Epstein Secrets

ant had successfully adjusted to pris- op, was genuinely interested m several reli- gions, and filed grievances for entirely le- gitimate purposes. U.S.C.A. Const.Amends. 1, 5. [33] Constitutional Law 92 4 1170 92 Constitutional Law 92X First Amendment in General 92X(B) Particular Issues and Applic-

U.S. 225, 95 S.Ct. 2160, 45 L.Ed.2d 141, 20 Fed.R.Serv.2d 547 (Cite as: 422 U.S. 225, 95 S.O. 2160) Supreme Court of the United States Reversed. UNITED ST ES, Petitioner, Robert Lee NOBLES. No. 74-634. Argued April 23, 1975. Decided June 23, 1975. Defendant was convicted in the United States District

rk an implied waiver of all confidential communications on the same subject mat- ter. Accord von Bulow, 82$ F.2d at 102-03; Yankee Atomic Elec. Co. I. United States, 54 Fed. Cl. 306, 316 (2002). The rationale behind our holding is self-evident. When an attorney participates in an extrajudicial meeting or nego

. 0042201 23 EFTA00177962 Page I of 55 Westlaw Page I 531 F.3d 197 (Cite as: 531 F.3d 197) United States Court of Appeals, Second Circuit. UNITED STATES America, Appellee, Donald FELL, Defendant-Appellant. Docket No. 06-2882-cr. Argued: June 27, 2007. Decided: June 27, 2008. Background: Defendant was con

s Reversed. UNITED ST ES, Petitioner, Robert Lee NOBLES. No. 74-634. Argued April 23, 1975. Decided June 23, 1975. Defendant was convicted in the United States District Court for the Central Dis- trict of California of bank robbery and the Court of Appeals, 501 F.2d 146, affumed in part, reversed in part,

er a particular plea is desirable, since "[e]ffective assistance of counsel includes counsel's informed opinion as to what pleas should be entered." United Stalest Pillar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Borial. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility

in- stance. The court authorized no general `fishing expedition' into the defense files ji or indeed even into the defense 'nvestigat- or's report. a. United States . Wright, 160 U.S.App.D.C. 57, 489 .2d 1181 O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. https://web2.westlaw.com/print/printstream.a

ictims a right to approve or disapprove a proposed plea in advance or to participate in plea negotiations." In re Dean on remand as United States'. BP Products North America, Mc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009). Instead, "[t]he purpose of the reasonable right to confer is for victims to provide information to

pecialist TOTAL P.O? EFTA00177316 Case 9:08-cv-t -KAM Document 14 Entered on FLSD Docket 07/1 38 Page 18 of 21 U.S. Department of Justice %sr United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach. FL 33401 (361)8204711 Facsimile: (561) 820-8777 Jul

efore the Court on Plaintiff's Emergency Petition for Enforcement of Crime Victim's Rights Act (DE 1), filed July 7, 2008. It is hereby ORDERED that the United States' Attorney shall file a response to this petition by 5:00 P.M. on Wednesday, July 9, 2008. DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach

RT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-C1V-MARRA/JOHNSON 38 Page 1 of 1 ORDER DENYING MOTION TO SEAL THIS CAUSE comes before the Court on the United States of America's Motion to Seal its Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, filed July 9, 2008. The Court has carefully

Government claims is troublesome, the Fifth Circuit cited to the district coirt opinion under review, which had quoted all the words in the statute. See United States'. SP Peoducts, 2008 WL 501321 at *7 (noting victims right to confer "in the case"), cited in In re Dean, 527 F.3d at 394. The Government finally no

ng its broad discretion." Id. at 395. In Dean, the government sought and obtained an gh pane order permitting it to negotiate a plea agreement with BP Products North America, without first consulting with the victims, individuals injured and survivors of those killed in a refinery explosion. A plea agreement was ultimat

employee as the source of the information. (2) Appearance. A former employee makes an appearance when he is physically present before an employee of the United Slates, in either a formal or informal setting. Although an appearance also may be accompanied by certain communications, an appearance need not involve an

ecified in paragraphs (fXI) (i) through (f)(l)(iv) of this section, e.g., as when a former employee directs remarks to an employee representing the United Slates as a party or intervenor in a Federal or non-Federal judicial proceeding. A Conner employee does not direct his communication or appearance to a bys

id not participate as a Government employee. Example 7 to paragraph (hX2): An employee of the Department of State participated in the development of the United States' position with respect to a proposed treaty with a foreign government concerning transfer of ownership with respect to a parcel of real property and

esolving prisoner disputes. Construing the CVRA in the way that "See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States v. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United St

ment deemed was a "reasonable procedure to give effect to this chapter that does not unduly complicate or prolong the proceedings." United States v. BP Products North America, Inc., 2008 WL 501321 (S.D.Tex. Feb. 21, 2008) at " 2. The government announced to the court 29 EFTA00230094 Case 9:08-cv-80736-KAM Document 62

OE, Petitioner. FILED by rte D.C. JUL 0 91008 STEVEN M. lAR0AOSE CLERK U.S. 0IST CT S.D. OF FLA. - W..N W. DECLARATION OF Al IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT. 18 U.S.C. & 3771 I, , do hereby declare that I am a member in

