Epstein Secrets

led under seal by order of Judge unsealed and made public. (15-cv-7433, Dkt. Nos. 362, 550, 935.) Harvard Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetrating sex crimes alongside Epstein, moved to unseal a limited portion of the record in order to clear his name. (

d Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetrating sex crim

arvard Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetratin

is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition." Id (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself—similarly weighs in favor of modification. The Protective Order provided tha

der seal by order of Judge Sweet unsealed and made public. (15-cv-7433, Dkt. Nos. 362, 550, 935.) Harvard Law professor and criminal defense lawyer Alan Dershowitz, whom Giuffre publicly alleged of perpetrating sex crimes alongside Epstein, moved to unseal a limited portion of the record in order to clear his

d Law professor and criminal defense lawyer Alan Dershowitz, whom Giuffre publicly alleged of perpetrating se

arvard Law professor and criminal defense lawyer Alan Dershowitz, whom Giuffre publicly alleged of perp

is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.' Id. (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself-similarly weighs in favor of modification. The Protective Order provided tha

ndrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and R

nce Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefko

ment, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00179727 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docke

icipation of litigation, and certainly not litigation about the Crime Victims' Rights Act. See, e.g., Southern Union Co. v. Southwest Gas Corp., 205 F.R.D. 542, 549 (D. Ariz. 2002) (documents not protected by work product because not prepared in connection with case at hand). II. Specific Responses to

32, 08-80380, 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. AUerbury Goldberger & Weiss, P.

to embody a general federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Coro. v. Krueger, 55 F.R.D. 514-15 (N.D. III. 1972X"it is the opinion of this court that (§6103] reflect[s] a valid public policy against disclosure of income tax returns. This

08-80381, 08-80993, 08- Pro Rae Vice 80994 Jack Alan Goldberger, Esq. Counsel for Defendant Jetty Est

to embody a general federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Corp. v. Krueger, 55 F.R.D. 514-15 (N.D. Ill. 1972X"it is the opinion of this court that [§6103] reflect[s] a valid public policy against disclosure of income tax returns. This

.Y. Nov. 2, 2016), ECF No. 496 (Opinion Granting Dershowitz Motion to Intervene); Giuffre v. Maxwell, No. 15

ore difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.') (quoting In re EPDM, 255 F.R.D. at 319). Since the Protective Order does not address specific deposition testimony or exhibit documents, the parties do not have demonstrated relian

.Y. Nov. 2, 2016), ECF No. 496 (Opinion Granting Dershowitz Motion to Intervene); v. Maxwell, No. 15 Civ. 7

ore difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.') (quoting In re EPDM, 255 F.R.D. at 319). Since the Protective Order does not address specific deposition testimony or exhibit documents, the parties do not have demonstrated relian

looseleaf service updated annually). 3A Charles Alan Wright, Federa 1 Practice and Procedure SS 761-7

vernment is required to demonstrate that there are grounds for a hearing under the specific provisions of either 3142(f)(1) or (f)(2)." Butler, 165 F.R.D. at 71. "When there exists one or more grounds for holding a hearing under those provisions, the government may proceed on the theory of risk of fli

n Related Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

ere, preventing Epstein from identifying Plaintiffs' in subpoenas and other type discovery overwhelmingly inhibits discovery. Ees Doe v. Evans, 202 F.R.D. at 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing De

en & Sir- cusa ("RMJS"), and others, principally Alan Garfinkel and Leigh Katzman, form- ing Katzman Ga

to Orig. US Gov. Works. https://web2.westlaw.contrint/printstream.aspers=WLW11.07&pbc=8C6E23F9,Sidecti n ObAPIAI EFTA00177915 Page 10 of 25 183 F.R.D. 458,51 Fed. R. Evid. Serv. 35 (Cite as: 183 F.R.D. 458) L . way that the attorney client priv- ilege can. Whether the information involved is fac