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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
9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grol
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-
9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grol
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-
9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Groli
Entities connected to both The Eleventh Circuit and Underwriters Ins. Co.

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
United States
LOCATION
Paul Cassell
PERSONthe Southern District
LOCATIONLeon Black
PERSON
George W. Bush
PERSONRoy Black
PERSON
Department of Justice
ORGANIZATIONthe Federal Rules of Civil
ORGANIZATION
Jay Lefkowitz
PERSOND.C. Cir
ORGANIZATION
Supreme Court
ORGANIZATIONEmmy Taylor
PERSON
Michael Douglas
PERSONHickman
PERSONWayte
PERSONDouglas Oil Co.
ORGANIZATIONWright
PERSON