Epstein Secrets

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

at the party puts its muscles to work to perform with full energy and fairness the relevant express promises and reasonable implications therefrom." Stabile v. Stabile, 774 N.E.2d 5 EFTA00178103 Case 9:08-cv-80736-KAM Document 76 Entered on FLSD Docket 05/02/2011 Page 6 of 11 673, 676 (Mass. App. Ct. 2002). Th

s" language have routinely recognized that this language can create affirmative obligations to act. See, e.g., Hughes Communications Galaxy, Inc. v. United States, 26 Cl. Ct. 123, 135 (1992) ("A best efforts clause . . . can also affirmatively obligate."). Here, the action that is affirmatively required by the

at the party puts its muscles to work to perform with full energy and fairness the relevant express promises and reasonable implications therefrom." Stabile v. Stabile, 774 N.E.2d 673, 676 (Mass. App. Ct. 2002). Here, far from putting its full energies towards protecting victims' their rights, the U.S. Attorney's

s" language have routinely recognized that this language can create affirmative obligations to act. See, e.g., Hughes Communications Galaxy, Inc. v. United States, 26 Cl. Ct. 123, 135 (1992) ("A best efforts clause . . . can also affirmatively obligate."). Here, the action that is affirmatively required by the

at the party puts its muscles to work to perform with full energy and fairness the relevant express promises and reasonable implications therefrom." Stabile v. Stabile, 774 N.E.2d 673, 676 (Mass. App. Ct. 2002). Here, far from putting its full energies towards protecting victims' their rights, the U.S. Attorney's

ners argue that the Court should accept their Statement as true, despite its conclusory allegations and internal inconsistencies, solely because of the United States' failure to stipulate to the Statement. The Court should deny the motion because: (1) Petitioners have misstated that United States' efforts at reach

at the party puts its muscles to work to perform with full energy and fairness the relevant express promises and reasonable implications therefrom." Stabile v. Stabile, 774 N.E.2d 673, 676 (Mass. App. Ct 2002). Here, far from putting its full energies towards protecting victims' their rights, the U.S. Attorney's O