EFTA00805367Set 9
2018-03-0822p7,118w
waiver
category below applies to which e-mail.
1. Voluntary and Intentional Disclosure to Adversary Constitutes Waiver
As a threshold basis for waiver, it is undisputed that the law firm ... Razorback victims' interests were not aligned in any way, and in fact
were adversarial in every key respect, Edwards cannot "have his cake and eat it too" by voluntarily
producing ... Attorney-Client Privilege and Work-Product Protection Based
on Voluntary Disclosure to a Clear Adversary in the Razorback Litigation.
Edwards waived attorney-client privilege and work-product protection claimed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805367.pdf
EFTA00287327Set 9
20p8,168w
counter this direction and help to keep markets efficient and functioning well? How might
adversaries and incentives lead to a thwarting of such attempts?
POTENTIAL GOALS
Identify key challenges ahead ... planning, and action.
• Rise of powerful Al-power planning, messaging, and systems by competitors, adversaries, and
third parties that can prompt war intentionally or inadvertently via sham or false signaling ... scenarios can be painted that involve that start of a large-scale war among adversaries via
inadequate human oversight in a time-pressured response situation after receiving signals
https://www.justice.gov/epstein/files/DataSet%209/EFTA00287327.pdf
EFTA00205728Set 9
2011-10-1027p8,165w
U.S.C. § 3771(c)(1). Second, the CVRA bars the Government from erecting an
adversarial work product privilege against the victims when they are attempting to secure
information to protect their ... explained in Section III.B below, the victims do not believe they stand in an
adversarial posture with the Government, as Congress has obligated the Government to use its
"best efforts ... Cooperatively to Protect the
Victims' Rights and Thus Bars the Government from Interposing an
Adversarial Work Product Defense.
The Government argues that the work-product doctrine it is asserting prevents
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205728.pdf
EFTA01097994Set 9
2011-10-1027p8,199w
U.S.C. § 3771(c)(1). Second, the CVRA bars the Government from erecting an
adversarial work product privilege against the victims when they are attempting to secure
information to protect their ... explained in Section III.B below, the victims do not believe they stand in an
adversarial posture with the Government, as Congress has obligated the Government to use its
"best efforts ... Cooperatively to Protect the
Victims' Rights and Thus Bars the Government from Interposing an
Adversarial Work Product Defense.
The Government argues that the work-product doctrine it is asserting prevents
https://www.justice.gov/epstein/files/DataSet%209/EFTA01097994.pdf
EFTA01081982Set 9
2012-04-1927p8,102w
U.S.C. § 3771(c)(1). Second, the CVRA bars the Government from erecting an
adversarial work product privilege against the victims when they are attempting to secure
information to protect their ... explained in Section III.B below, the victims do not believe they stand in an
adversarial posture with the Government, as Congress has obligated the Government to use its
"best efforts ... Cooperatively to Protect the
Victims' Rights and Thus Bars the Government from Interposing an
Adversarial Work Product Defense.
The Government argues that the work-product doctrine it is asserting prevents
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081982.pdf
EFTA01074153Set 9
2011-06-0211p2,554w
Trustee; b) the Bankruptcy Rule 7030 deposition of Rothstein in any pending adversary
proceeding of record filed by the Trustee, including Case No. 10-03767-RBR-BKC-A ("the
Gibraltar ... Adversary Action"); c) the Rule 1.310, Fla. R. Civ. P., deposition of Rothstein in the
state court action Razorback Funding, LLC et al. v. Scott W. Rothstein ... Trustee has or may have against third parties who are not parties to
existing adversary proceedings in this matter; and (b) the acts, conduct, property or liabilities and
financial condition
https://www.justice.gov/epstein/files/DataSet%209/EFTA01074153.pdf
EFTA01113713Set 9
2011-06-0211p2,549w
Trustee; b) the Bankruptcy Rule 7030 deposition of Rothstein in any pending adversary
proceeding of record filed by the Trustee, including Case No. I0-03767-RBR-BKC-A ("the
Gibraltar ... Adversary Action"); c) the Rule 1.310, Fla. R. Civ. P., deposition of Rothstein in the
state court action Razorback Funding, LLC et al. v. Scott W. Rothstein, et at, pending ... Trustee has or may have against third parties who are not parties to
existing adversary proceedings in this matter; and (b) the acts, conduct, property or liabilities and
financial condition
https://www.justice.gov/epstein/files/DataSet%209/EFTA01113713.pdf
EFTA00160591Set 9
2023-12-0579p28,473w
continue to work relentlessly to stay ahead of
those threats and to outpace our adversaries.
