Epstein Secrets

bject to use of the documents there: "Epstein is not a party to that suit, which involves Jane Does #1 and #2's allegations that the U.S. Attorney's Office for the Southern District of Florida violated their rights. Accordingly, without intervening in the case, he cannot raise any objections to the use of the correspondence in

required to make the same initial disclosures that are part and parcel of civil suits. He would also presumably be subject to deposition. See Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1305 (11th Cir. 2008) (affirming denial of motion to intervene because of delay that would be involved in deposing the intervenors)

bject to use of the documents there: "Epstein is not a party to that suit, which involves Jane Does #1 and #2's allegations that the U.S. Attorney's Office for the Southern District of Florida violated their rights. Accordingly, without intervening in the case, he cannot raise any objections to the use of the correspondence in

required to make the same initial disclosures that are part and parcel of civil suits. He would also presumably be subject to deposition. See Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1305 (11th Cir. 2008) (affirming denial of motion to intervene because of delay that would be involved in deposing the intervenors)

CIV. 1540 MN, 2013 WL 139560, at *2 (S.D.N.Y. Jan. 11, 2013) and United States v. Bouchard Transp., No. 08-CV-4490 NGG ALC, 2010 WL 1529248, at *2 (E.D.N.Y. Apr. 14, 2010). Ms. Maxwell agrees, which is precisely why she has not logged post-litigation privileged communications. Ms. Maxwell never stated,

ions of the agreement were prepared in anticipation of litigation and therefore fall within the definition of attorney work product."); Oklahoma v. Tyson Foods, Inc., No. 05-CV-329, 2007 WL 3128422, at • (N.D. Okla. Oct. 24, 2007). 10 EFTA00618143 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 13 of 1