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

ant. Indeed, so inactive were plaintiffs that the district court dismissed the case for lack of prosecution sua sponte in September, 2010. Doc. 38. See Order Denying Government's Motion to Dismiss (Doc. 189) at 5 ("Over the course of the next eighteen months, the CVRA case stalled as petitioners pursued collateral civil claims agai

: 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

ant. Indeed, so inactive were plaintiffs that the district court dismissed the case for lack of prosecution sua sponte in September, 2010. Doc. 38. See Order Denying Government's Motion to Dismiss (Doc. 189) at 5 ("Over the course of the next eighteen months, the CVRA case stalled as petitioners pursued collateral civil claims agai

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

3771(dX3), in favor of pursuing civil settlement actions against Mr. Epstein prior to, rather than concurrently with, litigating their CVRA rights. See Order Denying Government's Motion to Dismiss (Doc. 189) at 5 ("Over the course of the next eighteen months, the CVRA case stalled as petitioners pursued collateral civil claims agai

reement). 5 EFTA00617884 Case 9:08-cv-80736-KAM Document 207 Entered on FLSD Docket 07/08/2013 Page 6 of 11 from contesting liability.; See also United States' Reply in Support of Its Motion to Dismiss for Lack of Subject Matter Jurisdiction (Doc. 205-6), Exhibit F at 11-12 (detailing reliance of plaintiff

motion, the government contended, inter alia, that the remedy of rescission of the non-prosecution agreement was prohibited on due process grounds. See Order Denying Government's Motion to Dismiss for Lack of Subject Matter Jurisdiction (Doc. 189) at 6-7. It was not until June 19, 2013, that the Court denied the motion and indicated

imants due in significant part to the requirements of the non-prosecution agreement that prohibited Mr. Epstein from contesting liability? See also United States' Reply in Support of Its Motion to Dismiss for Lack of Subject Matter Jurisdiction (Doc. 205-6), Exhibit F at 11-12 (detailing reliance of plaintiffs

motion, the government contended, inter alia, that the remedy of rescission of the non-prosecution agreement was prohibited on due process grounds. See Order Denying Government's Motion to Dismiss for Lack of Subject Matter Jurisdiction (Doc. 189) at 6-7. It was not until June 19, 2013, that the Court denied the motion and indicated