1 until 37:23 urge 22:9 use 10:25 11:8 20:24 23:11 28:25 40:11 used 28:19 U.S 2:15 4:10 7:1,9 8:6 12:8,12 16:16 26:19 27:4,18,19 43:5,11,25 U.S.A 2:16 U.S.0 33:7 various 3:1 1025 very 4:21 5:7 11:1,2 11:20 12:21 16:19 16:24 17:12,12 23:11 29:4 32:1 35:18 38:10 40:18 42:2 43:18 44:14 Vi

anticipate this agreement will not be made part of any public record but if there is a Freedom of information Act Request or compulsory process on the United States for this agreement, the U.S. will give petitioner notice before disclosing the agreement; that the U.S. Attorney cannot guarantee what the state at

ng its broad discretion." Id. at 395. In Dean, the government sought and obtained an ex pane order permitting it to negotiate a plea agreement with BP Products North America, without first consulting with the victims, individuals injured and survivors of those killed in a refinery explosion. A plea agreement was ultimat

IV-MARRAMOHNSON EFTA00208068 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 33 of 54 The district court found that the United States' admission that Dr. Jackson was an employee was not a judicial admission, because "[w]hether Dr. Jackson was a federal employee under the FTCA appea

. 2005) (emphasis added). In W.R. me, petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the Rigas family. Two members of the Rigas family were convicted of securities fraud. A third was acquitted. Adelphia Communications

ment deemed was a "reasonable procedure to give effect to this chapter that does not unduly complicate or prolong the proceedings." United States v. BP Products North America, Inc., 2008 WL 501321 (S.D.Tex. Feb. 21, 2008) at * 2. The government announced to the court 29 Respondent's Exhibit A Case No. 08-80736-CIV-MARR

place nor suppkniont the filing and seivice of pkadings or whet papers a by local mks of :oat. Tins form. approwed by the Judicial Conference of 'he United Stales In Septanba 1974. is required for the use of the Clerk tX Civil cockei nett SEE INSTRUC TIOVS ON THE REVERSE OF THE FORM.' NOTICE: Attorneys MUST

n "ancillary criminal proceeding[]," DE 290 at 2, presumably not covered by a statute of limitations applicable to a "civil action commences against the United States." 28 U.S.C. § 2401(a). Even more surprising to us was your Office's failure to discuss the second sentence in § 2401(a), which provides that the si

Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district court in which a defendant

ator Feinstein)(explaining that the right to confer was "intended to be expansive," applying to "any critical state or disposition of the case") and United States v. Heaton, 458 F. Supp. 2d 1272 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to enga

ted States of America. (Lee, Dexter) (Entered: 01/26/2012) 01/26/2012 .1.44 RESPONSE in Opposition re_12$ Motion for Miscellaneous Relief filed by United States of America. (Sanchez, Eduardo) (Entered: 01/26/2012) 01/27/2012 145 ENDOR ingitl Motion for Leave to File Excess Pages. Signed by Judge on 1/27/2012. (ir)

prelude to the full unfettered exercise of their conferral rights at a time that will enable the victims to exercise those rights meaningfully. See BP Products North America, supra at *14 ("Section 3771(c)(1) requires government officials to use best efforts to give victims notice of their rights under subsection (1), i

tes. Id. at *5. 32 EFTA00078866 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 33 of 54 The district court found that the United States' admission that Dr. Jackson was an employee was not a judicial admission, because "[w]hether Dr. Jackson was a federal employee under the FTCA appea

. 2005) (emphasis added). In W.R. me, petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the Rigas family. Two members of the Rigas family were convicted of securities fraud. A third was acquitted. Adelphia Communications

ment deemed was a "reasonable procedure to give effect to this chapter that does not unduly complicate or prolong the proceedings." United States v. BP Products North America, Inc., 2008 WL 501321 (S.D.Tex. Feb. 21, 2008) at * 2. The government announced to the court 29 EFTA00078863 Case 9:08-cv-80736-KAM Document 62

N RE: JANE DOE, Petitioner. FILED by D.C. JUL 0 91008 STEVEN M. LKRIMORE CLERK U.S. Din CT. S.D. OF FLA. • WA B. DECLARATION a IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT cw CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771 I. I, do hereby declare that 1 am a member

of a violation of section 1589, 1590, or 1591 of this chapter may bring a civil action against the perpetrator in an appropriate district court of the United States and may recover damages and reasonable attorneys fees. (b) (1) Any civil action filed under this section shall be stayed during the pendency of

sing its broad discretion." a at 395. In pear, the government sought and obtained an eK pane order permitting it to negotiate a plea agreement with BP Products North America, without first consulting with the victims, individuals injured and survivors of those killed in a refinery explosion. A plea agreement was ultimat

.g., Doe v. United Slates. 666 F.2d 43. 46 14th Cir. 1981) (rape victim allowed to appeal dis- trict court's adverse 'rape shield statute" ruling): United Stales Ilona. 77 F.3d 66 ford Cir. 1996) (victim allowed to appeal adverse restitution decision). Congress sought to leave these protections in place. w

that crime victims had no right to confer with prosecutors until after the Department had reached and signed a plea agreement with a corporation (BP Products North America) whose illegal actions had resulted in the deaths of fifteen workers in an oil refinery explosion. Of course, this position meant that the victim