Epstein Secrets

736-KAM Document 100 Entered on FLSD Docket 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 St

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

736-KAM Document 100 Entered on FLSD Docket 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 St

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 AND #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTI

and information should be privileged under a common law plea negotiations privilege. In addition, in its initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the P

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant, ROY BLACK, et al., Intervenors. INTERVENORS' MOTION FOR A PR

d on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E

EXHIBIT 1 EFTA00605701 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plantiffs, v. UNITED STATES OF AMERICA, Defendant, ROY BLACK, el at, Intervenors / PROPOSED ORDER OF CONFIDENT

n paragraph 5.a. above, upon prior written consent of the Producing Party's and Intervenors' counsel. If either the Producing Party's counsel or the Intervenors' counsel refuses to give consent, the CDM shall not be disclosed. The Receiving Parties may apply to the Court for an order of relief, on notice to

Document 207 Entered on FLSD Docket 07/08/2013 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT

harm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et at, Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecution agreement which wo

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT

arm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et al., Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecution agreement which wo

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not

ed on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E