10
Shared Docs
10
Same-Page
15 / 10
Mentions
M, (USAFLS)" < wrote: Paul Cassell is eager to know what the government's position is on the intervenors' appeal to the Eleventh Circuit on Judge Marra's interlocutory order. If he is so sure the appellate court lacks jurisdiction, I wonder why it is so important to him that we endorse his argument.
e intervenors' appeal to the Eleventh Circuit on Judge Marra's interlocutory order. If he is so sure the appel
of DOD's position on interlocutory appeals is that they are notimnissible in these circumstances, particularly in light of Mohawk Industries, Inc. I Carpenter, 130 =. 599 (2009) (affirming 11th Circuit decision that an attorney-client rivilege order is not immediately appealable). As you probably know, E
eard anything back from you. Are you going to confer with us about this? And what is the government's position going to be? You will note that Judge Marra said yesterday that there is a "substantial question" about whether the denial of a motion for a protective order is immediately appealable under M
rnment's position going to be? You will note that Judge Marra said yesterday that there is a "substantial ques
DOD's position on interlocutory appeals is that they are not permissible in these circumstances, particularly in light of Mohawk Industries, Inc. I Carpenter, 130 S.C.t. 599 (2009) (affirming 11th Circuit decision that an attorney-client rivilege order is not immediately appealable). As you probably know
NS Pursuant to 11th Cir. R. 26.1, Intervenor/Appellants hereby certify that the following persons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo
. The prior civil discovery order relied upon by Judge Marra, DE188:3-4, resulted from the efforts of the civ
Appx. 286 (4th Cir. 2012), cert. denied, 133 S.Ct. 991 (2013) 55 *Missouri v. Frye, 132 S. Ct. 1399 (2012) 12, 35,36 Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009) 46, 47, 48, 49, 51 EFTA00209664 Case: 13-12923 Date Filed: 08/05/2013 Page: 9 of 75 Moulder v. State, 154 Ind. App. 248,
was at issue during the plea/settlement negotiations between his attorneys and the government. The prior civil discovery order relied upon by Judge Marra resulted from the efforts of the civil litigants to enhance their case through the mechanism of acquiring the target's attorney's communications wit
. The prior civil discovery order relied upon by Judge Marra resulted from the efforts of the civil litigants
on to hear their appeal under Perlman v. United States, 247 U.S. 7 (1918); contrary to plaintiffs' arguments, nothing in Mohawk Industries, Inc. v. Carpenter, 558 U .S. 100 (2009), undercuts the Court's exercise of Perhnan jurisdiction in this case. While the underlying CVRA action was commenced as an "e
sue during the plea/settlement negotiations between the targets' attorneys and the government. The prior civil discovery order relied upon by Judge Marra resulted from the efforts of the civil litigants to enhance their case through the mechanism of acquiring the target's attorney's communications wi
. The prior civil discovery order relied upon by Judge Marra resulted from the efforts of the civil litigants
hear their appeal under Perlman v. United States, 247 U.S. 7 (1918), and, contrary to plaintiffs' arguments, nothing in Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009), undercuts the Court's exercise of Perlman jurisdiction in this case. While the underlying CVRA action was commenced as an "e
UTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I AND JANE DOE 2, Plaintiffs
Opposition at 2-3. Intervenors did not, however, ignore controlling Supreme Court precedent, for the simple reason that Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009), does not affect the intervenors' ability to take an appeal from this Court's disclosure order. There are two EFTA00583454 i
o. 1 and Jane Doe No. 2, through undersigned counsel, hereby certifies that the following persons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo
C. Cir. 2013) 13, 17 Miccosukee Tribe of Indians of Florida v. United States, 516 F.3d 1235, 1265 (11th Cir. 2008) 21 Mohawk Industries, Inc. v. Carpenter, 130 S. Ct. 599 (2009) passim Nat'l Super Spuds, Inc. v. N.Y. Mercantile Exch., 591 F.2d 174, 178 (2d Cir.1979) 13 Perlman v. United States, 24
by Magistrate Judge Linnea Johnson in a discovery order entered in a parallel civil lawsuit, Jane Doe # 2'. Jeffrey Epstein, Case No. 08-80893-CIV- MARRA." (DE 188 at 3). This Court's decision to turn over the correspondence does not break new ground. Indeed, if anything, it would be new ground to hol
matic example of when interlocutory appeals are proper, the Supreme Court has recently and flatly concluded otherwise. In Mohawk Industries, Inc. I Carpenter, 130 S.Ct. 599 (2009), an opinion that immediately appears when performing basic research on this issue, the Supreme Court affirmed the Eleventh Ci
UTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I AND JANE DOE 2, Plaintiffs
Opposition at 2-3. Intervenors did not, however, ignore controlling Supreme Court precedent, for the simple reason that Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009), does not affect the intervenors' ability to take an appeal from this Court's disclosure order. There are two EFTA00583780 i
ect the strength of ow case, Case No. 08-80736-CV-MARRA P-011947 EFTA00226735 Ltd' tu0 .244CAIYU 0:r
ivity. Knowingly transport (or attempt) a minor to engage in sexual activity. 07- Sammy 4 18 U.S.C.S. 1591(a); Knowingly attempted to 20214 Carpenter, Darryl Jennings, Luroy Jennings 18 U.S.C.S. 2422(a) induce minor to engage in prostitution. 07- Nelson Cintron 3 18 U.S.C.S. Use of inteme
Entities connected to both Kenneth Marra and Carpenter

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSON
United States
LOCATIONJack Goldberger
PERSON
A. Marie Villafana
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONLeon Black
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONSouthern District
LOCATION
Jay Lefkowitz
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSONRoy Black
PERSON