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

sistently recognized that the harm caused by an erroneous order to disclose privileged or confidential information is irreparable. See, e.g., In re Professionals Direct Ins. Co., 578 F.3d 432, 438 (6th Cir. 2009)(finding risk of irreparable harm because "a court cannot restore confidentiality to documents after they are dis

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Black, Martin

courts have recognized that the harm caused by an erroneous order to disclosetivileged or confidential information is irreparable. See, e.g., In re Professionals Direct Ins. Co., 578 F.3d 432, 438 (6th _eV Cir. 2009)(finding risk of irreparable harm because "a court cannat restore confidentiality to documents after they ar

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Black, Martin

courts have recognized that the harm caused by an erroneous order to disclosetivileged or confidential information is irreparable. See, e.g., In re Professionals Direct Ins. Co., 578 F.3d 432, 438 (6th _eV Cir. 2009)(finding risk of irreparable harm because "a court cannat restore confidentiality to documents after they ar

pstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane Doe #1 and Jane Doe #2's Response to Motion to Intervene (DE 78) at 4-6. Perhaps recognizing the strength of the victims' response, the defense attorne

e the Government has cataloged the documents in its privilege log, it then bears the burden of proving the applicability of the privilege. See In re Professionals Direct Ins. Co., 578 F.3d 432 (6ih Cir. 2009); Boogie v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003). The victims will, of course, later respond in detail to any

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

66 (5th Cir. 1994) 19 In re Grand Jury Proceedings, 832 F.2d 554 (11th Cir. 1987) 13 In re Perrigo Co., 128 F.3d 430 (6th Cir.1997) 19 In re Professionals Direct Ins. Co., 578 F.3d 432 (6th Cir. 2009) 19 In re Sealed Case, F.3d 2013 WL 2120157 13 (D.C.Cir. March 5, 2013) Lafler. Cooper, 132 S.Ct. 1376 (2012) 5

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

66 (5th Cir. 1994) 19 In re Grand Jury Proceedings, 832 F.2d 554 (11th Cir. 1987) 13 In re Perrigo Co., 128 F.3d 430 (6th Cir.1997) 19 In re Professionals Direct Ins. Co., 578 F.3d 432 (6th Cir. 2009) 19 In re Sealed Case, F.3d 2013 WL 2120157 13 (D.C.Cir. March 5, 2013) Lafler. Cooper, 132 S.Ct. 1376 (2012) 5

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);

sistently recognized that the harm caused by an erroneous order to disclose privileged or confidential information is irreparable. See, e.g., In re Professionals Direct Ins. Co., 578 F.3d 432, 438 (6th Cir. 2009)(finding risk of irreparable harm because "a court cannot restore confidentiality to documents after they are dis