Epstein Secrets

n Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 [email protected] Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe 6 EFTA008

dwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the Eleventh Circuit held that Epstein's former counsel had waived the work- product privilege with respect to documents sought by Edwards' clients, after having voluntar

/2008) 08/08/2008 20 MOTION for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing for Jay C. Howell, Filing Fee $75, Receipt #724591. (cw) (Entered: 08/12/2008) 08/13/2008 21 ENDORSED ORDER granting Jay C. Howell 20 Motion for Limited Appearance

Black. Filing fee $ 455.00 receipt number 113C- 5845273. Within fourteen days of the filing date of a Notice of Appeal, the appellant must complete the Eleventh Circuit Transcript Order Form regardless of whether transcripts are being ordered [Pursuant to FRAP 10(b)]. For information go to our FLSD website under Tr

ldberger Atterb , Goldber er & Weiss, P.A. o- ounse or aint:I oimter- e endant Je E•stein unite ntervenor o- ounse or L.M., E.W. and Jane Doe Jay Howell Jay Howell & Associates L.M., E.W. Limited Intervenor Co-Counsel for and Jane Doe 21 EFTA00794297

ssary . . . to prevent a client from committing a crime."). Following earlier precedent in Parrott v. Wilson, 707 F.2d 1262, 1271 (11th Cir. 1983), the Eleventh Circuit affirmed the part of the district court's order determining that the crime-fraud exception may be applied because an attorney's illegal or fraudulen

Burlington &Rockenbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. Edwards Jay Howell, Esq. Jay Howell & Associates Florida Bar No.: 225657 Attorney E-Mail(s): [email protected] 644 Cesery Blvd. #250 Jacksonville, FL 32211 (904)

pt penalty"); Watkins, 943 F.2d at 1301, 1304 1301; Jaeger v. Massis, No. 00-7390. 2000 U.S. App. LEXIS 27908 (2d Cir. Nov. 3, 2000). Courts within the Eleventh Circuit have not hesitated to impose severe sanctions pursuant to their inherent powers, including cases where a party has acted in bad faith. See, e.g., I

perpetrator. We will help you to do this in any way possible to ensure that true Justice is served in this case. Sincerely, Brad Edwards, Esquire Jay Howell, Esquire 2025 HARRISON STREHT,SUITI 202, HOLLYWOOD, FLORIDA 33020 OFFICE, 954-414-503S/S05-935-2011 FAX, 954-924-15SO/S05-SS5-4227 BRORADEDWARDSL

ng cases and concluding "the relevant case law unanimously agrees that the CVRA extends rights to crime victims before charges have been filed"). As the Eleventh Circuit has explained, "Congress is presumed to know the federal courts' interpretation of a statute that it intends to amend," and "[w]here there is no in

s Avenue Suite 2 Fort Lauderdale, FL 33301 954-524-2820 Fax: 954-524-2822 Email: bradepathtojustice coin LEAD ATTORNEY ATTORNEY TO BE NOTICED Jay C. Howell Jay Howell &Associates PA 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Email: [email protected] PRO HAC VICE ATTORNEY TO BE NOTICED

The CVRA at §3771(e) defines a "crime victim" as " a person directly and proximately harmed as a result of the commission of a Federal offense." In the Eleventh Circuit, a two-part test is employed to determine whether an individual qualifies as a crime victim under this statute: First, the court must identify the