Subject: Fw: Hearing Set for CVRA Case - August 12, 2011 at 2:00 p.m.
Summary
Subject: Fw: Hearing Set for CVRA Case - August 12, 2011 at 2:00 p.m. Date: Thu, 23 Jun 2011 21:10:58 +0000 Importance: Normal Let me know what you need from me. Mike Sent: Thu Jun 23 17:06:50 2011 Subject: Hearing Set for CVRA Case - August 12, 2011 at 2:00 p.m. Colleagues, Judge Marra has scheduled a hearing on the CVRA case for August 12, 2011, at 2:00 p.m. Dexter From: [email protected] [mailto:[email protected]] Sent: Thursday, June 23, 2011 4:58 PM To: flsd_cmecf [email protected] Subject: Activity in Case 9:08-cv-80736-KAM Doe I United States of America Order Setting Hearing on Motion This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of al
Persons Referenced (8)
“...ION for Sanctions, [56] MOTION to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz, [49] Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Their Fac...”
United States of AmericaUnited StatesJane Doe #1“...rvene of Roy Black, Martin Weinberg, and Jay Lefkowitz, [49] Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Their Facts Accepted Because of the Governmen...”
Roy Black“...ns: [79] MOTION to Intervene MOTION for Sanctions, [56] MOTION to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz, [49] Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Thei...”
Jane Doe #2“...ck, Martin Weinberg, and Jay Lefkowitz, [49] Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts, [51]...”
U.S. Attorney“...laintiff's MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence : Motion Hearing set for 8/12/2011 02:00 PM in West Palm Beach...”
Martin Weinberg“...TION to Intervene MOTION for Sanctions, [56] MOTION to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz, [49] Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Their Facts Acc...”
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EFTA DisclosureRelated Documents (6)
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-MarratIVIatthewman JANE DOE #1 AND JANE DOE #2, Petitioners, UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING THIRD SUPPLEMENTAL 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 Third Supplemental Privilege Log. The index has been marked with Bates Numbers P-014924 thru P-015267. The documents referenced in the Third Supplemental Privilege Log will be delivered tomorrow to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafafia A. MARIE VILLAFAFIA Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Ave, Suite 40
No. 13-12923
No. 13-12923 IN THE Iluiteb Mateo Court of appeato FOR THE ELEVENTH CIRCUIT JANE DOE NO. I AND JANE DOE NO. 2, 1. UNITED STATES OF AMERICA, ROY BLACK ET AL., Plaintiffs-Appellees Defendant-Appellee Intervenors-Appellants MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Bradley J. Edwards FARMER, JAFFEE, WEISSING EDWARDS, FISTOS & LEHRMAN, P.L. Paul G. Cassell S. J. Quinney College of Law at the University of Utah Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209567 CERTIFICATE OF INTERESTED PERSONS Pursuant to 11th Cir. R. 26.1, Jane Doe No. 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 A. 8. Howell, Jay 9. IMPIIPIS 10. Lefkowitz, Jay 11. Perczek, Jackie 12. libuilm.1 13. ra.c....
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true: 1. Between about 2001 and 2006, defendant Jeffrey Epstein (a—billienaire—with—signifteant politieal-eenneetiens)-sexually-abusedinere-than-40 enticed into prostitution minor girls at his mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually sed so enticed were Jane Doe #1 and Jane Doe #2. Because Epstein, through others, used a means of interstate commerce and knowingly traveled in interstate commerce to engage in this conduct, te-abuse-Jane-Dee-#4-en43ane-Dee-#2-(and-the-ether-vietims), he committed violations of federal law, specifically repeated violations of 18 U.S.C. § 2422. 2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Inves
No. 13-12923
No. 13-12923 IN THE Einiteb ibtateo Court of appeato FOR THE ELEVENTH CIRCUIT JANE DOE NO. 1 AND JANE DOE NO. 2, Plaintiffs-Appellees v. UNITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenors-Appellants MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Bradley J. Edwards FARMER, JAFFEE, WEISSING EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 [email protected] Paul G. Cassell S. J. Quinney College of Law at the University of Utah 332 S. 1400 E., Room 101 Salt Lake City, UT 84112 (801) 585-5202 [email protected] Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209355 CERTIFICATE OF INTERESTED PERSONS Pursuant to 11th Cir. R. 26.1, Jane Doe No. 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
CWECF - Live Database - flsd
CWECF - Live Database - flsd Page I of 24 WM U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80736-KAM Internal Use Only Doe . United States of America Assigned to: Judge Kenneth A. Marra Cause: no cause specified Date Filed: 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant Petitioner Jane Doe represented by Bradley James Edwards Fanner Jaffe Weissing Edwards Fistos & Lehrman PL I. Respondent United States of America Fax: 954-524-2822 Email: brad®pathtojustice.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Jay C. Howell Jay Howell & Associates PA Paul G. Cassell En e represented by https://ecf.fisd.circll.den/cgi-bin/DktRpt.p17818316027212123-L_1_0-1 6/27/2013 EFTA00209211 CM/ECF - Live Database - flsd Page 2 of 24 561-820-8711 Fax: 820-8777 LEAD ATTORNEY ATTORNEY TO BE NOTICED Intervenor Roy Black Black, Srebnick, Komspan & Stumpf, P.A. 2
II. ARGUMENT
II. ARGUMENT The work product doctrine is "an intensely practical one, grounded in the realities of litigation in our adversary system." United States'. Nobles 422 U.S. 225, 238 (1975).. Relying on Sporck Peil, 759 F.2d 312 (3d Cir. 1985), and its progeny, Plaintiff contends that the compilation of non-privileged documents by attorneys is "opinion work product," and seemingly asserts that the documents themselves, and not just the compilation, can be kept from the defense. These sweeping claims, belied as they are by the record in this case, should be rejected. A. The Supposedly Unassailable Sporck Plaintiff's Memorandum makes it appear as though the principle announced in Sporck has been accepted as gospel throughout the federal court system. Nothing could be further from the truth. Not only was Sporck a 2-1 decision with a strong dissent, later cases and commentators have criticized its expansion of the work product doctrine. In Sporck, a civil securities fraud case, th
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