4
Shared Docs
4
Same-Page
4 / 4
Mentions
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'
lege is a non- litigant, Wilson, 621 F.3d at 643.2 The grand jury limitation for which plaintiffs argue simply does not exist. 2 Plaintiffs rely on the Tenth Circuit's lack of awareness that Perlman had ever been applied outside the grand jury context, Opposition at 6, but a quick Westlaw search demonstrates that
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 #21 Epstein, No. 08-80119-MARRA, Doc. 462. Thus, the plaintiffs' statement that during that civil litigation, "Epstein's counsel produced to the vic
ea negotiations is protected by the work product privilege, it stopped short of advocating the recognition of a settlement/plea 'Plaintiffs rely on the Tenth Circuit's lack of awareness that Perlman had ever been applied outside the grand jury context, Motion at 16-17, but a quick Westlaw search demonstrates that
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 #21 Epstein, No. 08-80119-MARRA, Doc. 462. Thus, the plaintiffs' statement that during that civil litigation, "Epstein's counsel produced to the vic
ea negotiations is protected by the work product privilege, it stopped short of advocating the recognition of a settlement/plea 'Plaintiffs rely on the Tenth Circuit's lack of awareness that Perlman had ever been applied outside the grand jury context, Motion at 16-17, but a quick Westlaw search demonstrates that
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'
ort of Motion to Intervene (Doc. 100). The government's institutional interests differ significantly from those of attorneys who Plaintiffs rely on the Tenth Circuit's lack of awareness that Perlman had ever been applied outside the grand jury context, Opposition at 6, but a quick Westlaw search demonstrates that
Entities connected to both Jane Doe and the Tenth Circuit's

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATIONRoy Black
PERSONMartin Weinberg
PERSONthe Eleventh Circuit
ORGANIZATIONJANE DOE NO
PERSON
Supreme Court
ORGANIZATIONNadia Marcinkova
PERSON
Wilbur Ross
PERSON
Jacksonville
LOCATION
Michael Cohen
PERSON
Bradley Cooper
PERSONSecond Circuit
ORGANIZATIONSrebnick
PERSON