Epstein Secrets

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

for the filing of our brief while a contested (and, in our view, meritorious) jurisdictional issue is before the Court. In looking more carefully at the CA11 Local Rules, we notice that under the Rule 31-21(d), if the Court were to issue a jurisdictional question, that would stay the time for filing our brief for 30

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

for the filing of our brief while a contested (and, in our view, meritorious) jurisdictional issue is before the Court. In looking more carefully at the CA11 Local Rules, we notice that under the Rule 31-21(d), if the Court were to issue a jurisdictional question, that would stay the time for filing our brief for 30

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

for the filing of our brief while a contested (and, in our view, meritorious) jurisdictional issue is before the Court. In looking more carefully at the CA11 Local Rules, we notice that under the Rule 31-21(d), if the Court were to issue a jurisdictional question, that would stay the time for filing our brief for 30