Epstein Secrets

Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 5 of 11 proceedings against the defendant making them under Rule 410. See e.g United States v. Paden, 908 F.2d 1229, 1235 (.5th Cir. 1990)(statements made during negotiations that resulted in a final plea of guilty not protected under Rule

ided only against "adversaries." Thus, disclosure of the material to an adversary, real or potential, works a forfeiture of work product protection. United States v. Massachusetts Institute of Technology, 129 F.3d 681 (1" Cir. 1997). In this case, Epstein's attorneys' disclosure to the United States Attorney's

324 (11' Cir. 2007Xdeclining to recognize medical peer review privilege in federal discrimination cases); Weiss ex rel. Estate of Weiss v. County of Chester, 231 F.R.D. 202 (E. D. Pa. 2005)(declining to recognize medical peer review privilege in §1983 action); Johnson v. United Parcel Service, Inc., 206

Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 5 of 11 proceedings against the defendant making them under Rule 410. See e.g United States v. Paden, 908 F.2d 1229, 1235 (5ih Cir. 1990)(statements made during negotiations that resulted in a final plea of guilty not protected under Rule

ided only against "adversaries." Thus, disclosure of the material to an adversary, real or potential, works a forfeiture of work product protection. United States v. Massachusetts Institute of Technology, 129 F.3d 681(1" Cir. 1997). In this case, Epstein's attorneys' disclosure to the United States Attorney's

24 (11ih Cir. 2007)(declining to recognize medical peer review privilege in federal discrimination cases); Weiss ex reL Estate of Weiss v. County of Chester, 231 F.R.D. 202 (E. D. Pa. 2005)(declining to recognize medical peer review privilege in §1983 action); Johnson v. United Parcel Service, Inc., 206

u./ 4-ittukt Case 7:16-cr-00832-KMK DocuerO nt 120a FlreMS9 l Pace / o zu loud Slew UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA SUPERSEDING INDICTMENT S4 16 Cr. 832 (KMK) NICHOLAS TARTAGLIONE, De

iled 04/16/19 Page 14 of 20 person, other than one of the participants in the offense, and the victim died as a direct result of the act (Title 18, United States Code, Section 3591(a)(2)(C)); e. intentionally and specifically engaged in an act of violence, knowing that the act created a grave risk of - deat

nded, induced, procured, and caused the intentional killing of Martin Luna, in and around a bar known as the Likquid Lounge at 69 Brookside Avenue, Chester, New York (the "Likquid Lounge"), and did aid and abet the same. (Title 21, United States Code, Section 848(e)(1)(A); Title 18, United States Code

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ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

nded, induced, procured, and caused the intentional killing of Martin Luna, in and around a bar known as the Likquid Lounge at 69 Brookside Avenue, Chester, New York (the "Likquid Lounge"), and did aid and abet the same. (Title 21, United States Code, Section 848(e)(1)(A); Title 18, United States Code

ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

nded, induced, procured, and caused the intentional killing of Martin Luna, in and around a bar known as the Likquid Lounge at 69 Brookside Avenue, Chester, New York (the "Likquid Lounge"), and did aid and abet the same. (Title 21, United States Code, Section 848(e)(1)(A); Title 18, United States Code