Epstein Secrets

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. UNOPPOSED MOTION OF PROPOSED INTERVENORS FOR A ONE-WEEK EXTENSI

Accordingly, we respectfully request an extension of time until Friday, September 2, 2011, to file the supplemental briefing of proposed intervenors Black, Weinberg & Lefkowitz, and to file a motion for limited intervention to assert rights under Rules of Evidence 408 and 410. We certify that on August 22, 2011, the forego

Document 169 Entered on FLSD Docket 04/23/2012 Page 1 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, 1. Plaintiffs, UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENOR

which he adhered and has fully performed. These are the unique facts that underlie the claims of work-product and common-law privilege of attorneys Black, Weinberg & Lefkowitz as it pertains to the plea discussions in this case. For good reason, the Rules require that the Court consider each claim of privilege on a case-by

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant. UNOPPOSED MOTION OF PROPOSED INTERVENORS FOR A ONE-WEEK EXTENSI

Accordingly, we respectfully request an extension of time until Friday, September 2, 2011, to file the supplemental briefing of proposed intervenors Black, Weinberg & Lefkowitz, and to file a motion for limited intervention to assert rights under Rules of Evidence 408 and 410. We certify that on August 22, 2011, the forego