Epstein Secrets

FLSD Docket 08/16/2013 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS THAT ARE NOT PRIVILEGED EFTA00208672 Case 9:08-cv-8

communications made for purposes of facilitating the rendition of legal services to the Government client. See, e.g., Diamond v. City of Mobile, 86 F.R.D. 324 (D. Ala. 1978) (attorney-client privilege did not bar disclosure of statements made to the city attorney while conducting the internal investigatio

FLSD Docket 08/01/2013 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDINARY BRIEFING SCHEDULE AND ORDINARY PAGE LIMITS TO RESPOND TO GOVERNMENT PRIVIL

communications made for purposes of facilitating the rendition of legal services to the Government client. See, e.g., Diamond I City of Mobile, 86 F.R.D. 324 (D. Ala. 1978) (attorney- client privilege did not bar disclosure of statements made to the city attorney while conducting an internal investigation

given to attorneys for the victims about the non-prosecution agreement, including information about what could be told to Brad Edwards (counsel for Jane Doe #1 and Jane Doe #2) about the non-prosecution agreement; f) All correspondence, documents, and other information regarding Epstein's awareness that

communications made for purposes of facilitating the rendition of legal services to the Government client. See, e.g., Diamond v. City of Mobile, 86 F.R.D. 324 (D. Ala. 1978) (attorney-client privilege did not bar disclosure of statements made to the city attorney while conducting the internal investigatio