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

ossi City of Memphis, 423 F.3d 596 (6th Cir. 2007) 18 passim 14 passim 13, 15 S.E.C. I. CMKA1 Diamonds, Inc., 656 F.3d 829 (9th Cir. 2011) 15 Sheet Metal Workers Intern. I Sweeney, 29 F.3d 120 (4th Cir.1994) 15 United States' Gonzalez, 669 F.3d 974 (9th Cir. 2012) 14 United States' Krane, 625 F.3d 568 (9th Cir.

: 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

ossi City of Memphis, 423 F.3d 596 (6th Cir. 2007) 18 passim 14 passim 13, 15 S.E.C. I. CMKA1 Diamonds, Inc., 656 F.3d 829 (9th Cir. 2011) 15 Sheet Metal Workers Intern. I Sweeney, 29 F.3d 120 (4th Cir.1994) 15 United States' Gonzalez, 669 F.3d 974 (9th Cir. 2012) 14 United States' Krane, 625 F.3d 568 (9th Cir.

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

City of Memphis, 423 F.3d 596, 599-600 (6th Cir. 2007); Gill v. Gulfstream Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)(civil case); Sheet Metal Workers Intern. v. Sweeney, 29 F.3d 120, 212 (4th Cir.1994)(civil case). 8 EFTA00583787 represented a private individual under criminal investigation by the go

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

ss v. City of Memphis, 423 F.3d 596, 599-600 (6th Cir. 2007); Gill v. Gulfstream Park Racing= Inc.., 399 F.3d 391, 398 (1st Cir. 2005)(civil case); Sheet Metal Workers Intern. v. Sweeney, 29 F.3d 120, 212 (4th Cir.1994)(civil case). 8 EFTA00583461 not the privilege for which intervenors contend would, if recognized, e

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

City of Memphis, 423 F.3d 596, 599-600 (6th Cir. 2007); Gill v. Gulfstream Park Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)(civil case); Sheet Metal Workers Intern. v. Sweeney, 29 F.3d 120, 212 (4th Cir.1994)(civil case). 15 EFTA00583774 D. The United States is a Disinterested Third Party. Under the circu

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

ity of Memphis, 423 F.3d 596, 599-600 (6th Cir. 2007); Gill v. Gulfstream Park Racing Ass '?7, Inc., 399 F.3d 391, 398 (1st Cir. 2005)(civil case); Sheet Metal Workers Intern. v. Sweeney, 29 F.3d 120, 212 (4th Cir.1994)(civil case). 16 EFTA00584618 government and who sought, though full and frank exploration of the fa