Epstein Secrets

ed. R. Evid. 501 4, 16 iv EFTA00209469 Case: 13-12923 Date Filed: 07/12/2013 Page: 6 of 25 INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

nagement Dist., 647 F.3d 1296 (11th Cir. 2011) 14 6 18 Gill Gulfstream Park Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005) 13, 15, 19 Gotham Holdings, LPG. Health Grades, Inc., 580 F.3d 664 (7th Cir. 2009) 15 Holt-Orsted. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 10, 11, 15 In re Grand Ju

ed. R. Evid. 501 4, 16 iv EFTA00209538 Case: 13-12923 Date Filed: 07/12/2013 Page: 6 of 25 INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

nagement Dist., 647 F.3d 1296 (11th Cir. 2011) 14 6 18 Gill Gulfstream Park Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005) 13, 15, 19 Gotham Holdings, LPG. Health Grades, Inc., 580 F.3d 664 (7th Cir. 2009) 15 Holt-Orsted. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 10, 11, 15 In re Grand Ju

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

e impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

ry context, Motion at 16-17, but a quick Westlaw search demonstrates that Perlman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. Health Grades, Inc., 580 F.3d 664, 665 (7th Cir. 2009)(civil case); United States v. Williams Cos., Inc., 562 F.3d 387, 392 (D.C.Cir. 2009)(

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4, . Instead, he pled guilty to two state offenses, one of which was a fel

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

e impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

ry context, Motion at 16-17, but a quick Westlaw search demonstrates that Perlman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. Health Grades, Inc., 580 F.3d 664, 665 (7th Cir. 2009)(civil case); United States v. Williams Cos., Inc., 562 F.3d 387, 392 (D.C.Cir. 2009)(

07 (emphasis added). This conclusion underscores that inapplicability of Mohawk in the present circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to the litigation, having intervened solely for the limited purpose of seeking to prevent the disclosu

circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to

jury context, Opposition at 6, but a quick Westlaw search demonstrates that Penman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. 7 EFTA00583460 D. The United States is a Disinterested Third Party. Under the circumstances of this case, the government, contrary to pl

07 (emphasis added). This conclusion underscores the inapplicability of Mohawk in the present circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to the litigation, having intervened solely for the limited purpose of seeking to prevent the disclosu

ircumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to

ury context, Opposition at 6, but a quick Westlaw search demonstrates that Perlman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. Health Grades, Inc., 580 F.3d 664, 665 (7th Cir. 2009)(civil case); United States v. Williams Cos., Inc., 562 F.3d 387, 392 (D.C.Cir. 2009)(