For example, last year we disrupted over 40 percent more cyber operations and
arrested over ... particular that is indispensable to our
efforts to combat threats posed by foreign adversaries, one that will expire in just a
few short weeks if Congress does ... conduct US
person queries of our existing 702 collection. When it comes to foreign adversaries
like Iran, whose actions across a whole host of threats have grown more brazen,
seeking
https://www.justice.gov/epstein/files/DataSet%209/EFTA00160591.pdf
EFTA01122989Set 9
2011-08-12113p33,117w
Okay. How can a letter between you and
11 your co-counsel and an adversary in a criminal prosecution be
12 considered work product, if it's given ... adversary?
13 MR. BLACK: Yes, sir, and I am happy to answer that
14 question. In order to do so, I have to give the Court some
15 background ... things that were sent to
8 the government -- and while we were adversaries at the time,
9 although we no longer became adversaries -- it was under the
10 protections that
https://www.justice.gov/epstein/files/DataSet%209/EFTA01122989.pdf
EFTA01070608Set 9
2011-08-12138p36,785w
Okay. How can a letter between
4 you and your co-counsel and an adversary in a
5 criminal prosecution be considered work product, if
6 it's given ... adversary?
7 MR. BLACK: Yes, sir, and I am happy to answer
8 that question. In order to do so, I have to give
9 the Court some background ... things that were sent to the government -- and
25 while we were adversaries at the time, although we
Page: 24
EFTA01070631
sor & Associates
Repettttt z and frar•cip.iiit
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070608.pdf
EFTA00611358Set 9
2011-08-12138p36,797w
Okay. How can a letter between
4 you and your co-counsel and an adversary in a
5 criminal prosecution be considered work product, if
6 it's given ... adversary?
7 MR. BLACK: Yes, sir, and I am happy to answer
8 that question. In order to do so, I have to give
9 the Court some background ... things that were sent to the government -- and
25 while we were adversaries at the time, although we
Page: 24
EFTA00611381
sor & Associates
Rcpe,,,,, z and trao.c-ips
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611358.pdf
EFTA01118695Set 9
2012-05-1417p6,707w
BALLAMOR CAPITAL MANAGEMENT, INC., BALLAMOR CAPITAL
MANAGEMENT, LLC, and BARRY R. BEKKEDAM, defendants in Adversary Proceeding
No. 11-02929-BKC-RBR-A pending in this Court, give notice ... parties who are authorized to receive electronically Notices of
Electronic Filing in this adversary proceeding and by first class mail, postage pit-paid, on those
persons listed on the Service ... Ballamor Capital Management, Inc., Ballamor Capital Management, LLC, and Barry Bekkedam, as defendants
in adversary proceeding number 11-02929-BKC-RBR-A, are required to advise you of how much
https://www.justice.gov/epstein/files/DataSet%209/EFTA01118695.pdf
EFTA01082366Set 9
2012-02-1310p2,908w
deposition [DE 120], the responses to the
Trustee's Motion of the Brauser Adversary Defendants [DE 108], the Insurance
Companies [DE 109],' Emess Capital, LLC [DE 110], Ballamor Capital Management ... deposition, in conjunction with its statutory duties and deadlines,
the Trustee filed additional adversary actions against numerous parties. Some of those
parties sought to be included in the December deposition ... deposition in
early spring of 2012. Simply being sued by the Trustee in an adversary
action is not by itself sufficient cause. Those parties who believe that they
have sufficient
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082366.pdf
EFTA00874196Set 9
2013-05-2029p10,004w
Battle concept -- which disrupts the so-called "kill
chains" of our potential adversaries -- is our services' approach to negate
these efforts.
A new form of coercion
Nations seeking to intimidate ... while proliferation has
put them in the hands of a range of potential new adversaries. And three,
the American way of projecting force changed from placing bases and
garrisons close ... defeating threats to access. Air-Sea Battle is not focused on one specific
adversary, since the anti-access capabilities it is intended to defeat are
proliferating and, with automation, becoming
https://www.justice.gov/epstein/files/DataSet%209/EFTA00874196.pdf
EFTA00148445Set 9
2020-10-2338p22,243w
activity that threatens the sanctity of your vote." Thomas: "Two of America's primary
adversaries successfully penetrated voter registration databases at the local level along with
gleaning voter data from ... Iran poses to the U.S. election, a different foe - Russia - remains the more potent adversary,
and has in recent months stolen data from at least two county systems in California ... Blake, 492K) reports that "leaders of the Senate
Select Committee on Intelligence warned foreign adversaries Thursday not to meddle in next
month's elections while urging Americans to stay vigilant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00148445.pdf
EFTA00136939Set 9
2020-10-2346p22,773w
activity that threatens the sanctity of your vote." Thomas: "Two of America's primary
adversaries successfully penetrated voter registration databases at the local level along with gleaning voter data
from ... Iran poses to the U.S. election, a different foe — Russia — remains
the more potent adversary, and has in recent months stolen data from at least two county systems in California ... Blake, 492K) reports that "leaders of the Senate Select Committee on Intelligence warned foreign
adversaries Thursday not to meddle in next month's elections while urging Americans to stay vigilant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00136939.pdf