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constitutional authority to address criminal contempt, absent statutory authority.") citing In re Hipp and Walton v Countrywide Homes Loans. While the Eleventh Circuit has recently reviewed a bankruptcy court's ruling imposing both civil and punitive sanctions in In re McLean, 794 F. 3d 1313 (11th Cir. 2015), it di
e any detail—much less an unequivocal command—as to what Fowler White is to do with the disc at issue. INTRODUCTION AND BACKGROUND Although L.M., E.W., and Jane Doe have sought to join in the motion for order to show cause, they have not been granted leave to intervene in this action. The motion to
ssary . . . to prevent a client from committing a crime."). Following earlier precedent in Parrott v. Wilson, 707 F.2d 1262, 1271 (11th Cir. 1983), the Eleventh Circuit affirmed the part of the district court's order determining that the crime-fraud exception may be applied because an attorney's illegal or fraudulen
ls are attorney-client privileged communications between Edwards (or any other co-counsel) and Edwards' and Mr. Cassell's three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents are e- mails among attorneys and staff within RRA, with Mr. Cassell, and with media sources and d
pt penalty"); Watkins, 943 F.2d at 1301, 1304 1301; Jaeger v. Massis, No. 00-7390. 2000 U.S. App. LEXIS 27908 (2d Cir. Nov. 3, 2000). Courts within the Eleventh Circuit have not hesitated to impose severe sanctions pursuant to their inherent powers, including cases where a party has acted in bad faith. See, e.g., I
to have dealt with this issue head on because of the apparent implications of same." Hearing Trans. at 60:20-61:14. 33. Counsel for victims L.M., E.W., and Jane Doe also asked Judge Hafele to order Fowler White to explain who they had distributed the confidential materials to. Judge Hafele indicat
", to the extent discernable, every case brought under §2422(b) in this district includes use of the intemet. There are only four reported cases in the Eleventh Circuit involving use of the phones only: three of them concern telephone calls to travel agencies advertising overseas underage sex touriand involved expli
z] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein's bedroom getting sexually abused, correct? 26 Of course, in a proceeding such as this one, the victims are entitled to an i
whether such a claim exists." Stoner v. Walsh, 772 F. Supp. In Bonner v. City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11i° Cir. 1981) (en bane), the Eleventh Circuit adopted as binding precedent the decisions of the Fifth Circuit rendered prior to October 1, 1981. 3 EFTA_R1_00012688 EFTA01734468 Case 9:08-cv
follows: The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Offic
whether such a claim exists." Stoner v. Walsh, 772 F. Supp. In Bonner v. City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11i° Cir. 1981) (en bane), the Eleventh Circuit adopted as binding precedent the decisions of the Fifth Circuit rendered prior to October 1, 1981. 3 EFTA_R1_02213296 EFTA02725753 Case 9:08-cv
follows: The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Offic
Entities connected to both the Eleventh Circuit and E.W.

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSONJack Goldberger
PERSON
United States
LOCATION
Scarlett Johansson
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONScott Rothstein
PERSONMaria Farmer
PERSONLeon Black
PERSON
Alan Dershowitz
PERSONRobert D. Critton
PERSON
Alexander Acosta
PERSONJack Scarola
PERSON
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSONFBI
ORGANIZATION