Epstein Secrets

201 F.R.D. 272 (D.D.C. 2001); See also, Salter v. Upjohn Co., 593 F.2d 649, 651 (5th Circ. 1979)(It is very u

x [email protected] Co-counsel/or Plaintiff Jane Doe Isidro M. Qarcia, Esq. Garcia Law Firm, P.A. 2

). An order completely prohibiting a deposition from going forward, however, is rare, and only resorted to in extraordinary circumstances. Salter v. Upjohn Co., 593 F.2d 649, 651 (5 Cir. 1979)(noting that it is very unusual for trial court to th prohibit the taking of a deposition altogether, and absent ext

T OF FLORIDA CASE NO: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN,

_00059577 CONFIDENTIAL - PURSUANT TO FED. R.CCIN(F IDENTIAL DB-SONY-0022401 EFTA 00170127 EFTA01296795 Page 71 2015 U.S. Dist. LEXIS 87203, * Upjohn Co. v. United States, 449 U.S. 383, 402, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981)); see also In re Doe, 662 F.2d 1073, 1080 (4th Cir. 1981) (even under c

00059568 CONFIDENTIAL - PURSUANT TO FED. R.WANI(E IDENTIAL DB-SDNY-0022392 EFTA_00I7Ol 18 EFTA01296786 Page 62 2015 U.S. Dist. LEXIS 87203, * JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. CASE NO.:08-CV-80736-KAM UNITED STATES DISTRICT COURT FOR THE SOUTHERN DIS

"a far stronger showing of necessity and unavailability by other means" than is needed to justify discovery of fact-based work product. Id. (quoting Upjohn Co. v. United States, 14 EFTA01657765 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 15 of 51 449 U.S. 383, 402 (1981));

M Document 330 Entered on FLSD Docket 07/06/2015 Page 1 of 51 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. OPINION AND ORDER This cause is before the Court on various discovery re

enabling the client to conform his conduct to the dictates of the law and to present le- gitimate claims and dt enses f if litigation ensues. See Upjohn Co. I United States, O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. https://web2.westlaw.com/print/printstream.aspx?vi-2.0&mt=EleventhCircuit

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

/2013 Page 5 of 12 connection with the specific representation." Id. at 619. The Seventh Circuit found this letter brought the case squarely within Upjohn Co. v. United States 449 U.S. 383 (1981), "which explained that factual investigations performed by attorneys as attorneys fall comfortably within the

given to attorneys for the victims about the non-prosecution agreement, including information about what could be told to Brad Edwards (counsel for Jane Doe #1 and Jane Doe #2) about the non-prosecution agreement; f) All correspondence, documents, and other information regarding Epstein's awareness that