Epstein Secrets

400 West Palm Beach, FL 33401 Telephone: Facsimile: I 6 EFTA00086382 GOVERNMENT EXHIBIT Case No. 08-80736-CV-MARRA P-001713 EFTA00086383 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FCII 07-103 (WPB) IN RE: GRAND JURY PROCEEDINGS Party Filing Matter Under Seal ORDER RE: SEALED FILING Name: UNI

strict of Florida, and it appearing to the satisfaction of the Court: 1. That has been called to testify and to provide other information before the United States District Court for the Southern District of Florida, including a Grand Jury impanelled therein; and 2. That in the judgment of the said United States Attorney,

"work-product doctrine is distinct from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply

ein's Fifth Amendment concerns are not unwarranted. In a federal companion case, Jane Doe No. 2 v. Epstein, Case No. 08- CIV-80119 MARRA/JOHNSON, in the United States District Court for the Southern District of Florida, United States Magistrate Judge Linnea R. Johnson found, "pin 2008, Epstein entered into a Non-Prosecution Agr

ation need not be admissible at trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Id.; see also Hickman 12 EFTA00723247 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 13 of 22 v. Taylor, 329 U.S. 495, 507-508 (1947); Far

296697325-L_801_0-1 6/10/2009 EFTA00175264 Case'9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/2009 RIPON 1 105 0.1 ELECTRONIC UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Mar. 24, 2009 STEVEN m.LARim0RE CLERK N.S. DIST. CT. s.o. Or FLA.• MIAMI 09-80469-Civ-RYSKAMPNITUNAC JANE DOE II

o.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing., Hickman v. Taylor 329 U.S. 495, 501, 507 (1947). 15. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes, Inc. v. Brand

Donald FELL, Defendant-Appellant. Docket No. 06-2882-cr. Argued: June 27, 2007. Decided: June 27, 2008. Background: Defendant was convicted in the United States District Court for the Dis- trict of Vermont, William K. Sessions III, Chief Judge, of murder in course of car- jacking and kidnapping, and he was sen- tenced to d

notes had in the first place before reaching the `waiver' issue. Accordingly, and because I do not believe that the ork-product *243 doctrine of Hickman Taylor, 329 U.S. 495, 67 S.Ct. 385, 91 L. . 451 (1947), can be extended wholesale from its historic role as a limita- tion on the nonevidentiary m

iled motion to intervene, for purposes of filing motion to unseal documents that were placed under seal and included in protective order. Holdings: The United States District Court for the Southern District of New York, Sweet, J., held that: m news media and journalist could intervene in action; 121 public did not have right

to a morbid craving for that which is sensational and impure."). IsiPretrial discovery is intended to aid the parties in their search for truth. See Hickman v. Taylor, 329 U.S. 495, 501, 67 S.Ct. 385, 91 L.Ed. 451 (1947) (celebrating that "[t]he deposition-discovery regime set out by the Federal Rules o