EFTA00209600Set 9
2013-06-2816p4,515w
denied a motion to quash a grand jury subpoena directed at a disinterested third party,
non-litigant, leaving the privilege holder powerless to remedy harm from disclosure. Perlman's
reasoning ... Perlman permits a privilege-
holder to appeal a disclosure order directed at a disinterested third party . . . .") (emphasis
added). We are aware of no case (and Epstein cites none) in which ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209600.pdf
EFTA01098146Set 9
2013-06-2817p4,747w
denied a motion to quash a grand jury subpoena directed at a disinterested third party,
non-litigant, leaving the privilege holder powerless to remedy harm from disclosure. Perlman's
reasoning ... Perlman permits a privilege-
holder to appeal a disclosure order directed at a disinterested third party . . . .") (emphasis
added). We are aware of no case (and Epstein cites none) in which ... 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
EFTA01098151
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098146.pdf
EFTA01143529Set 9
2013-06-2817p4,700w
denied a motion to quash a grand jury subpoena directed at a disinterested third party,
non-litigant, leaving the privilege holder powerless to remedy harm from disclosure. Perlman's
reasoning ... Perlman permits a privilege-
holder to appeal a disclosure order directed at a disinterested third party . . . .") (emphasis
added). We are aware of no case (and Epstein cites none) in which ... 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
EFTA01143534
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA01143529.pdf
EFTA01128707Set 9
2013-07-0228p5,886w
denied a
motion to quash a grand jury subpoena directed at a disinterested third party, non-
litigant, leaving the privilege holder powerless to remedy harm from disclosure ... Perlman permits a privilege-holder to
appeal a disclosure order directed at a disinterested third party . . . .") (emphasis
added)). We are aware of no case (and Epstein cited none below ... take an interlocutory appeal is that this is
not a situation where a disinterested third party has the correspondence in question.
Instead, the correspondence is held by a party
https://www.justice.gov/epstein/files/DataSet%209/EFTA01128707.pdf
EFTA00209567Set 9
2007-09-2428p5,531w
denied a
motion to quash a grand jury subpoena directed at a disinterested third party, non-
litigant, leaving the privilege holder powerless to remedy harm from disclosure ... Perlman permits a privilege-holder to
appeal a disclosure order directed at a disinterested third party . . . .") (emphasis
added)). We are aware of no case (and Epstein cited none below ... take an interlocutory appeal is that this is
not a situation where a disinterested third party has the correspondence in question.
Instead, the correspondence is held by a party
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209567.pdf
EFTA00209355Set 9
2007-09-2428p5,591w
denied a
motion to quash a grand jury subpoena directed at a disinterested third party, non-
litigant, leaving the privilege holder powerless to remedy harm from disclosure ... Perlman permits a privilege-holder to
appeal a disclosure order directed at a disinterested third party . . . .") (emphasis
added)). We are aware of no case (and Epstein cited none below ... take an interlocutory appeal is that this is
not a situation where a disinterested third party has the correspondence in question.
Instead, the correspondence is held by a party
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209355.pdf
EFTA00583454Set 9
13p3,972w
nder the . . .Perlman doctrine, a discovery order directed at a disinterested third party is
treated as an immediately appealable final order because the third party presumably lacks a
sufficient stake ... Gotham Holdings, LP v.
7
EFTA00583460
D. The United States is a Disinterested Third Party.
Under the circumstances of this case, the government, contrary to plaintiffs' argument,
Opposition
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583454.pdf
EFTA00209465Set 9
2013-07-1225p5,673w
Limited to the Grand Jury Context 14
D. The United States is a Disinterested Third Party 15
III. INTERVENORS WILL SUFFER INJURY IF THE
PRIVILEGED AND CONFIDENTIAL CORRESPONDENCE
IS DISCLOSED ... nder the . . . Perlman doctrine, a discovery order directed at a
disinterested third party is treated as an immediately appealable final order because
the third party presumably lacks a sufficient stake ... which
plaintiffs argue simply does not exist.
D. The United States is a Disinterested Third Party.
Under the circumstances of this case, the government, contrary to plaintiffs'
argument, Motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209465.pdf
EFTA00209534Set 9
2013-07-1225p5,708w
Limited to the Grand Jury Context 14
D. The United States is a Disinterested Third Party 15
III. INTERVENORS WILL SUFFER INJURY IF THE
PRIVILEGED AND CONFIDENTIAL CORRESPONDENCE
IS DISCLOSED ... nder the . . . Perlman doctrine, a discovery order directed at a
disinterested third party is treated as an immediately appealable final order because
the third party presumably lacks a sufficient stake ... which
plaintiffs argue simply does not exist.
D. The United States is a Disinterested Third Party.
Under the circumstances of this case, the government, contrary to plaintiffs'
argument, Motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209534.pdf
EFTA01072169Set 9
2013-07-1225p5,750w
Limited to the Grand Jury Context 14
D. The United States is a Disinterested Third Party 15
III. INTERVENORS WILL SUFFER INJURY IF THE
PRIVILEGED AND CONFIDENTIAL CORRESPONDENCE
IS DISCLOSED ... nder the . . . Perlman doctrine, a discovery order directed at a
disinterested third party is treated as an immediately appealable final order because
the third party presumably lacks a sufficient stake ... which
plaintiffs argue simply does not exist.
D. The United States is a Disinterested Third Party.
Under the circumstances of this case, the government, contrary to plaintiffs'
argument, Motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA01072169.pdf
EFTA00583780Set 9
15p4,660w
nder the . . . Perlman doctrine, a discovery order directed at a disinterested third party is
treated as an immediately appealable final order because the third party presumably lacks a
sufficient stake ... which plaintiffs argue simply
does not exist.
D. The United States is a Disinterested Third Party.
Under the circumstances of this case, the government, contrary to plaintiffs' argument,
Opposition
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583780.pdf
EFTA00583760Set 9
2008-07-1120p5,068w
nder the . . . Perlman doctrine, a discovery order
directed at a disinterested third party is treated as an immediately appealable final
order because the third party presumably lacks a sufficient stake ... Cir.1994)(civil case).
15
EFTA00583774
D. The United States is a Disinterested Third Party.
Under the circumstances of this case, the government, contrary to plaintiffs'
argument, Motion at 17, should
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583760.pdf
EFTA00584603Set 9
2008-07-1121p5,110w
nder the . . . Perlman doctrine, a discovery order
directed at a disinterested third party is treated as an immediately appealable final
order because the third party presumably lacks a sufficient stake ... which plaintiffs argue
simply does not exist.
D. The United States is a Disinterested Third Party.
Under the circumstances of this case, the government, contrary to plaintiffs'
argument, Motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584603.pdf