5
Shared Docs
5
Same-Page
11 / 5
Mentions
plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha
o power to compel the custodian of the material to risk a contempt citation for his refusal to comply" (internal quotation marks omitted)); Overby. United States Fid. & Guar. Co., 224 F.2d 158, 162 & n.5 (5th Cir. 1955) (exercising interlocutory jurisdiction and citing Perlman in a civil action to recover damage
a privilege); Krane, 625 F.3d at 572 (ruling that "Perlman and Mohawk are not in tension" when the claimant of a privilege is not a party). But see United States'. Copar Pumice Co., Inc., 714 F.3d 1197, 1207-09 (10th Cir. 2013) (holding that jurisdiction under the Perlman doctrine is limited to only the grand
the privilege asserted by appellants is without a basis in Florida law" and that appellants "have no privilege of nondisclosure under state law"); Rossi City of Memphis, 423 F.3d 596,599 (6th Cir. 2005) ("[Perlman] jurisdiction does not depend on the validity of the appellant's underlying claims for reli
plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha
ims intend to use the correspondence against the United States, not against Epstein. Rule 410 "create[s], in effect, a privilege of the defendant," United States' Mezzanatto, 513 U.S. 196, 205, 115 S. Ct. 797, 803 (1995) (internal quotation marks and alteration omitted), but not a privilege of non-disclosure
the privilege asserted by appellants is without a basis in Florida law" and that appellants "have no privilege of nondisclosure under state law"); Rossi City of Memphis, 423 F.3d 596,599 (6th Cir. 2005) ("[Perlman] jurisdiction does not depend on the validity of the appellant's underlying claims for reli
plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha
ims intend to use the correspondence against the United States, not against Epstein. Rule 410 "create[s], in effect, a privilege of the defendant," United States' Mezzanatto, 513 U.S. 196, 205, 115 S. Ct. 797, 803 (1995) (internal quotation marks and alteration omitted), but not a privilege of non-disclosure
the privilege asserted by appellants is without a basis in Florida law" and that appellants "have no privilege of nondisclosure under state law"); Rossi City of Memphis, 423 F.3d 596,599 (6th Cir. 2005) ("[Perlman] jurisdiction does not depend on the validity of the appellant's underlying claims for reli
: 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
Inc.. Carpenter, 558 U.S. 100 (2009) Overby,. U.S. Fidelity & Guar. Co., 224 F.2d 158 (11th Cir. 1955) Perlman' United States, 247 U.S. 7 (1918) Rossi 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 Met
: 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
Inc.. Carpenter, 558 U.S. 100 (2009) Overby,. U.S. Fidelity & Guar. Co., 224 F.2d 158 (11th Cir. 1955) Perlman' United States, 247 U.S. 7 (1918) Rossi 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 Met
Entities connected to both United States and Rossi City

Jeffrey Epstein
PERSON
George W. Bush
PERSONthe Southern District
LOCATIONLeon Black
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Southern District of New York
ORGANIZATION
Michael Cohen
PERSONRoy Black
PERSON
Supreme Court
ORGANIZATION
Bradley Cooper
PERSONNadia Marcinkova
PERSON
Alberto Gonzales
PERSON
Adriana Ross
PERSONO'Brien
PERSON