Epstein Secrets

en if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00100343 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 8 of 20 see

en if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally

e issues for judicial decision, and (2) the hardship to the panics of withholding court consideration.- ' (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136. 149 (1967))); 6 EFTA00205159 see also, e.g., Association For Children for Enforcement of Support, Inc. v. Conger. 899

en if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00208800 see also, e.g., Association For Children for Enforcement of Support, Inc. v. Conger, 899

en if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs... Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00209774 see also, e.g., Association For Children for Enforcement of Support, Inc.t Conger, 899 F.2

en if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00795156 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 8 of 20 see

en if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00799480 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 8 of 20 see

RMB Document 6 Filed 07/11/19 Page 7 of 16 that was unsealed and became public in July 2013, specifically noted that "a number of districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Flori

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00076105 Case 9:08-c 3fi-19464-0CtailltdReta 2ffeeurEenteea o if iractsarmatket GRAB/80131.5Page 8

RMB Document 6 Filed 07/11/19 Page 7 of 16 that was unsealed and became public in July 2013, specifically noted that "a number of districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Flori

sues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00095908 Case 9:08-c 3fi-19464-0CtailltdReta 2ffeeurEenteea o if iractsarmatket GRAB/80131.5Page 8

) and may be viewed as a waiver of the privilege or protection." 799 So. 2d at 340. The TIG court further observed that Local Rule 26.1(G)(3)(b), of the Southern District of Florida, spelled out the requirements for a valid privilege log, hi. at 341: Where a claim of privilege is asserted in objecting to any interro

ls, do not permit Epstein or the Court to begin to evaluate the applicability of the privileges claimed by Epstein. TIG, 799 So. 2d at 341 (quoting Abbott Labs, 2000 U.S. Dist. LEXIS 20834, at *13)("[D]escriptions such as 'letter re claim', 'analysis of claim' or 'report in anticipation of litigation'. . .