Epstein Secrets

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'

rcuit has indicated in a civil case that Perlman jurisdiction is still viable after Mohawk where the privilege holder is not a party to the action, Holt-Orsted, 641 F.3d at 239; and the Seventh Circuit has indicated in a civil case that Perlman jurisdiction still attaches where the person asserting the priv

Utah 332 S. 1400 E., Room 101 Salt Lake City, UT 84112 (801) 585-5202 [email protected] Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209355 CERTIFICATE OF INTERESTED PERSONS Pursuant to 11th Cir. R. 26.1, Jane Doe No. 1 and Jane Doe No. 2, through undersigned couns

, an appeal from the final decision will allow review of the district court's ruling." Wilson v. O'Brien, 621 F.3d 641, 643 (7th Cir. 2010); accord Holt-Orsted v. City of Dickson, 641 F.3d 230, 236-40 (6th Cir. 2011) ("[T]he Mohawk decision has altered the legal landscape related to collateral appeals of d

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

rk Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005) 13, 15, 19 Gotham Holdings, LPG. Health Grades, Inc., 580 F.3d 664 (7th Cir. 2009) 15 Holt-Orsted. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 10, 11, 15 In re Grand Jury, 705 F.3d 133 (3d Cir. 2012) 9 In re Grand Jury Proceedings, 43 F.3d

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

rk Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005) 13, 15, 19 Gotham Holdings, LPG. Health Grades, Inc., 580 F.3d 664 (7th Cir. 2009) 15 Holt-Orsted. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 10, 11, 15 In re Grand Jury, 705 F.3d 133 (3d Cir. 2012) 9 In re Grand Jury Proceedings, 43 F.3d

ISTOS & LEHRMAN, P.L. Paul G. Cassell S. J. Quinney College of Law at the University of Utah Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209567 CERTIFICATE OF INTERESTED PERSONS Pursuant to 11th Cir. R. 26.1, Jane Doe No. 1 and Jane Doe No. 2, through undersigned couns

y, an appeal from the final decision will allow review of the district court's ruling." Wilson'. O'Brien, 621 F.3d 641, 643 (7th Cir. 2010); accord Holt-Orsted I City of Dickson, 641 F.3d 230, 236-40 (6th Cir. 2011) ("[T]he Mohawk decision has altered the legal landscape related to collateral appeals of di

trict of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane Doe No. I and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the United States and Epstein. On September 24, 2007,

7th Cir. 2010); see also In re Grand Jury, 705 F.3d at 145-46 & n.11 (rejecting that Mohawk narrowed Perlman "at least in the grand jury context"); Holt-Orsted v. City of Dickson, 641 F.3d 230, 239 (6th Cir. 2011) (recognizing that Perlman jurisdiction remains when a nonparty asserts a privilege); Krane, 6

ver 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. In response to that order, settlement negotiation correspondence authored by government prosecutors (

re & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 51, 52, 55 In re Air Crash Near Cali, Colombia, 959 F.Supp. 1529 (S.D.F1a. 1997) 38, 40 In

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

t 606-07. That, however, is not the case here. Since the attorney intervenors are not "litigants" or parties in this action, under both Wilson and Holt-Orsted, they would retain the right to appeal under Perlman. Plaintiffs seek to cast Mr. Epstein as a "litigant" in this action, but his limited intervent

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'

at 606-07. That, however, is not the case here. Since the attorney intervenors are not "litigants" or parties in this action, under both Wilson and Holt-Orsted, they would retain the right to appeal under Perlman. Plaintiffs seek to cast Mr. Epstein as a "litigant" in this action, but his limited interventi

oc. 205-6 at 12-13. Now having reaped the benefits of the NPA, plaintiffs seek, among other remedies, a recision of that agreement. EFTA00584603 Jane Doe No. 1 commenced the underlying action in 2008, contending that the government had violated her rights under the CVRA, 18 U.S.C. §3771. Epstein is n

t 606-07. That, however, is not the case here. Since the attorney intervenors are not "litigants" or parties in this action, under both Wilson and Holt-Orsted, they would retain the right to appeal under EFTA00584613 Perlman. Plaintiffs seek to cast Mr. Epstein as a "litigant" in this action, but his li