Epstein Secrets

ce in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confident

iosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?5 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out)

a settlement privilege which insulates them not just from admission into evidence but from discovery as well. See, M, Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to settlement negotiations in bot

ce in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confident

iosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?3 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out)

ettlement privilege which insulates them not just from admission into evidence but from discovery as well. See, Lls-, Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to settlement negotiations in bot

DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent, UNITED STATES' MEMORANDUM OF LAW REGARDING INTERVENORS' RIGHTS TO OBSERVE AND PARTICIPATE IN THE SETTLEMENT CONFERENCE The Respondent, United States of America, b

tim cannot be required to participate in a sentencing or restitution hearing in order to obtain an order of restitution. 18 U.S.C. § 3664(g)(1). See United States v. Speakman, 594 F.3d 1165 (10th Cir. 2010); United States v. Amara, 616 F. App'x 612 (4th Cir. 2015); United States v. Schmidt, 675 F.3d 1164 (8th

o pre-trial settlement procedures, asserting a First Amendment right of access, and the courts denied such access. In Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit similarly recognized that "confidential settlement communications are a tradition in this country."

unications from disclosure to third parties outside the negotiation process. 3. Whether this Court has jurisdiction of this appeal under Perlman v. United States, 247 U.S. 7 (1918). EFTA00209671 Case: 13-12923 Date Filed: 08/05/2013 Page: 16 of 75 STATEMENT OF THE CASE AND STATEMENT OF FACTS In Septembe

tomary practices of the defense and prosecution function, entitled to assume would remain confidential and would not be disclosed to third parties. See United States v. Deloitte UP, 610 F.3d 129, 141 (D.C.Cir. 2010)(court "examine[s] whether the disclosing party had a reasonable basis for believing that the reci

1164 (C.D.CaI. 1998) 33, 37, 40 Gill v. Gulfstream Park Racing Ass 'Ft, Inc., 399 F.3d 391 (1st Cir. 2005) 54 *Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v. City of Dickson, 641 F.3d 230

DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, 1. UNITED STATES OF AMERICA, Respondent, UNITED STATES' MEMORANDUM OF LAW REGARDING INTERVENORS' RIGHTS TO OBSERVE AND PARTICIPATE IN THE SETTLEMENT CONFERENCE The Respondent, United States of America, b

Circuit has determined that this is not a civil case, but rather is "ancillary to a criminal investigation" and "a criminal action." Jane Doe No. 1 I. United States, 749 F.3d 999, 1005, 1006 (11th Cir. 2014). Despite that designation, the petitioners filed their case as a civil action and the district court has

to pre-trial settlement procedures, asserting a First Amendment right of access, and the courts denied such access. In Goodyear Tire & Rubber Co. I Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit similarly recognized that "confidential settlement communications are a tradition in this country."

DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, 1. UNITED STATES OF AMERICA, Respondent, UNITED STATES' MEMORANDUM OF LAW REGARDING INTERVENORS' RIGHTS TO OBSERVE AND PARTICIPATE IN THE SETTLEMENT CONFERENCE The Respondent, United States of America, b

Palm Beach Post and The Palm Beach Daily News. case, but rather is "ancillary to a criminal investigation" and "a criminal action." Jane Doe No. 1 I. United States, 749 F.3d 999, 1005, 1006 (11th Cir. 2014). Despite that designation, the petitioners filed their case as a civil action and the district court has

that a "person accused of the crime may not obtain any form of relief under this chapter." 18 U.S.C. § 3771(d)(1). 5 EFTA00211684 & Rubber Co.I Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit went further, finding that settlement communications were privileged and not discoverable.3 Id. At

lls and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. -7- FOWLER WHITE BURNETT, PA. • PHILLIPS Peon - WIRT TOWE

red by settlement privilege which insulates them not just from admission into evidence but from discovery as well. Goodyear Tire & Rubber Company v. Chiles Power Supply, Inc., 332 F. 3d 976, 979-983 (6th Cir. 2003). The court specifically stated: There exists a strong public interest in favor of secrecy of matters discu

lls and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. -7- FOWLER WHITE BURNETT, PA. • PHILLIPS Peon - WIRT TOWE

red by settlement privilege which insulates them not just from admission into evidence but from discovery as well. Goodyear Tire & Rubber Company v. Chiles Power Supply, Inc., 332 F. 3d 976, 979-983 (6th Cir. 2003). The court specifically stated: There exists a strong public interest in favor of secrecy of matters discu

lls and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. -7- FOWLER WHITE BURNETT, PA. • PHILLIPS Peon - WIRT TOWE

red by settlement privilege which insulates them not just from admission into evidence but from discovery as well. Goodyear Tire & Rubber Company v. Chiles Power Supply, Inc., 332 F. 3d 976, 979-983 (6th Cir. 2003). The court specifically stated: There exists a strong public interest in favor of secrecy of matters discu