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lege is a non- litigant, Wilson, 621 F.3d at 643.2 The grand jury limitation for which plaintiffs argue simply does not exist. 2 Plaintiffs rely on the Tenth Circuit's lack of awareness that Perlman had ever been applied outside the grand jury context, Opposition at 6, but a quick Westlaw search demonstrates that
the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its opportunity to do so in the future." hi. at 239. The same is true here. The Court found no appellate jurisdict
ea negotiations is protected by the work product privilege, it stopped short of advocating the recognition of a settlement/plea 'Plaintiffs rely on the Tenth Circuit's lack of awareness that Perlman had ever been applied outside the grand jury context, Motion at 16-17, but a quick Westlaw search demonstrates that
the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its 10 EFTA00209479 Case: 13-12923 Date Filed: 07/12/2013 Page: 16 of 25 opportunity to do so in the future."
ea negotiations is protected by the work product privilege, it stopped short of advocating the recognition of a settlement/plea 'Plaintiffs rely on the Tenth Circuit's lack of awareness that Perlman had ever been applied outside the grand jury context, Motion at 16-17, but a quick Westlaw search demonstrates that
the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its 10 EFTA00209548 Case: 13-12923 Date Filed: 07/12/2013 Page: 16 of 25 opportunity to do so in the future."
ort of Motion to Intervene (Doc. 100). The government's institutional interests differ significantly from those of attorneys who Plaintiffs rely on the Tenth Circuit's lack of awareness that Perlman had ever been applied outside the grand jury context, Opposition at 6, but a quick Westlaw search demonstrates that
the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its opportunity to do so in the future." Id. at 239. The same is true here. The Court found no appellate jurisdict
Entities connected to both the Tenth Circuit's and Quellos

Jeffrey Epstein
PERSON
United States
LOCATION
Alberto Gonzales
PERSONKrane
PERSONNadia Marcinkova
PERSONSealed Case
PERSON
Michael Cohen
PERSON
Kenneth Marra
PERSONHolt-Orsted
ORGANIZATIONthe Wilson Court
ORGANIZATIONthe Mohawk Court
ORGANIZATIONLoan Corp.
ORGANIZATIONO'Brien
PERSONOverby
PERSONDickson
PERSONJane Doe
PERSONLeon Black
PERSONU.S. Fidelity & Guar
ORGANIZATIONGotham Holdings
ORGANIZATIONSheet Metal Workers Intern
ORGANIZATION