Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. / REPLY IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, A

pose intervention because according to them, proposed intervenors Black, Weinberg and Lefkowitz do not have a claim of privilege or confidentiality. Jane Doe I and Jane Doe 2 contend that all the correspondence at issue was already turned over to them. They are mistaken. Undersigned counsel spoke with Pa

a practical matter impair or impede the movant's ability to protect its interest, unless existing parties adequately represent that interest. FED. R. Cry. P. 24(a) (emphasis added). The defense team has an interest in protecting its work product and the privileged and confidential settlement negotiat

searohlooMotIonloOlsmiss;:MoreCeffilte"Sfiteltilrie and to Strike Complaint (080893J.D. case) 10/10/2008 P.-- Review Motion and RICO statement re: Jane Doe; revision Page 3 EFTA00722494 Matter ID: 2008029 Invoice 629296 Federal ID # 59-2827461 Per Prefeeetemsd Settee Rendered: EFTA00722495 Ma(t

his Invoice: Total Due: Balance In Trust:, Balance in Retainer: 1 I I II I 1St Page 9 EFTA00722500 LAW OFFICES OF BURMAN, CRIFON, II irrtFrk R. Cry *maw up 616 NORTH RACIER DRIVE SUITE 400 WEST PALM BEACH, FLORIDA 33401 April C6, 2009 INVOICE Matter ID: 2008-029 Client ID: 3371 EPSTEIN, J

00059568 CONFIDENTIAL - PURSUANT TO FED. R.WANI(E IDENTIAL DB-SDNY-0022392 EFTA_00I7Ol 18 EFTA01296786 Page 62 2015 U.S. Dist. LEXIS 87203, * JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. CASE NO.:08-CV-80736-KAM UNITED STATES DISTRICT COURT FOR THE SOUTHERN DIS

s, the Government has not demonstrated that they were prepared "in anticipation of litigation or for trial" so as to be protected work product. Fed. R. Cry. P. 26(b)(3)(A). As discussed in the next section, however, the Court has thoroughly reviewed these documents and finds that they are not relevant.