Epstein Secrets

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t--closed their inquiry r32] into the matter by noting that the OPR has jurisdiction to investigate allegations of misconduct involving only current Department of Justice attorneys. (See P-O13937;' see also P-0013946). The OPR did not investigate the matter further, and it issued no factual determinations on whether a

" (DE 266 at 11). Specifically, it requests "all documents, correspondence, and other information regarding the potential conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral For internal use only SDNY_GM_00059581 CONFIDENTIAL - PURSUANT TO FED.

ing one case remain protected in a subsequent case[] if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the lite

RANSMISSION OK TX/RX. NO 2683 CONNECTION TEL 6592380 SUBADDRESS CONNECTION ID ST. TIME 09/06 14:62 USAGE T 01'00 PGS. SENT 2 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 Facsimile . FACSIMILE CO

counsel upon lift of stay by 11d' Circuit Box #2 P-008364 Thru P-008382 File folder entitled Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request 6(e) Work Product Deliberative Process Investigative privilege Box #2 P-008383 Thru P

330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the liter

y reference in the substantive charge (Count 2, ¶ 23). Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Eps

2 (11th Cir. 2011), such as if the claim "'rests upon contingent future events that may not occur as anticipated, or indeed may not occur at all,"' Atlanta Gas Light Co. v. FERC, 140 F.3d 1392, 1404 (11th Cir. 1998) (quoting Texas v. United States, 523U.S. 296, 300 (1998)). Indeed, "[t]he ripeness doctrine is designe

y reference in the substantive charge (Count 2, ¶ 23). Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Eps

2 (11th Cir. 2011), such as if the claim "'rests upon contingent future events that may not occur as anticipated, or indeed may not occur at all,"' Atlanta Gas Light Co. v. FERC, 140 F.3d 1392, 1404 (11th Cir. 1998) (quoting Texas v. United States, 523U.S. 296, 300 (1998)). Indeed, "[t]he ripeness doctrine is designe