Epstein Secrets

Motion at and cases cited therein. The single case cited by plaintiff, Northeastern Florida Chapter of of Gen. Contractors of America v. City of Jacksonville, 896 F.2d 1283 (11th Cir. 1990), did not involve privileged or confidential communications but instead the question whether the plaintiff had demons

nors have already fully addressed this issue, including this Court's reasoning, in their Motion at . As they pointed out there, in United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement, not to state charges as here, renderin

d irreparably — if the victims read the correspondence. See, e.g., Northeastern Florida Chapter of Ass 'rt of General Contractors of America City of Jacksonville, Fla., 896 F.2d 1283, 1286 (11th Cir. 1990) ("Because plaintiff presented no evidence on the issue, we cannot agree that irreparable injury is `app

. . . which are inadmissible in proceedings against the defendant making them under Rule 410." DE 188 at 5 (emphasis added) (citing United States' Paden, 908 F.2d 1229, 1235 (5th Cir. 1990) (statements made during negotiations that resulted in a final plea of guilty not protected under Rule 410), ce

ll be injured if the victims read the correspondence. See, e.g., Northeastern Florida Chapter of Ass'n of General Contractors of America I. City of Jacksonville, Fla., 896 F.2d 1283, 1286 (11th Cir. 1990) ("Because plaintiff presented no evidence on the issue, we cannot agree that irreparable injury is "app

a guilty plea . . . .' which are inadmissible in proceedings against the defendant making them under Rule 410." (DE 188 at 5) (citing United States' Paden, 908 F.2d 1229, 1235 (5th Cir. 1990) (statements made during negotiations that resulted in a final plea of guilty not protected under Rule 410), ce

22 Email: bradepathtojustice coin LEAD ATTORNEY ATTORNEY TO BE NOTICED Jay C. Howell Jay Howell &Associates PA 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Email: [email protected] PRO HAC VICE ATTORNEY TO BE NOTICED Paul G. Cassell Email: PRO HAC VICE ATTORNEY TO BE NOTICED represented

ounsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

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15-17, and cases cited therein. The single case cited by plaintiff, Northeastern Florida Chapter of Ass'n of Gen. Contractors of America v. City of Jacksonville, 896 F.2d 1283 (11th Cir. 1990), did not involve privileged or confidential communications but instead the question whether the plaintiff had demons

rs have already fully addressed this issue, including this Court's reasoning, in their Motion at 6-9. As they pointed out there, in United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement, not to state charges as here, renderin