Epstein Secrets

n attorney's work is for his client's advantage, opposing counsel or adverse parties should not gain the use of that work through discovery." In re John Doe, 662 F.2d 1073, 1081 (4i° Cir. 1981). As is required by the Sixth Amendment, a criminal defense attorney must exert his best efforts to convince the

ocket 09'27:2011 Page 12 of 12 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954)

ichard C. W. Hall, M.D., P.A. Taxpayer ID #: Drs. Hall's time: Jane Doe #2 Records reviewed: Correspondence of Gilbert Kliman, MD Transcript of John Doe #2 v. Rabbi Yehuda Kolko et al Palm Beach Police Department Probable Cause Affidavit Billing records of Gilbert Kliman, MD 08/07/09 Review, annot

rst Amended Complaint Civil RICO Case Statement Plaintiff's Answers to Defendant's First Interrogatories Correspondence of United States Attorney, Southern District of Florida Plaintiff's Supplemental Response to Defendant's First Request to Produce Number 7 Defendant's Reply to Plaintiff's Response in Oppositi

Review, annotate and highlight records min Total hours 50 min Rate: $400/hour Jane Doe #3 Records reviewed: Correspondence of Transcript of John Doe #2 v. Rabbi Yehuda Kolko et al Palm Beach Police Department Probable Cause Affidavit Billing records ofinsin 08/07/09 Review, annotate and highli

rst Amended Complaint Civil RICO Case Statement Plaintiff's Answers to Defendant's First Interrogatories Correspondence of United States Attorney, Southern District of Florida Plaintiff's Supplemental Response to Defendant's First Request to Produce Number 7 Defendant's Reply to Plaintiff's Response in Oppositi

n attorney's work is for his client's advantage, opposing counsel or adverse parties should not gain the use of that work through discovery." In re John Doe, 662 F.2d 1073, 1081 (4i° Cir. 1981). As is required by the Sixth Amendment, a criminal defense attorney must exert his best efforts to convince the

ocket 09'27:2011 Page 12 of 12 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954)

ichard C. W. Hall, M.D., P.A. Taxpayer ID #: Drs. Hall's time: Jane Doe #2 Records reviewed: Correspondence of Gilbert Kliman, MD Transcript of John Doe #2 v. Rabbi Ychuda Kolko et al Palm Beach Police Department Probable Cause Affidavit Billing records of Gilbert Kliman, MD 08/07/09 Review, annot

rst Amended Complaint Civil RICO Case Statement Plaintiff's Answers to Defendant's First Interrogatories Correspondence of United States Attorney, Southern District of Florida Plaintiff's Supplemental Response to Defendant's First Request to Produce Number 7 Defendant's Reply to Plaintiff's Response in Oppositi

ie the policy of grand jury secrecy are implicated to a much lesser extent when the disclosure merely involves Government attorneys." United States. John Doe, Inc. I, 481 U.S. 102, 112 (1987). Nothing in Douglas Oil, however, requires a district court to pretend that there are no differences between gov

requested."). CONCURRENCE REGARDING THE FILING OF THIS MOTION 26. The filing of this application has been approved by the U.S. Attorney for the Southern District of Florida and the Chief of the Criminal Division of the U.S. Attorney's Office for the Southern District of Florida. 27. The Criminal Chief also

LLAND & KNIGHT Attorneys for Intervenors Julie Brown and Miami Herald Media Company BY: CHRISTINE N. WALZ KRIEGER KIM & LEWIN, LLP Attorneys for John Doe Defendants BY: PAUL M. KRIEGER SOUTHERN DISTRICT REPORTERS, P.C.•• (212) 805-0300 EFTA00082164 L1JMGIUC 1 2 3 4 5 6 7 9 10 11 12 13

ourt's mandate is to undertake a particularized review of each document and to: (1) evaluate the weight of the presumption of public access to the SOUTHERN DISTRICT REPORTERS, P.C.•• (212) 805-0300 EFTA00082165 L1JMGIUC 1 materials; (2) identify and evaluate the weight of any 2 countervailing interests; a

a sexual activity for which a person can be charged with an offense? A Yes. Q How many telephone calls have you been able to document between John Doe Number 14 and A We have approximately 70 phone calls between and Jane Doe Number 14. Q And what about with A Approximately seven. Q And bec

of May, 2007. Dated at West Palm Beach, Florida this 28th day of May, 2007. Court Reporter EFTA00085489 1 1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH 3 4 5 6 7 8 IN RE: OPERATION LEAP YEAR 9 10 11 12 / Grand Jury #07-103 (TUES-WPB) West Palm Beach, Florid