Epstein offers no argument for extending the Perlman doctrine into the new context of crime victims' rights cases, much less a persuasive one. 3. The Documents Are Not Held By a Disinterested Third Party Litigant, But By a Party in the Case. 6 EFTA00209605 Case 9:08-cv-80736-KAM Document 198 Entered on FLSD Docket 0