Epstein Secrets

of Rule 408 are covered by a settlement privilege which insulates them not just from admission into evidence but from discovery as well. aLL, tl,g Goodyear Tire & Rubber Co. v. Chiles Power Stumlva Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to se

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth therein are incorporated

e, if this court rules that any of the information requested herein should be produced (e.g., Requests Numbers 12 and 13 (tax returns and passport — Jane Doe) and Request Number 1 (tax returns-Jane Doe 2-8)), it shall only do so after an in camera hearing allowing the documents to be reviewed and placed o

efendant's computers in case involving disciplinary proceedings brought against teacher for exchanging sexually explicit emails with students); d. Goodyear Tire & Rubber Co. v. Cooey 359 So. 2d 1200 (Fla. 1st DCA 1978) (quashing order permitting inspection of tire plant because plaintiff did not demonstrate that tires m

equest as true, photographing Epstein's genitalia could potentially provide a 'lead or clue' to evidence having a tendency to incriminate. 8. In Jane Doe No. 2 v. Epstein, Case No. 08-CIV-80119 MARRA/JOHNSON, the Court sustained Epstein's Fifth Amendment objections to several interrogatories a

& Health Plans, 16 F.Supp.2d 1164 (C.D.CaI. 1998) 33, 37, 40 Gill v. Gulfstream Park Racing Ass 'Ft, Inc., 399 F.3d 391 (1st Cir. 2005) 54 *Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v.

ver his strenuous objection, to produce documents given to him by the government during the course of his settlement/plea negotiations with it. See Jane Doe #2 v. Epstein, No. 08-80119-MARRA, Doc. 462. In response to that order, settlement negotiation correspondence authored by government prosecutors (

hapter." 18 U.S.C. § 3771(d)( I). 5 EFTA00211517 procedures, asserting a First Amendment right of access, and the courts denied such access. In Goodyear Tire & Rubber Co. I. Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit went further, finding that settlement communications were privileged a

ttend in person. PROCEDURAL HISTORY REGARDING INTERVENTION This action involves a petition filed on behalf of two individuals ("Jane Doe #1" and "Jane Doe #2") alleging that they were deprived of certain rights contained in the Crime Victims Rights act ("CVRA"), 18 U.S.C. § 3771, by the U.S. government