Epstein Secrets

tive waiver of work-product protection where materials were disclosed to the government, despite confidentiality agreement); McKesson HBOC, Inc. v. Superior Court, 9 Cal. Rptr. 3d 812, 819 (Cal. Ct. App. 2004) (rejecting selective waiver of attorney-client privilege and work-product protection where materials

eir work product waived any claim of privilege. Id. at 1008 (emphasis added). Indeed, Edwards' clients made this argument in their Answer Brief to the Eleventh Circuit! See Excerpt of Ans. Br. in Jane Doe I v. United States, Exhibit at pp. 35-36. Edwards' contrary legal argument now is nothing more than presently

ute is to impose punishment that is criminal in nature, the ex post facto clause is implicated." See generally, Roman Catholic Bishop of Oakland v. Superior Court, 28 Cal.Rptr.3d 355, at 360, citing Kansas v. Hendricks 521 U.S. 346, 360-61 (1997). The effect of applying the 2006 version of §2255 would be to t

Defendant's position that application of the current version of 18 U.S.C. §2255 would be in clear violation of the Ex Post Facto Clause. In Siegel, the Eleventh Circuit found that the Ex Post Facto Clause barred application of the EFTA00201264 Case 9:08-cv-80811-KAM Document 78 Entered on FLSD Docket 05/08/2009

ute is to impose punishment that is criminal in nature, the ex post facto clause is implicated." See generally, Roman Catholic Bishop of Oakland v. Superior Court, 28 Cal.Rptr.3d 355, at 360, citing Kansas v. Hendricks, 521 U.S. 346, 360.61 (1997). The effect of applying the 2006 version of §2255 would be to t

so would violate the Ex Post Facto Clause of the United States Constitution. See U.S. Const. art I, §9, el. 3." The Ex Post Facto analysis made by the Eleventh Circuit in Siegel is applicable to this action. In resolving the issue in favor of the defendant, the Court first considered whether a restitution order is

nts and transcripts here could easily kill many re utations. This overriding interest is, I believe, of a higher value under [ Puss-Enterprise Co. I Superior Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Steing

n related to grand jury proceedings as "matters occurring before the grand jury." fiThis opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner I City of Prichard , 661 F.2d 1206, 1209 (11th Cir. 1981) ( en bane). L4The NPA also contains such references. EFTA00208551

ts and transcripts here could easily kill many reputations. This overriding interest is, I believe, of a higher value under [ Puss-Enterprise Co. v. Superior Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Steing

n related to grand jury proceedings as "matters occurring before the grand jury." fiThis opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Priclund, 661 F.2d 1206, 1209 (11th Cir. 1981) ( en banc). Line NPA also contains such references. EFTA00208558

ts and transcripts here could easily kill many re utations. This overriding interest is, I believe, of a higher value under [ Press-Enterprise Co. I Superior Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Steing

n related to grand jury proceedings as "matters occurring before the grand jury." fiThis opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner. City of Prichatd, 661 F.2d 1206, 1209 (11th Cir. 1981) ( en banc). EFTA00212565

sealed. the settlement might not have been reached. Appellant Decker is the plaintiff in the case of Decker v. American Motors Corp., No. 474278, Superior Court of San Diego County, State of California (hereinafter the "California suit"). The California suit is also a wrongful death claim, involving a 1977

was a part of the coon's participation in that settlement." (ROA at 81). 2 In Bonner v. City of Prichard. 661 F.2d 1206 (11th Cir.1981) (en bane). the Eleventh Circuit adopted as precedent the decisions of the Fifth Circuit rendered prior to October 1, 1981. 3 Quite the contrary would appear to be true. If formal

ray of mandatory closure rules ... proves too much, and runs contrary to the very foundation of the right of access...." Globe Newspa- per Company" Superior Court, 102 S.Ct. 2613, 2622 (1982). Accordingly, having considered the briefs and argu- ments of counsel for the reasons set forth in this opinion, it i

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

ts and transcripts here could easily kill many reputations. This overriding interest is, I believe, of a higher value under [Ness-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Swinger

etition, held on July 11, 2008. The Court discussed a need to "hav[e] a complete record, and this is going to be an issue that's ... going to go to the Eleventh Circuit, (so it] may be better to have a complete record as to what your position is and the government's is as to what actions were taken." Tr. at 25-26. C

nts and transcripts here could easily kill many reputations. This overriding interest is, I believe, of a higher value under [Ness-Enterprise Co.'. Superior Court, 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Swinger

etition, held on July 11, 2008. The Court discussed a need to "hav[e] a complete record, and this is going to be an issue that's ... going to go to the Eleventh Circuit, (so it] may be better to have a complete record as to what your position is and the government's is as to what actions were taken." Tr. at 25-26. C