Epstein Secrets

civil lawsuit, Jane Doe # 2 v. Jeffrey Epstein, Case No. 08- 80893-CIV-MARRA. By order entered January 5, 2011 in that proceeding, Magistrate Judge Johnson expressly rejected Epstein's request for the "Court to find the subject correspondence privileged and on that basis prohibit plaintiff? counsel from

rnational, Inc., 450 F.3d 1179 (10'" Cir. 2006); Westinghouse Electric Corp. v Republic of Philippines, 951 F.2d 1414, 1428-31 (3d Cir. 1991); In re Subpoena Duces Tecum, 738 F.2d 1367, 1372 (D.C. Cir. 1984). Finally, the court rejects the intervenors' invitation to craft a new federal common law privilege governin

Document 225 Entered on FLSD Docket 08/16/2013 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS THAT ARE NOT PRIVILEGED EFT

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not

civil lawsuit, Jane Doe # 2 v. Jeffrey Epstein, Case No. 08- 80893-CIV-MARRA. By order entered January 5, 2011 in that proceeding, Magistrate Judge Johnson expressly rejected Epstein's request for the "Court to find the subject correspondence privileged and on that basis prohibit plaintiffs' counsel fro

rnational, Inc., 450 F.3d 1179 (10ih Cir. 2006); Westinghouse Electric Corp. v Republic of Philippines, 951 F.2d 1414, 1428-31 (3d Cir. 1991); In re Subpoena Duces Tecum, 738 F.2d 1367, 1372 (D.C. Cir. 1984). Finally, the court rejects the intervenors' invitation to craft a new federal common law privilege governin

tements elicited from another. . . . It is extortion of information from the accused himself that offends our sense of justice. Id. at 328 (quoting Johnson I United States , 228 U.S. 457, 458 (1913)) (emphasis in original). Thus, the Court found that the accountant did not have a Fifth Amendment privile

ited 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 , 1 F.3d 87, 90 (2d Cir. 1993) (defendant's personal calendar not protected because voluntarily prepared); Barrett I Acevedo , 169 F.3d 1155, 1168 (

Market Land Value: $1626790 Market Improvement $17653363 Value: Total Market Value: $19280153 2: Deed Record for EAGLE County Buyer Information JOHNSON. ELIZABETH ROSS EPSTEIN. JEFFREY E 457 MADISON AVE NEW YORK, NY 10022-6843 NEW YORK Name: Name: Address: County/FIPS: Name: Address: County

documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure

except in the most extraordinary circumstances." Forde, 740 F.Supp.2d at 412 (citing Gaudin, 515 U.S. at 522-23). As the Supreme Court explained in Johnson v. United States, 520 U.S. 461 (1997), "there is no doubt that materiality is an element of perjury under § 1623," and its precedent "therefore dict

the proper remedy.38 Indeed, none of the Second Circuit cases applying Martindell contemplate suppression as a remedy. See, e.g., In re Grand Jut), Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d at 1224 (remanding for findings "on whether the protective order was improvidently granted or whether the government

for Protective Order. Signed by Magistrate Judge Linnea R. Johnson on 1/27/2010. (sa) (Entered: 01/27/2010) 455 ORDER Affirming Magistrate Judge Johnson's Discovery Order; denying 327 Appeal of Magistrate Judge Decision to District Court filed by Jane Doe. Signed by Judge Kenneth A. Marra on 1/27/20

Exhibit A)(Horowitz, Adam) (Entered: 12/21/2009) 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachm

ument 225-1 Entered on FLSD Docket 08/16/2013 Page 26 of 64 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Plaintiffs UNITED STATES, Defendants JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not

: Jurisdiction: 07/21/2008 Judge Kenneth A Marra Magistrate Judge Linnea Personal Injury (360) Diversity 9:08-cv-80119-KAM None Diversity R Johnson Cma Plaintiff Jeffrey Epstein Defendant Class Code: CLOSED Closed: Yes Statute: 28:1332 Jury Demand: Plaintiff Demand Amount: $0 NOS Descri

orowitz, Adam) (Entered: 12/21/2009) 12/29/2009 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachme