Epstein Secrets

ult in a disposition of the charges in the next several days." [CVRA Petition, DE 1, 13]. Claiming to be wrongfully excluded from those discussions, Jane Doe 1 asserted the violation of her CVRA rights to confer with federal prosecutors; to be treated with fairness; to receive timely notice of relevant cou

ntiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence Jane Doe #1 and Jane Doe &filed by United States of America. (Lee, Dexter) (Entered: 05/30/2011) 06/17/2011 fd Notice of Supplemental Authority ma& Plaintiffs MOTION for Sum

ding risk of irreparable harm because "a court cannot restore confidentiality to documents after they are disclosed"); Gill v. Guyitream Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)("once the documents are turned over to Gill with no clear limitation on what he may do with them, the cat is out

documents waived the privilege. § 90.507, Fla. Stat. (2006). Id. Notably, Edwards is already familiar with this basic principle. Specifically, in Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014), it was Edwards who argued that the United States failed to confer with his clients before en

ilege where that disclosure is inconsistent with maintaining secrecy from the disclosing party's adversary." Tumelaire v. Naples Estates Homeowners Ass'n, Inc., 137 So. 3d 596, 599 (Fla. 2d DCA 2014). In Tumelaire, the plaintiff was accused of conspiring with a mobile home park's owner in litigation agains

perfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airplane travel in support of Jane Doe's Federal Rico claims and punitive damages (911 77-79); Epstein's interview with a New York newspaper reporter (9191 80-81); Epstein's alleged threat

icated documentary evidence may not be relied on or considered in support of a motion for summary judgment. See, e.g., Hollywood Towers Condominium Ass'n, Inc. v. Hampton, 993 So. 2d 174, 175-176 (Fla. 4th DCA 2008) (unauthenticated photocopies of check, letter and bank statement attached to motion for sum

efore the renewed motion should be denied. A. The "Legal Ethics and 1 .sponsibility" Related to the Discovery Edwards Conducted in the El M. and Jane Doe Cases Has Been at Issue Since 2009. 3. The first category of Smith's proposed expert testimony is "legal ethics and responsibility," regarding th

expert should not be allowed to testify concerning questions of law." Edward J. Seibert, Architect & Planner, P.A. v. Bayport Beach & Tennis Club Ass'n, Inc., 573 So. 2d 889, 892 (Fla. 2d DCA 1990) citing Devin v. City of Hollywood, 351 So. 2d 1022, 1022 (Fla. 4th DCA 1976). Thus, Smith's purported opinio

in reliance on Edwards' previous waiver and agreement to produce the same, these e-mails must be deemed not protected by Edwards' clear waiver. See Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014)(held that Epstein's former counsel had waived the work-product privilege with respect to docum

ion of legal services to the client. 2. Those reasonably necessary for the transmission of the communication. Las Olas River House Condo. Ass'n, Inc. v. Lorh, LLC, 181 So. 3d 556, 557-58 (Fla. 4th DCA 2015); § 90.502(1Xc), Fla. Stat. (2017); Witte v. Witte, 126 So. 3d 1076 (Fla. 4th DCA 2012)(sec

d Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and Disclosure of Plea Negotiations (Doc. 162); Notice of Supplemental Authority of the United States Supreme Court (Doc. 163);

ing risk of irreparable harm because "a court cannot restore confidentiality to documents after they are disclosed"); Gill v. Gulfstream Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)("once the documents are turned over to Gill with no clear limitation on what he may do with them, the cat is out

over his strenuous objection, to produce documents given to him by the government during the course of his settlement/plea negotiations with it. See Jane Doe #2 v. Epstein, No. 08-80119-MARRA, Doc. 462. Thus, the plaintiffs' statement that during that civil litigation, "Epstein's counsel produced to the

ng risk of irreparable harm because "a court cannot restore confidentiality to documents after they are disclosed"); Gill v. Gulfstreant Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005X"once the documents are turned over to Gill with no clear limitation on what he may do with them, the cat is out o

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENORS' REPLY TO JANE DOE #1 AND JANE DOES #2'S RESPONSE IN OPPOSITION TO INTERVENORS'

Cir. 2007)(Perlman jurisdiction "does not depend on the validity of the appellant's underlying claims for relief'); Gill v. Gulfstream Park Racing Ass'n, Inc., 399 F.3d 391, 398, 402 (1st Cir. 2005)(asserting jurisdiction under Perlman, but concluding that informant privilege was not available to private