Epstein Secrets

ause it is more stringent than in other circuits. [DE 106 at 15]. The 1982 standard the plaintiffs accuse us of hiding was effectively overruled by the Supreme Court in Jaffee, a 1996 case we cited throughout our supplemental filing. Indeed, we referred to Jaffee as "perhaps the leading case addressing Rule 501 a

e elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality." DeBartolo Corp.. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988). One final matter must be addressed concerning Mr. Epstein's state court plea: During a hearing in this case, the Court a

t has made it abundantly plain that, whatever the outcome of this litigation, the agreement it made with Mr. Epstein will stand. indeed, controlling Supreme Court case law prevents it from doing otherwise. Mr. Epstein has fully performed his side of the bargain with the government, and when a bargain is based

elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality." DeBartolo Corp. v. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988). B. Recognition of a Privilege Under Rule 501. The Court rejected intervenors' contention that the Court should recogniz

t has made it abundantly plain that, whatever the outcome of this litigation, the agreement it made with Mr. Epstein will stand. Indeed, controlling Supreme Court case law prevents it from doing otherwise. Mr. Epstein has fully performed his side of the bargain with the government, and when a bargain is based

elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality." DeBartolo Corp. v. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988). B. Recognition of a Privilege Under Rule 501. The Court rejected intervenors' contention that the Court should recogniz