a3ael> References: <F712EBE036B6A84FAAF82097C45052EB23378A1D@SDSBS-Exch2.US.Searcy.Law> <2697B05B038B3542BABODD8E6CA700CB86C9OF P3PWEX3MB004.ex3.secureservennet> <2697B05B038B3542BABODD8E6CA700CB86CF3F P3PWEX3MB004.ex3.secureserver.net> <DE2418EDDlED41878BCC50D7EC880956@martin037a3ael> Date: Wed, 21<Ata 2013 07:38:14 -0600 Message-ID: Subject: Fwd: ATTORNEY-CLIENT PRIVILEGE From: Jeffrey Epstein <*eevacation a, mail.com> To: Darren Indyke , Jack Goldberger EFTA00967702 Content-Type: multipart/alternative; boundary 47d7bacbe700b49c104e47549ea Is there a way to get crow to rule prior Forwarded message From: *Martin Weinberg* Date: Wednesday, August 21, 2013 Subject: ATTORNEY-CLIENT PRIVILEGE To: Jeffre E stein <*eevacation ail.com> Cc: ** My very quick response to the question about waiver of privilege: Step 1 - Have the Fla lawyers identify the leading cases in Fla state law (from Fla Sup Ct and District C/Appeals where case is pending) defining the scope of waiver when a party raises reliance on counsel (a) if a party has multiple lawyers at the same time does waiver as to one result in waiver as to all, (b) scope of subject matter waiver - how integrated or overlapping are other subjects of representation i.e. can the opposing party contend that the opinion opens door to all related subjects within representation, (c) discovery - can the opposing party access opinion lawyers file to determine all information available to lawyer at time of opinion including documents received from JE, emails from JE, does and emails from co-counsel so that waiver for one is de facto waiver for all under circumstances where there were multiple lawyers (this requires some knowledge of how broadly the trial judge is interpreting rules of discovery). Reliance on counsel is a total waiver of all work product and attorney-client that relates to the subject of the opinion. How much farther it goes is case and fact specific. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail. Message truncated EFTA00967703