Epstein Secrets

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00210154 Case 9:08-cv-

65 at 13). Second, they argue that the doctrine does not apply because the conduct of those prosecutors is a "central issue" in this case. a at 15). The Courts finds these arguments unavailing. First, Petitioners argue that the "work product doctrine does not apply to claims advanced by crime victims that

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA_R1_01293450 EFTA023359

5 at 13). Second, they argue that the doctrine does not apply because the conduct of those prosecutors is a "central issue" in this case. (1 at 15). The Courts finds these arguments unavailing. First, Petitioners argue that the "work product doctrine does not apply to claims advanced by crime victims that

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00086459 Case 9:08-cv-

at 13). Second, they argue that the doctrine does not apply because the conduct of those prosecutors is a "central issue" in this case. (a. at 15). The Courts finds these arguments unavailing. First, Petitioners argue that the "work product doctrine does not apply to claims advanced by crime victims that

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA01657766 Case 9:08-cv-

65 at 13). Second, they argue that the doctrine does not apply because the conduct of those prosecutors is a "central issue" in this case. a at 15). The Courts finds these arguments unavailing. First, Petitioners argue that the "work product doctrine does not apply to claims advanced by crime victims that