Epstein Secrets

dwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the Eleventh Circuit held that Epstein's former counsel had waived the work- product privilege with respect to documents sought by Edwards' clients, after having voluntar

to class counsel during settlement negotiated waived work product when tape sought by government as part of criminal 3 EFTA00806655 case); In re Sealed Case, 676 F.2d 793, 824-25 (D.C. Cir. 1982) (production of documents during settlement discussions with the SEC waived work product protection as to gra

E IN OPPOSITION TO INTERVENORS' MOTION TO STAY Intervenors' Motion for Stay Pending Appeal should be granted. Contrary to plaintiffs' contentions, the Eleventh Circuit will have jurisdiction over their appeal from the Court's disclosure order, and the standard for granting a stay pending appeal is amply satisfied i

n formally recognized is not a bar to Perlman jurisdiction. The controlling factor is whether the appellants assert a right or privilege, see In re Sealed Case, F.3d 2013 WL 2120157 at *4 March 5, 2013)("The Perlman doctrine permits appeals from some decisions that are not final but allow the disclosure

r victims in this case. 6 EFTA00208761 Case 9:08-cv-80736-KAM Document 218 Entered on FLSD Docket 08/01/2013 Page 7 of 11 of first impression in the Eleventh Circuit and require extensive briefing. Accordingly, the victims request (at least) the standard twenty pages to present their motion to compe1.5 The victim

lating to alleged indiscretion within the department). • Any attorney-client privilege is subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985). The victims intend to argue that the crime-fraud-misconduct exception applies on the facts of this case.' • A

tters occurring before the grand jury, but their interests, as well as what they would bring to the Court on the issue, vary substantially. Although the Eleventh Circuit has said that "Where is a presumption of adequate representation where an existing party seeks the same objectives as 5 EFTA00209268 the interve

, e.g., Hodge v. F.B.I., 703 F.3d 575, 580 (D.C.Cir. 2013)(identities of individuals who received grand jury subpoenas fell within Rule 6(e)); In re Sealed Case, 192 7 EFTA00209270 F.3d 995, 1004 (D.C.Cir. 1999)("[I]t would ordinarily be a violation of Rule 6(e) to disclose that a grand jury is investiga

E IN OPPOSITION TO INTERVENORS' MOTION TO STAY Intervenors' Motion for Stay Pending Appeal should be granted. Contrary to plaintiffs' contentions, the Eleventh Circuit will have jurisdiction over their appeal from the Court's disclosure order, and the standard for granting a stay pending appeal is amply satisfied i

n formally recognized is not a bar to Perlman jurisdiction. The controlling factor is whether the appellants assert a right or privilege, see In re Sealed Case, F.3d , 2013 WL 2120157 at *4 6 EFTA00583785 (D.C.Cir. March 5, 2013)("The Perlman doctrine permits appeals from some decisions that are not f

ts production in this case. With regard to item (1) — correspondence with Epstein, the Government withheld the correspondence pending a ruling from the Eleventh Circuit on Epstein's motion to stay production of these materials. With regard to the other items, the Government produced 14,825 pages of documents to the

). Communications Facilitating Crime-Fraud-Misconduct Not Covered - Any privilege would be subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985) (applying exception to attorney-client privilege); Cox v. Administrator U.S. Steel & Carnie, 17 F.3d 1386, 1422