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

l Rules of Civil Procedure Rule 24 United States Code Annotated Currentness Federal Rules of Civil Procedure for the United States District Courts (Refs & Annos) Kui Title IV. Parties Rule 24. Intervention (a) Intervention of Right.On timely motion, the court must permit anyone to intervene who: (1) is gi

employee as the source of the information. (2) Appearance. A former employee makes an appearance when he is physically present before an employee of the United Slates, in either a formal or informal setting. Although an appearance also may be accompanied by certain communications, an appearance need not involve an

ecified in paragraphs (fXI) (i) through (f)(l)(iv) of this section, e.g., as when a former employee directs remarks to an employee representing the United Slates as a party or intervenor in a Federal or non-Federal judicial proceeding. A Conner employee does not direct his communication or appearance to a bys

id not participate as a Government employee. Example 7 to paragraph (hX2): An employee of the Department of State participated in the development of the United States' position with respect to a proposed treaty with a foreign government concerning transfer of ownership with respect to a parcel of real property and

esolving prisoner disputes. Construing the CVRA in the way that "See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States v. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United St

e Personnel Chapter XVI. Office of Government Ethics Subchapter B. Government Ethics Part 2641. Post-Employment Conflict of Interest Restrictions (Refs & Annos) Subpart B. Prohibitions 5 C.F.R. § 2641.201 § 2641.201 Permanent restriction on any former employee's representations to United States concernin

the University of Pennsylvania Law School. 4. After graduating from law school, I served as judicial law clerk to the Honorable Norma L. Shapiro, Unites' States District Judge for the Eastern District of Pennsylvania. 5. In 1988, I began working at the Criminal Division of the United States Department of

bstantially in the matter. (j) United States is a party or has a direct and substantial interest— (1) United States. For purposes of this paragraph, the "United States" means: (i) The executive branch (including a Government corporation); (ii) The legislative branch; or (iii) The judicial branch. WestlavvNexe ©

partment of Justice about Epstein, and (3) Movant did not use confidential information obtained during his Government employment to the detriment of the United States. See Declaration of Bruce E. Reinhart at ¶111-12, 17. Rather than conducting the required inquiry, Plaintiffs simply make two irresponsible and uns

e Personnel Chapter XVI. Office of Government Ethics Subchapter B. Government Ethics Part 2641. Post-Employment Conflict of Interest Restrictions (Refs & Annos) Subpart B. Prohibitions 5 C.F.R. § 2641.201 § 2641.20i Permanent restriction on any former employee's representations to United States concernin

the University of Pennsylvania Law School. 4. After graduating from law school, I served as judicial law clerk to the Honorable Norma L. Shapiro, Unites' States District Judge for the Eastern District of Pennsylvania. 5. In 1988, I began working at the Criminal Division of the United States Department of

bstantially in the matter. (j) United States is a party or has a direct and substantial interest— (1) United States. For purposes of this paragraph, the "United States" means: (i) The executive branch (including a Government corporation); (ii) The legislative branch; or (iii) The judicial branch. WestlavvNexe ©

partment of Justice about Epstein, and (3) Movant did not use confidential information obtained during his Government employment to the detriment of the United States. See Declaration of Bruce E. Reinhart at ¶111-12, 17. Rather than conducting the required inquiry, Plaintiffs simply make two irresponsible and uns

e Personnel Chapter XVI. Office of Government Ethics Subchapter B. Government Ethics Part 2641. Post-Employment Conflict of Interest Restrictions (Refs & Annos) Subpart B. Prohibitions 5 C.F.R. § 2641.201 § 2641.20i Permanent restriction on any former employee's representations to United States concernin

employee as the source of the information. (2) Appearance. A former employee makes an appearance when he is physically present before an employee of the United Slates, in either a formal or informal setting. Although an appearance also may be accompanied by certain communications, an appearance need not involve an

id not participate as a Government employee. Example 7 to paragraph (hX2): An employee of the Department of State participated in the development of the United States' position with respect to a proposed treaty with a foreign government concerning transfer of ownership with respect to a parcel of real property and

esolving prisoner disputes. Construing the CVRA in the way that "See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United Stat

e Personnel Chapter XVI. Office of Government Ethics Subchapter B. Government Ethics Part 2641. Post-Employment Conflict of Interest Restrictions (Refs & Annos) Subpart B. Prohibitions 5 C.F.R. § 2641.201 § 2641.201 Permanent restriction on any former employee's representations to United States concernin

t trial. No more; no less." 2 EFTA00192643 U.S. Department of Justice United States Attorney Southern District of Florida Ft ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Ave, 14'h Floor Miami, FL 33131 Re: Jeffrey Epstein D

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

Effective:(See Text Amendments) West's Florida Statutes Annotated Currentness Title XLVI!. Criminal Procedure and Corrections (Chapters 900-999) (Refs & Annos) Chapter 951. County and Municipal Prisoners (Refs & Annos) 951.24. Extend the limits of confinement for county prisoners Page 1 (1) Any cotinty

at trial. No more; no less." 2 EFTA00183432 U.S. Department of Justice United States Attorney Southern District of Florida R ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Aye, le Floor Miami, FL 33131 Re: Jeffrey Epstein Dear

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

C Effective:Pee Text Amendments] West's Florida Statutes Annotated Currentness Title XLVII. Criminal Procedure and Corrections (Chapters 900-999) (Refs & Annos) Chapter 951. County and Municipal Prisoners (Refs & Annos) 951.24. Extend the limits of confinement for county prisoners (I) Any county shall be

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor a

Effective:fSee Text Amendments) West's Florida Statutes Annotated Currentness Title XLVII. Criminal Procedure and Corrections (Chapters 900-999) (Refs & Annos) Chapter 951. County and Municipal Prisoners (Refs & Annos) 951.24. Extend the limits of confinement for county prisoners (1) Any county shall be

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

Effective:ISee Text Amendments] West's Florida Statutes Annotated Currentness Title XLVII. Criminal Procedure and Corrections (Chapters 900-999) (Refs & Annos) Chapter 951. County and Municipal Prisoners (Refs & Annos) 951.24. Extend the limits of confinement for county prisoners (1) Any county shall be

e* does work :here and the reply was affirmative. MILITARY SERVICE I Asked the Person Spoken to whether defendant was in active military service of the United States or of the State of New York in any capacity whatever, and received a negative reply The source of my information and the grounds of my belief are th

ctice Law and Rules (Refs & Annosl ill Chapter Eight. Of the Consolidated Laws Article 3. Jurisdiction and Service, Appearance and Choice of Court !Refs & Annos) Si 311. Personal service upon a corporation or governmental subdivision (a) Personal service upon a corporation or governmental subdivision shall