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 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Bl

federal courts to `continue the evolutionary development of [evidentiary] privileges.' Adkins g Christie, 488 F.3d 1324, 1328 (11th 2007), quoting Trammel I United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 41001s that the accused is encouraged candidly to discuss his or her situat

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 tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Bl

federal courts to `continue the evolutionary development of [evidentiary] privileges.' Adkins g Christie, 488 F.3d 1324, 1328 (11th 2007), quoting Trammel I United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 41001s that the accused is encouraged candidly to discuss his or her situat

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

ivilege," and to provide the court "with the flexibility to develop rules of privilege on a case-by-case basis, and leave the door open to change." Trammel, 445 U.S. at 47. Whatever the circumstances may be in other cases in the future, the facts of this case, when "interpreted in the light of reason an

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

luding relevant evidence has a public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth." Trammel v. United States , 445 U.S. 40, 50 (1980) (internal quotation omitted). See also In re Grand Jury Subpoena , 274 F.3d 563, 571 (1st Cir. 2001) ("Be

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. (FN1) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in cantera submission of facts s

sons in special relationships from disclosure. By their very nature they impede the search for the truth and arc therefore generally disfavored. Trammel v. United States, 445 U.S. 40, 50, 100 S.Ct. 906, 912, 63 L.Ed.2d 186 (1980); Herbert v. Lando, 441 U.S. 153, 99 S.Ct. 1635, 60 L.Ed.2d 115 (1979)

hat certain officers of the Buffalo Police Department violated federal criminal civil tights laws during and after the arrest of Mr. Aiken and Mr. Johnson. [FN I) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in COMM submission of facts sur

sons in special relationships from disclosure. By their very nature they impede the search for the truth and are therefore generally disfavored. Trammel v. Unked States, 445 U.S. 40, 50. 100 S.Ct. 906, 912, 63 L.Ed.2d 186 (1980); Herbert v, Lando, 441 U.S. 153. 99 S.Ct. 1635, 60 L.Ed.2d 115 (1979);

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. (F141) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in camera submission of facts s

sons in special relationships from disclosure. By their very nature they impede the search for the truth and are therefore generally disfavored. Trammel v. United States, 445 U.S. 40, 50. 100 S.Ct. 906, 912, 63 L.Ed.2d 186 (1980); Herbert v. Lando, 441 U.S. 153. 99 S.Ct. 1635. 60 L.Ed.2d 115 (1979)

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. IFNI] FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in camera submission of facts su

sons in special relationships from disclosure. By their very nature they impede the search for the truth and arc therefore generally disfavored. Trammel v. United States, 445 U.S. 40, 50, 100 S.Ct. 906, 912, 63 L.Ed.2d 186 (1980); Herbert v. Lando, 441 U.S. 153, 99 S.Ct. 1635, 60 L.Ed.2d 115 (1979)