Epstein Secrets

uthern District of Florida . However, the NPA does not provide Epstein with any protection from criminal investigation or prosecution other than in the Southern District of Florida. As the court has acknowledged in its orders (e.g., DE 462), complaints in these related matters allege that Epstein both resided in and

to embody a general federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Coro. v. Krueger, 55 F.R.D. 514-15 (N.D. III. 1972X"it is the opinion of this court that (§6103] reflect[s] a valid public policy against disclosure of income tax returns. This

ed to the court, the filing "shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York." (Id. ¶ 10.) The docket sheet in v. Maxwell reveals that such motions were frequently made and routinely granted. As a result, a vast

is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition." Id (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself—similarly weighs in favor of modification. The Protective Order provided tha

eding.' (DE M-1 at 21-22); see Table at P-013227-013247). 4. Request No. 18—Documents Concerning Recusal of the United States Attorney's Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted

ket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication I. Grolier, Inc., that "the literal language o

hern District of Florida. However, the NPA does not provide Epstein with gni protection from criminal investigation or prosecution in other than in the Southern District of Florida. As the court has acknowledged in its orders (e.g., 9 EFTA00222450 Case 9:08-cv-80119-KAM Document 477 Entered on FLSD Docket 02/26/2

to embody a general federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Corp. v. Krueger, 55 F.R.D. 514-15 (N.D. Ill. 1972X"it is the opinion of this court that [§6103] reflect[s] a valid public policy against disclosure of income tax returns. This

ed to the court, the filing "shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York." (Id ¶ 10.) The docket sheet in Giulfre v. Maxwell reveals that such motions were frequently made and routinely granted. As a result,

is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.' Id. (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself-similarly weighs in favor of modification. The Protective Order provided tha

gned to the case for immediate revocation of the Magistrate Judge's Order. THE CHARGES IN THE INDICTMENT On April , 2008, a Grand Jury sitting in the Southern District of Florida returned a twenty-nine-count indictment charging defendant Jeffrey Epstein' with one count of conspiracy to use a means of interstate co

vernment is required to demonstrate that there are grounds for a hearing under the specific provisions of either 3142(f)(1) or (f)(2)." Butler, 165 F.R.D. at 71. "When there exists one or more grounds for holding a hearing under those provisions, the government may proceed on the theory of risk of fli

ing.' (DE 212-1 at 21-22); see Table at P-013227-013247). 4. Request No. 18—Documents Concerning Recusal of the United States Attorney's Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted

07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language o

this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. At

icipation of litigation, and certainly not litigation about the Crime Victims' Rights Act. See, e.g., Southern Union Co. v. Southwest Gas Corp., 205 F.R.D. 542, 549 (D. Ariz. 2002) (documents not protected by work product because not prepared in connection with case at hand). II. Specific Responses to