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efta-efta00707709DOJ Data Set 9Other

From: Martin Weinberg

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DOJ Data Set 9
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efta-efta00707709
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EFTA Disclosure
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From: Martin Weinberg To: "Jeffrey E." [email protected]> Cc: Martin Weinberg Subject: ATTORNEY-CLIENT PRIVILEGE Date: Fri, 17 Apr 2015 22:32:19 +0000 With Alan's involvement in CVRA over, and with you not being a party to defamation case, and with an unpredictability as to how judges in Broward would rule on discovery demands for "common interest" emails particularly after the CVRA ruling of last week, be cautious what you email to Alan especially if its not a legal question to him as part of your legal team rather than a matter more relevant to his case. I still strongly believe that the basis for a common interest agreement exists given the overlapping attacks on you/he but you know better than I the uncertainty of discovery rulings in state court.. Martin G. Weinberg, Esq. 20 Park Plaza, Suite 1000 Boston, MA 02116 cell This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. On Fri, 4/17/15, jeffrey E. <[email protected]> wrote: EFTA00707709 Subject: Re: cvra To: "Martin Weinberg" cMINIM> Date: Friday, April 17, 2015, 5:17 PM On Fri, Apr 17, 2015 at 4:55 PM, Martin Weinberg -MINIM> wrote: Are you freefor 5 min callNumber? Sent from my iPhone On Apr 17, 2015, at 3:11 PM, "jeffrey E." leevacation®gmail.com> wrote: i agree, re jean luc, I m considering lettign him file the libel claim in london. he has damages. keeps me off the firing line at least temporiy On Fri, Apr 17, 2015 at 3:10 PM, Martin Weinberg -MINIM> wrote: I would not appealYou will probably not get stay and would probably lose! think the order sent a hard message to cassell Sent from my iPhone On Apr 17, 2015, at 2:30 PM, "jeffrey E." <[email protected]> wrote: not a good chance on appeal ?? On Fri, Apr 17, 2015 at 2:28 PM, Jack Goldberger la wrote: assume we are attempting to take interlocutory appeal of Maras order on the motion for protective order. However, he did make it clear he would police and treat harshly wholesale dumping of documents in the record that have no bearing on CVRA lawsuit against the US. Look at this order in conjunction with the last orde, r clear he is trying to keep all the sensational crap out of the record Jack Goldberge EFTA00707710 Phone Faz <image001 jpg> please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify EFTA00707711 us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00707712

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DOJ Data Set 9OtherUnknown

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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

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Plaintiffs I UNITED STATES, Defendants JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and request the defendant United States (hereinafter "the Government") to produce the original or best copy of the items listed herein below for inspection and/or copying, pursuant to the Court's Order (DE #99) directing discovery in this case. BACKGROUND As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48

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