Epstein Secrets

opportunity to litigate his concerns in the other case, this Court need not — and should not — allow permissive intervention in this one. See. e.g., Morgan'. Sears, Roebuck & Co., 124 F.R.D. 231 (1988) (declining intervention in one case where litigation on a similar issue was already underway elsewhere

present that interest. Among the interests that satisfy these criteria are injury to reputation. Sackniani. Liggett Grp., Inc., 167 F.R.D. 6, 20-21 (E.D.N.Y. 1996) (citing Penthouse Intl. W.I. Playboy Enterprises, Inc.. 663 F.2d 371, 373, 392 (2d Cir. 1981)). The burden of demonstrating an interest relat

ptember 3, 2008 VIA COURIER Re: Jeffrey Epstein/ NOTIFICATION OF IDENTIFIED VICTIM Dear By virtue of this letter, the United States Attorney's Office for the Southern District of Florida provides you with the following notice because you are an identified victim of a federal offense. On June 30, 2008, Jeffrey Epstein (he

tion to the FSIA applies to negate the Kingdom's immunity. "[S]overeign immunity under the FSIA is immunity from suit, not just from liabili- ty." Moran a Kingdom of Saudi Arabia, 27 F.3d 169, 172 (5th Cir.1994). Because there were no factual disputes raised in the Court's resolution of this motion

here- fore not discretionary and not protected by the FSIA); Napolitano v. Tishman Constr. Corp., No. 96 Civ. 4402(5.1), 1998 WL 102789, at •4 (E.D.N.Y. Feb. 26, 1998) (finding purchasing consulate buildings and hiring contractor to renovate is a plan- ning function and therefore discretionary). De

e. See e.g., Safeco Ins. Co. of Am. v. M.E.S., Inc., 269 F.R.D. 41, 46 (E.D.N.Y. 2011) (applying New York law) (citing Abu Dhabi Commercial Bank v. Morgan Stanley, 08 CV 7508 (SAS), 2011 WL 4716334, at *2 (S.D.N.Y. Oct. 3, 2011)). 1. Communications with Jaffe Are Privileged "An attorney-client relationship

foundation for the Court to apply foreign law to Defendant's claims. See Tansey v. Cochlear Ltd., No. 13-CV-4628 SJF SIL, 2014 WL 4676588, at •4 (E.D.N.Y. Sept. 18, 2014) ("the party relying on foreign law has the burden of showing such law bars production of documents." (quoting BrightEdge Techs., In