Epstein Secrets

Document 462 Entered on FLSD Docket 02/04/2010 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-8089

prepared in anticipation of litigation by or for a party or by or for that party's attorney acting for his client, Fed. R. Civ. P. 26(b)(3)'; In re Grand Jury Proceedings, 601 F.2d 162, 171 (5th Cir. 1979), is also not implicated as the subject documents were not created by Epstein's attorneys. Id. Finally, Epstein

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 LIMITED INTERVENTION Jeffrey Epstei

1004 (D.C.Cir. 1999)("[I]t would ordinarily be a violation of Rule 6(e) to disclose that a grand jury is investigating a particular person"); In re Grand Jury Proceedings, 851 F.2d 860, 866-67 (6th Cir. 1988)("[C]onfidential documentary information not otherwise public obtained by the grand jury by coercive means is

oena threatens to compromise `the indispensable secrecy of the grand jury proceedings.'" R. Enterprises , 498 U.S. at 299 (quoting United States v. Johnson , 319 U.S. 503, 513 (1943)). "The need to preserve the secrecy of an ongoing grand jury investigation is of paramount importance." In re Grand Jury

, instead, the contents were voluntarily created by the persons who used them. F15 See, e.g., United States v. Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa

Document 462 Entered on FLSD Docket 02/04/2010 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-8089

prepared in anticipation of litigation by or for a party or by or for that party's attorney acting for his client, Fed. R. Civ. P. 26(b)(3)'; In re Grand Jury Proceedings, 601 F.2d 162, 171 (5th Cir. 1979), is also not implicated as the subject documents were not created by Epstein's attorneys. Id. Finally, Epstein

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

, the contents were voluntarily created by the persons who used them. EFTA00222988 See, e.g., United States' Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa

poena threatens to compromise `the indispensable secrecy of the grand jury proceedings.'" R. Enterprises , 498 U.S. at 299 (quoting United States I Johnson , 319 U.S. 503, 513 (1943)). "The need to preserve the secrecy of an ongoing grand July investigation is of paramount importance." In re Grand Jury

ed, instead, the contents were voluntarily created by the persons who used them. F15 See, e.g., United States' Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa

the indispensable secrecy of the grand jury proceedings." United States v. R. Enterprises, Inc., 498 U.S. 292, 299 (1991) (quoting United States v. Johnson, 319 U.S. 503, 513 (1943)). "The need to preserve the secrecy of an ongoing grand jury investigation is of paramount EFTA00179094 importance." In

lled, instead, the contents were voluntarily created by the persons who used them.15 See, e.g., United States v. Doe, 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings, 393 F.3d 905, 909 (9th Cir. 2004); In re Foster, 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informati