Epstein Secrets

deral government prosecutorial authorities, are DENIED. DONE AND ORDERED in Chambers at West Palm Beach, Florida this 18th day of June, 2013. ,en Kenneth Marta United States District Judge cc. All counsel 11 EFTA00600064 Case 9:08-cv-80736-KAM Document 187 Entered on FLSD Docket 06/18/2013 Page 1 of 4

scriptive references to the grand jury material in question. DONE AND ORDERED in Chambers at West Palm Beach, Florida this 18"' day of June, 2013. Kenneth A. Marra United States District Judge cc. All counsel 4 EFTA00600068

oe # 2 v. Jeffrey Epstein, Case No. 08- 80893-CIV-MARRA. By order entered January 5, 2011 in that proceed

prosecutorial authorities investigating allegations against Epstein at that time, any work product protection was necessarily lost. See e.g. In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289 (6th Cir. 2002), cert. dismissed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 4

nd federal government prosecutorial authorities, are DENIED. DONE AND ORDERED in Chambers at West Palm Beach, Florida this 18ih day of June, 2013. Kenneth Marra United States District Judge cc. All counsel II EFTA00602817

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, petitioners, VS.

prosecutorial authorities investigating allegations against Epstein at that time, any work product protection was necessarily lost. See e.g. In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289 (6ih Cir. 2002), cert. dismissed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 4

2 of 24 Jane Doe v. Epstein Case No. 08-CV-80893-Marra/Johnson Epstein's Memorandum of Law in Oppositio

tion to Jane Doe's Injunction Motion Page 17 of24 would entitle her to an accounting; she just asks for one. See Florida Software Systems, Inc. v. Columbia/HCA Healthcare Corp., 46 F.Supp.2d 1276, 1285 (M.D. Fla. 1999) (holding that a party seeking an equitable accounting must show the existence of a fiduciary relationship

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED

Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question); In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289, 302 (6th Cir. 2002) (attorney client/work product privilege was "never designed to protect conversation