Epstein Secrets

eir work product waived any claim of privilege. Id. at 1008 (emphasis added). Indeed, Edwards' clients made this argument in their Answer Brief to the Eleventh Circuit! See Excerpt of Ans. Br. in Jane Doe I v. United States, Exhibit at pp. 35-36. Edwards' contrary legal argument now is nothing more than presently

are foreign to the objectives underlying the work-product doctrine."). 9 EFTA00805375 Similarly, in In re Subpoenas Duces Tecum, 738 F.2d 1367 (D.C. Cir. 1984), a law firm performed an investigation of a corporation on the subject of whether improper payments had been made to domestic or foreign off

that " `special circumstances' so require in the 'interests of justice.' "United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the "special circumstances" which may support a stay are limited. The fact that the Defendant may "risk a non-criminal disadvantage by remaining si

ries Inflicted by Epstein. In general, "The compensation and remedy due a civil plaintiff should not be delayed? Gordon v. FDIC, 427 F.2d 578, 560 (D.C. Cir. 1970). Epstein has not discussed Jane Doe's interest in prompt compensation — much less demonstrated that his alleged interests• in a stay somehow

so would violate the Ex Post Facto Clause of the United States Constitution. See U.S. Const. art I, §9, el. 3." The Ex Post Facto analysis made by the Eleventh Circuit in Siegel is applicable to this action. In resolving the issue in favor of the defendant, the Court first considered whether a restitution order is

rts have long consulted official CRS summaries to assess legislative intent, see, e.g., Rettig v. Pension Ben. Guar. Corp., 744 F.2d 133, 145 & n.7 (D.C. Cir. 1984) DIRECTV Inc. v. Cionarella No. Civ.A 03-2384, 2005 WL 1252261 at 7 (D.N.J. May 24, 2005)' Clohessy v. St Francis How. & Healthcare No. 98-C-

criminal trial." Alcatel-Lucent 688 F.3d at 1306 (citing United States'. Johnson 983 F.2d 216, 219 (11th Cir. 1993)). Against this backdrop, where the Eleventh Circuit has determined that the CVRA must be strictly construed, this Court should decline to enlarge these proceedings to allow additional 3 Government E

construed. Center for Biological Diversity I. Hamilton, 453 F.3d 1331, 1334 (11th Cir. 2006), citing Spannaus I. Dept. of Justice 824 F.2d 52, 55 (D.C. Cir. 1987). "[A] waiver of the Government's sovereign immunity will be strictly construed, in terms of its scope, in favor of the sovereign." Lane'. Pe

c. D.E. 310 at 15-16 citin International Broth. of Teamsters I. AFL-CIO, 32 F.R.D. 441, 442 (E.D.Mich. 1963). Since it is a precedential decision of the Eleventh Circuit, McLellan is binding authority. Accordingly, if the Federal Rules of Civil Procedure are applied to petitioners' motion to add Jane Doe No. 3 and J

ly construed. Center for Biological Diversity I. Hamilton 453 F.3d 1331, 1334 (116 Cir. 2006), dtkgi Spannaus I. Dept. of Justice, 824 F.2d 52, 55 (D.C. Cir. 1987). "[A] waiver of the Government's sovereign immunity will be strictly construed, in terms of its scope, in favor of the sovereign." Lane I. P

hat crime victims' rights "shall be asserted in the district court" and referring to a "motion" to protect rights). The federal courts — including the Eleventh Circuit — have been unwilling to stretch the meaning of the phrase "civil action" so far as to cover proceedings ancillary to a criminal case. See, e.g., I

ed by a grand jury investigating possible criminal violations is not part of a 'civil action.'"); Blair-Bey. Quick, 151 F.3d 1036, 1039 (D.C. Cir.) (D.C. Cir. 1998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"

fic. D.E. 310 at 15-16, citing International Broth. of Teamsters'. AFL-CIO, 32 F.R.D. 441, 442 (E.D.Mich. 1963). Since it is a precedent decision of the Eleventh Circuit, McLellan is binding authority. Rule 15 governs petitioners' motion to add two new parties. II. PETITIONERS' MOTION TO AMEND THEIR PETITION SHOULD

construed. Center for Biological Diversity I. Hamilton, 453 F.3d 1331, 1334 (IP" Cir. 2006), citing Spannaus I. Dept. of Justice, 824 F.2d 52, 55 (D.C. Cir. 1987). "[A] waiver of the Government's sovereign immunity will be strictly construed, in terms of its scope, in favor of the sovereign." Lane'. Pe

ed Mr. Epstein's rights and privileges, Mr. Epstein and his counsel intervened to assert their rights, both in the district court, and on appeal to the Eleventh Circuit. See Doe No. 1, supra. That there would be no judgment against Mr. Epstein at the end of this CVRA litigation, however, was understood throughout t

Furthermore, "a district judge must be careful not to exceed his or her constitutional role." United States v. Microsoft Corp., 56 F.3d 1448, 1462 (D.C. Cir. 1995). "When a judge assumes the power to prosecute, the number [of branches] shrinks to two." In re United States, 345 F.3d 450, 454 (7th Cir. 20

tions to the victims — and having induced reliance by the victims — the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in

of the final decision of the Attorney General" of any complaints of violations of the CVRA. Block v. Securities and Exchange Comm In, 50 F.3d I078 (D.C. Cir. 1995), is instructive. In Block, petitioners filed a petition asking the Court to find that the SEC had failed to fulfill its obligation to hold a