Epstein Secrets

). Communications Facilitating Crime-Fraud-Misconduct Not Covered — Any privilege would be subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985) (applying exception to attorney-client privilege); Cox v. Administrator U.S. Steel & Carnie, 17 F.3d 1386, 1422

erent power beyond the literal wording of Rule 6(e)(3) to disclose grand jury material" and has properly exercised that power here. United States v. Aisenberg, 358 F.3d 1327, 1347 (11th Cir. 2004). Victims Have Properly Petitioned for the Release of Grand Jury Materials — A litigant can petition for rele

lating to alleged indiscretion within the department). • Any attorney-client privilege is subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985). The victims intend to argue that the crime-fraud-misconduct exception applies on the facts of this case.' • A

grand jury materials. • The Court has "inherent power beyond the literal wording of Rule 6(e)(3) to disclose grand jury material," United States. Aisenberg, 358 F.3d 1327, 1347 (11th Cir. 2004), and has properly exercised that power here. • A litigant can petition for release of grand jury materials.

inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document

grand jury secrecy has been incorporated into our federal common law and remains an integral part of our criminal justice system." United States v. Aisenberg, 358 F.3d 1327, 1346 (11th Cir. 2004) (internal quotation marks omitted). "Rule 6(e) of the Federal Rules of Criminal Procedure codifies this secre