Epstein Secrets

s reasoning applies even when the documents or information are classified as "personal papers" rather than business documents. See United States v. Feldman , 83 F.3d 9, 14 (1st Cir. 1996) (defendant's letters of apology not protected because voluntarily prepared); In re Grand Jury Subpoena Duces Tecum ,

would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United

d States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 21 United States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 17 United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 13, 26, 29, 30 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 16, 17 Unit

t in this District as barred by what they claimed was an earlier "plea agreement" in the Eastern District, and the court denied the motion. Id. The Second Circuit, in affirming the denial, stated simply that "[a] plea agreement binds only the office of the United States Attorney for the district in which the p

is reasoning applies even when the documents or information are classified as "personal papers" rather than business documents. See United States I Feldman , 83 F.3d 9, 14 (1st Cir. 1996) (defendant's letters of apology not protected because voluntarily prepared); In re Grand Jury Subpoena Duces Tecum ,

would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United

d in part by the Non-Prosecution Agreement — such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996). 4 EFTA000

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use.' For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reaso

d in part by the Non-Prosecution Agreement — such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996). 4 EFTA000

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use.' For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reaso

d States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 21 United States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 17 United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 13, 26, 29, 30 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 16, 17 Unit

t in this District as barred by what they claimed was an earlier "plea agreement" in the Eastern District, and the court denied the motion. Id. The Second Circuit, in affirming the denial, stated simply that "[I] plea agreement binds only the office of the United States Attorney for the district in which the p

s reasoning applies even when the documents or information are classified as "personal papers" rather than business documents. See United States v. Feldman, 83 F.3d 9, 14 (1st Cir. 1996) (defendant's letters of apology not protected because voluntarily prepared); In re Grand Jury Subpoena Duces Tecutn,

ould effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EF

pp. 197 (D.S.C. 1984), of d, 749 F.2d 33 (4'h Cir. 1984) 6 United States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 3, 6 United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 5, 6, 10, 17 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 3, 4, 6 Unite

an, 939 F.3d 182 (2d Cir. 2019), for the proposition that "plea agreements differ from commercial contracts" (Opp. 18), the "differ[ence]" to which the Second Circuit was referring was that in construing a plea agreement, 3 Accuser-2 is identified in the Indictment as Minor Victim-2. 5 EFTA00028888 --- PAGE BR

ns omitted), and the government is held "responsible for imprecisions or ambiguities in the agreement." United States v. Padilla, 186 F.3d 136, 142 (2d Cir. 1999). While the government argues that Annabi relieves it of this responsibility where the "imprecisions or ambiguities" relate to the geographic