Epstein Secrets

block below. For all other questions, please call Joe Caruso. CC at (404) 335.6177. Sincerely, JOHN L

rs argued that the work-product privilege 5 EFTA00209389 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

block below. For all other questions, please call Joe Caruso. CC Sincerely, JOHN LEY, Clerk of Court

rs argued that the work-product privilege 5 EFTA00209430 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

B. Grant other such relief as is appropriate. /s! Joe Titone Joe Titone Attorney FL BAR #: 203882 621 S

r discovery of the correspondence between the U.S. and Epstein’s attorneys during the plea negotiations. Epstein’s attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that the

Grant other such relief as is appropriate. /s/ Joe Titone Joc Titone Attorney FL BAR #: 203882 6

r discovery of the correspondence between the M. and Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure I I create a privilege for plea negotiations, barring release of the correspondence. They also argued that t