Epstein Secrets

081 (4th Cir. 1981). Under the circumstances, any claim of privilege or work product cannot be accepted without further evidentiary substantiation. See United States'. Aramony, 88 F.3d 1369, 1392 (4th Cir. 1996) (where the allegations against one party could not subject another to civil or criminal liability, joi

nce law. Most Cited Cases In a diversity case, court applies federal law to resolve work product claims. Fed.Rules Civ.Proc.Rule 26(b)(3), 28 U.S.C.A. [5j 04( Federal Civil Procedure 170A €=+ 16 2) 170A Federal Civil Procedure 170AX Depositions and Discovery 170AX(E) Discovery and Production

the law relating to inadvertent waiver of the attorney client privilege, not- ing that three distinct approaches had been followed by courts within the United States: a strict waiver approach, fmding waiver whenever a non-privileged disclos- ure occurs; a lenient approach: finding waiver only in the instance of

("Colorable claims of attor- ney-client and work product privilege [are] .. . a textbook example of an entitlement to intervention as of right."); United Stalest. AT & T Co., 642 F.2d 1285, 1292 (D.C.Cir.1980); Sackman I. Liggett Group, Inc., 167 F.R.D. 6, 20-21 (E.D.N.Y. 1996). In allowing intervention,

attorney, who also represented corporation, where attor- ney was not actively protecting that privi- lege. Fed.Rules Civ.Proc.Rule 24(a), (aX2), 28 U.S.C.A.; Fed.Rules Evid.Rule 501, 28 U.S.C.A.; N.Y.McKinney's CPLR 4503. 6. Witnesses o=>198(1) Existence of attorney-client privilege is based upon poli

aw firms will be sufficiently voluminous to minimize disclosure of the attorney's identification of some occasional wheat among the chaff."); In re Shell Oil, 125 F.R.D. at 134 ("it is highly unlikely that Shell will be able to discern the PLC's `theory of the case' or thought processes simply by knowing

esting the position of the United States on Defendant Jeffrey Epstein' s Motion to Stay Proceedings [DE 99). For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessary and was not contemplated by the Non-Prosecution Agreement between the United States and De

ted States, by and through the undersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein' s Motion to Stay Proceedings [DE 99). For the reasons set forth below, it is the United States' position that a stay o

this standard, Movants must show that invocation of the privilege in the instant matter will result in certain loss by automatic summary judgment. United Stalest Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "me

lent for fear of self incrimination in a parallel criminal proceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co.l Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regardini stays of civil action

esting the position of the United States on Defendant Jeffrey Epstein' s Motion to Stay Proceedings [DE 99). For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessary and was not contemplated by the Non-Prosecution Agreement between the United States and De

ted States, by and through the undersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein' s Motion to Stay Proceedings [DE 99). For the reasons set forth below, it is the United States' position that a stay o

this standard, Movants must show that invocation of the privilege in the instant matter will result in certain loss by automatic summary judgment. United Stalest Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "me

lent for fear of self incrimination in a parallel criminal proceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co.l Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regardini stays of civil action

sia. Longtime allies in Europe and in the Persian Gulf are worried by the inconsistency of a president who came to office promising the end of the United States' post-Sept. 11 wars. Now Ukraine has emerged as a test of Obama's argument that, far from weakening American power, he has enhanced it through smart

rgely in the hands of the European Union, given that its economic ties to Russia, particularly as a source of energy, are far greater than those of the United States. EFTA00705927 The most immediate threat that has surfaced: Obama could skip the G-8 meeting scheduled for June in Sochi, a day's drive from Crime

aifa and Caesarea. No luck. In 2007 the search for an American partner brought an Israel Petroleum Authority official to Houston and the offices of Shell Oil. It was a smart choice. Shell had been making breakthrough discoveries in how to produce oil from shale rock, thanks to its chief scientist, Harold

d criminal proceedings is warranted only when the defendant demonstrates that " `special circumstances' so require in the `interests of justice.' " United States'. Lot 5. Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the "special circumstances" which may support a stay are limited. Th

e Doe. 'In this regard, The Defendant's silence by invoking the Fifth Amendment does not prohibit adverse inferences against him in the civil case. Shell Oil, 866 F.Supp. at 40. - 3 - EFTA00222588 Case 9:08-cv-80119-KAM Document 82 Entered on FLSD Docket 04/23/2009 Page 4 of 9 defendant's right aga