Epstein Secrets

[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 EFTA00806658

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

Motion at and cases cited therein. The single case cited by plaintiff, Northeastern Florida Chapter of of Gen. Contractors of America v. City of Jacksonville, 896 F.2d 1283 (11th Cir. 1990), did not involve privileged or confidential communications but instead the question whether the plaintiff had demons

E IN OPPOSITION TO INTERVENORS' MOTION TO STAY Intervenors' Motion for Stay Pending Appeal should be granted. Contrary to plaintiffs' contentions, the Eleventh Circuit will have jurisdiction over their appeal from the Court's disclosure order, and the standard for granting a stay pending appeal is amply satisfied i

West Palm Beach FL 33401-5012 Co-Counsel Attorneys for Plaintiff Bradley JaMes Edwards ler Ft. Lauderdale, FL 33301 Lead Counsel Pro Hao Vice Jacksonville , FL 32211 14 Page 14 of 14 EFTA00201258

that " `special circumstances' so require in the 'interests of justice.' "United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the "special circumstances" which may support a stay are limited. The fact that the Defendant may "risk a non-criminal disadvantage by remaining si

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) 680-1234 Paul G. Cassell, Esq. S.J. Quinney College of Law at the University of Utah 332 S. University St. Salt Lake City, UT 84

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

22 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 Paul G. Cassell Email: PRO HAC VICE ATTORNEY TO BE NOTICED represented

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

I I TOTAL P.004 EFTA01711981 (Rev. 05-01-2008) • • UNCLASSIFIED FEDERAL BUREAU OF INVESTIGATION Precedence: ROUTINE Date: 11/24/2010 To: Jacksonville Attn: CFR Miami ofAttn: SA From: Jacksonville Squad 10 Contact: SA Approved By: Drafted By: Case ID #: 802R-JK-52669--11(Closed) 3113-MM-10

ur Office prevails on that issue, the victims would obviously have no claim under the CVRA. The victims would then pursue their appellate rights in the Eleventh Circuit. If, however, the victims prevail on that issue, then your Office would take "no position" on the remedy sought by the victims for the violation of

15-17, and cases cited therein. The single case cited by plaintiff, Northeastern Florida Chapter of Ass'n of Gen. Contractors of America v. City of Jacksonville, 896 F.2d 1283 (11th Cir. 1990), did not involve privileged or confidential communications but instead the question whether the plaintiff had demons

E IN OPPOSITION TO INTERVENORS' MOTION TO STAY Intervenors' Motion for Stay Pending Appeal should be granted. Contrary to plaintiffs' contentions, the Eleventh Circuit will have jurisdiction over their appeal from the Court's disclosure order, and the standard for granting a stay pending appeal is amply satisfied i

that the Motion to Close Trial be denied. DONE AND ORDERED. Fla.Cir.Ct.,1994. John Doc-1 Through John Doe-41. Museum of Sci- ence and History of Jacksonville, Inc. Not Reported in So.2d, 1994 WC. 741009 (Fla.Cir.Ct.), 22 Media L. Rcp. 2497 END OF DOCUMENT Page 7 O 2009 Thomson Reuters/West. No Claim

njoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One District Court within the Eleventh Circuit recently construed "the plain language of § 3509(k)" as "requirlind a stay in a case . . . where . . . a parallel criminal action [is] pending." Do