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

TA00177878 Case 9:08-cv-80736-KAM Document 93 Entered on FLSD Docket 09/02/2.011 Page 2 of 9 See El-Ad Residences at Miramar Condo. Ass'''. Inc. I Mt. Hawley Ins. Co., 716 F. Supp. 2d 1257, 1262 (S.D. Fla. 2010), quoting In re Grand Jury Subpoena (Newparent Inc.), 274 F.3d 563, 570 (1st Cir. 2001) (in the co

zier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock v. United Slates, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside the grand jury ro

he Court's earlier finding. The Government also candidly admits that since then "the delay from October 28, 2010 through early March 2011 was due to the United States' efforts to reach [an] amicable resolution of the case . . . .. Gov't Resp. at 46 n.22. 9 The CVRA does not appear to impose specific timelines for v

ring before Epstein and Groff that had nothing to do with the inner workings of the grand jury. There is abundant caselaw to that effect. See, e.g., United States v. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blal

ubstantial, legally protectable interest in the proceedings." Purcell v. Bank/Mantic Financial Corp., 85 F.3d 1508, 1512 (I I th Cir. 1996); accord Mt. Hawley Ins. Co. v. Sandy Lake Properties, Inc., 425 F.3d 1308 (1Ith Cir. 2005). The The defense attorneys have not claimed that they should be permitted to int

Reach, FL 33401 (56!) 82047/! rocssmile: (561)820-8777 September 3, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WIT

here he could get passports or other travel documents for young girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United States for sexual purposes and farm them out to his friends, including Epstein. 49. Brunel would offer the girls "modeling" jobs. A lot of the girls came

agent's ensuing report. Rodriguez "discussed in detail the information contained within the book. and identified important information to the UCE." See United States'. Rodriguez, No. 9:1 0-cr- 800I5-KAM. DE 3 at 5 (S.D. Fla. Dec. 9, 2009). While all of the details of the verbal information explained by Rodriguez t

tervention by a person who has "a claim or defense that shares with the main action a common question of law or fact." Fed. R. Civ. P. 24(b); accord Mt. Hawley Ins. Co. Sandy Lake Properties, Inc., 425 F.3d 1308, 1311 (1Ith Cir. 2005) (permissive intervention allowed only where "a claim or defense and the mai

lies. In any event, it is obvious that grand jury secrecy only extends to matters that occurred in secret before the grand jury. See, e.g., Blalock. United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside the grand jury roo

substantial, legally protectable interest in the proceedings." Purcell I BankAtlantic Financial Corp., 85 F.3d 1508, 1512 (11th Cir. 1996); accord Mt. Hawley Ins. Co.l Sandy Lake Properties, Inc., 425 F.3d 1308 (11th Cir. 2005). The The defense attorneys have not claimed that they should be permitted to inter