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

rn.aspx?rs=WLW11.07&pbc=BC6E23F9&destin... 9/26/2011 EFTA00177913 183 F.R.D. 458, 51 Fed. R. Evid. Serv. 35 (Cite as: 183 F.R.D. 458) 8A Wright, Miller & Marcus, Fed- eral Practice and Procedure § 2113 (2d ed.1994). There is contrary ( au- thority, however. ee, e.g. Omaha Pub. Power Dist. . Foster Wheeler

ida 3340) Facsimile- FACSIMILE COVER SHEET TO: JIM EISENBERG E_SQ. DATE: February 5, 2007 FAX NO. PHONE NO. # OP PAGES: FROM: ASSISTANT U. S . ATTORNEY PHONE NO. COMMENTS: 3(1/1_- &at- °L4191-fr\k' -61r ougar&cLau ' V IA P i t 'an t_ I t itifft attia 1 1'6 ffidgAgr. Case No. 08-80

T OF FLORIDA NORTHERN (WEST PALM BEACH) DIVISION FGJ NO. 07-103 (WPB) IN RE: GRAND JURY PROCEEDINGS / SEALED ORDER It is hereby ordered that the United States' Sealed Motion for Permission to Disclose Grand Jury Material and the Order granting same be SEALED until further Order of this Court, except that a

new grand jury has been tided and I have enclosed a new subpoena for= MI. As 1 mentioned earlier, Ms is not a target of this investigation and the United States seeks her testimony solely as a victim/winless. During our last conversation regarding Ms. , you indicated that she was unwilling to speak with us

F AMERICA, Respondent. UNITED STATES' NOTICE OF FILING PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto.

me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o

nd finds that the Government has submitted sufficient evidence to evaluate its claims of privilege. (See DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern I. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.)

DE 268 is hereby UNSEALED. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6ih day July, 2015. KENNETH A. MARRA United State District Judge 25 EFTA00210164 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 26 of 51 TABLE Detail of Privilege an

me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o

and finds that the Government has submitted sufficient evidence to evaluate its claims of privilege. L DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.)

E 268 is hereby UNSEALED. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 611' day July, 2015. KENNETH A. MARRA United State District Judge 25 EFTA_R1_0 1293460 EFTA02335922 Case 9 08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 26 of 51 TABLE Det

me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o

nd finds that the Government has submitted sufficient evidence to evaluate its claims of privilege. (See DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.)

DE 268 is hereby UNSEALED. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6ih day July, 2015. KENNETH A. MARRA United State District Judge 25 EFTA01657776 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 26 of 51 TABLE Detail of Privilege an

me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o

nexplicably poor decision when it decided not to prosecute Epstein. "[T]he Government retains 'broad discretion' as to whom to prosecute." Wayte v. United States, 470 U.S. 598, 607, 105 S. Ct. 1524, 84 L. Ed. 2d 547 (1985). The CVRA incorporates this principle, providing that "[n]othing in this chapter shall

me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o