Epstein Secrets

r filed charges against Jeffrey Epstein or any other person involved in criminal activity with Ms.M. 14. In the Jane Doe suit, U.S. District Judge Kenneth A. Marra allowed limited discovery. Exhibits 1 and 2 were listed on a privilege log and provided to Judge Marra in camera for review. The United States asse

Jane Doe suit, U.S. District Judge Kenneth A. Marra allowed limited discovery. Exhibits 1 and 2 were listed on a privilege log and provided to Judge Marra in camera for review. The United States asserted that the items should not be produced because they were governed by Fed. R. Crim. P. 6(e) and incl

2 were listed on a privilege log and provided to Judge Marra in camera for review. The United States asserted

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

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

rials prepared by an attorney `acting for his client in anticipation of litigation,"' United States v. Nobles, 422 U.S. 225, 237-38 (1975), quoting Hickman v. Taylor, 329 U.S. 495, 508 (1947), which applies in both civil and criminal litigation: Although the work-product doctrine most frequently is asserted as a

mas & LoCicero PL, Tampa, FL. JUDGES: KENNETH A. MARRA, United State District Judge. OPINION BY: KENNET

ami, FL. For The Palm Beach Post, Palm Beach Daily News, Intervenors: Rachel Elise Fugate, LEAD ATTORNEY, Thomas & LoCicero PL, Tampa, FL. JUDGES: KENNETH A. MARRA, United State District Judge. OPINION BY: KENNETH A. MARRA OPINION OPINION AND ORDER This cause is before the Court on various discovery related

"it is essential that a lawyer work with a certain r 161 degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510, 67 S. Ct. 385, 91 L. Ed. 451 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a part

Order at DE 326; DE 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

, Florida, this 611' day July, 2015. KENNETH A. MARRA United State District Judge 25 EFTA_R1_0 12934

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

Order at DE 326; 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 o

y, Florida, this 6ih day July, 2015. KENNETH A. MARRA United State District Judge 25 EFTA01657776

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

')007, at West Palm Beach. Florida. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE cc: William L. Ri

Jury Subpoenas and Cross Motion to Compel is deemed timely filed. DONE AND ORDERED in chambers this day of , ')007, at West Palm Beach. Florida. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE cc: William L. Richey. Esquire Roy Black. Esquire EFTA00178973 (Rev. 06/2005)Sealcd Document Tracking Form Corr

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modern work- product doctrine, holding that: [lin performing his various duties, how

tion is GRANTED. DONE AND ORDERED in chambers this day of , 2007, at West Palm Beach, Florida. cc: AUSA Roy Black, Esq. William Richey, Esq. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE West Palm Beach EFTA00179097 (Rev. 06/2005)Seakd Document Tracking Form UNITED STATES DISTRICT COURT Southern Dis

Roy Black, Esq. William Richey, Esq. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE West Palm Beach E

ain hidden in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor, 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re

UTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs,

litigation.' United States v. Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman v. Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawyer is bou

UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY

So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing, Hickman v. Taylor, 329 U.S. 495, 501, 507 (1947). 14. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes, Inc. v. Brandsmart U.S