Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true

ensued between the United States and Epstein. Despite the investigation revealing that Epstein had molested more than 40 minor girls, in Late 2007, the United Stales entered into a non- prosecution agreement (NPA) with Epstein - esseNiatly egree:ng to immunize Epstein for al of the Federal Sex crimes he committed

copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The-rietifieation4id-net

on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the

t argument: Disclosure of work-product materials to an adversarywaives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settlem

plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha

o power to compel the custodian of the material to risk a contempt citation for his refusal to comply" (internal quotation marks omitted)); Overby. United States Fid. & Guar. Co., 224 F.2d 158, 162 & n.5 (5th Cir. 1955) (exercising interlocutory jurisdiction and citing Perlman in a civil action to recover damage

a privilege); Krane, 625 F.3d at 572 (ruling that "Perlman and Mohawk are not in tension" when the claimant of a privilege is not a party). But see United States'. Copar Pumice Co., Inc., 714 F.3d 1197, 1207-09 (10th Cir. 2013) (holding that jurisdiction under the Perlman doctrine is limited to only the grand

erroneous. Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settl

plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha

ims intend to use the correspondence against the United States, not against Epstein. Rule 410 "create[s], in effect, a privilege of the defendant," United States' Mezzanatto, 513 U.S. 196, 205, 115 S. Ct. 797, 803 (1995) (internal quotation marks and alteration omitted), but not a privilege of non-disclosure

erroneous. Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settl

plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha

ims intend to use the correspondence against the United States, not against Epstein. Rule 410 "create[s], in effect, a privilege of the defendant," United States' Mezzanatto, 513 U.S. 196, 205, 115 S. Ct. 797, 803 (1995) (internal quotation marks and alteration omitted), but not a privilege of non-disclosure

erroneous. Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settl

rring admission of plea negotiations; the alleged victims intended to admit the evidence of the plea negotiations to prove violations of the CVRA by the United States, not to be used against the alleged perpetrator. Fed.Rules Evid.Rule 410, 28 U.S.C.A. [12] Federal Civil Procedure 170A f=1604(2) 170A Federal Civ

s. United States I. Cartwright, 413 F.3d 1295, 1299 (11th Cir.2005). We also review de novo the interpretation of the Federal Rules of Evidence. See United States I. Campa, 459 F.3d 1121, 1174 (11th Cir.2006); Pickett I. Iowa Beef Processors, 209 F.3d 1276, 1279 (11th Cir.2000). And the issue of whether to r

lea negotiations is not work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir.1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir.1981). Even if it shared the common goal of reaching a quick settle

familiar with this basic principle. Specifically, in Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014), it was Edwards who argued that the United States failed to confer with his clients before entering a non-prosecution agreement with Epstein. Edwards' clients had sought to discover correspondence b

erroneous. Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settl

plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha

erroneous. Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settl