Epstein Secrets

: 1 of 25 No. 13-12923 IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT JANE DOE NO. 1 AND JANE DOES NO. 2, Plaintiffs-Appellees I. UNITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenor/Appellants INTERVENORS' RESPONSE TO MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Roy Black

to Mr. Epstein's attorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's counsel during the course of the negotiations. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100) at 2 ("To the knowledge of the government, the Jane Does have only r

nagement Dist., 647 F.3d 1296 (11th Cir. 2011) 14 6 18 Gill Gulfstream Park Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005) 13, 15, 19 Gotham Holdings, LPG. Health Grades, Inc., 580 F.3d 664 (7th Cir. 2009) 15 Holt-Orsted. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 10, 11, 15 In re Grand Ju

: 1 of 25 No. 13-12923 IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT JANE DOE NO. 1 AND JANE DOES NO. 2, Plaintiffs-Appellees I. UNITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenor/Appellants INTERVENORS' RESPONSE TO MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Roy Black

to Mr. Epstein's attorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's counsel during the course of the negotiations. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100) at 2 ("To the knowledge of the government, the Jane Does have only r

nagement Dist., 647 F.3d 1296 (11th Cir. 2011) 14 6 18 Gill Gulfstream Park Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005) 13, 15, 19 Gotham Holdings, LPG. Health Grades, Inc., 580 F.3d 664 (7th Cir. 2009) 15 Holt-Orsted. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 10, 11, 15 In re Grand Ju

v. Morgan State University, 495 Fed. Appx. 286, 289 (4th Cir. 2012); the Ninth Circuit has applied Perlman in a case arising under 28 U.S.C. §2255, United States v. Gonzalez, 669 F.3d 974, 977 n.2 (9th Cir. 2012), and in a civil case, S.E.C. v. CMKM Diamonds, Inc., 656 F.3d 829, 830-31 (9th Cir. 2011); the Si

d by the work product privilege, it stopped short of advocating the recognition of a settlement/plea negotiation privilege under Rules 410 and 501. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100). The government's institutional interests differ significantly from t

ury context, Opposition at 6, but a quick Westlaw search demonstrates that Perlman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. Health Grades, Inc., 580 F.3d 664, 665 (7th Cir. 2009)(civil case); United States v. Williams Cos., Inc., 562 F.3d 387, 392 (D.C.Cir. 2009)(

v. Morgan State University, 495 Fed. Appx. 286, 289 (4th Cir. 2012); the Ninth Circuit has applied Perlman in a case arising under 28 U.S.C. §2255, United States v. Gonzalez, 669 F.3d 974, 977 n.2 (9th Cir. 2012), and in a civil case, S.E.C. v. CMKM Diamonds, Inc., 656 F.3d 829, 830-31 (9th Cir. 2011); the Si

jury context, Opposition at 6, but a quick Westlaw search demonstrates that Penman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. 7 EFTA00583460 D. The United States is a Disinterested Third Party. Under the circumstances of this case, the government, contrary to pl

to Mr. Epstein's attorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's counsel during the course of the negotiations. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100) at 2 ("To the knowledge of the government, the Jane Does have only r

ry context, Motion at 16-17, but a quick Westlaw search demonstrates that Perlman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. Health Grades, Inc., 580 F.3d 664, 665 (7th Cir. 2009)(civil case); United States v. Williams Cos., Inc., 562 F.3d 387, 392 (D.C.Cir. 2009)(

to Mr. Epstein's attorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's counsel during the course of the negotiations. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100) at 2 ("To the knowledge of the government, the Jane Does have only r

ry context, Motion at 16-17, but a quick Westlaw search demonstrates that Perlman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. Health Grades, Inc., 580 F.3d 664, 665 (7th Cir. 2009)(civil case); United States v. Williams Cos., Inc., 562 F.3d 387, 392 (D.C.Cir. 2009)(