Epstein Secrets

serDynamics, Inc. v. Quanta Computes; Inc., 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement agreement at trial); Apple, Inc. v. Samsung Electronics Co., Case No. 11-CV-01846-LHK (N.D. Cal. Nov. 7, 2013), 2013 U.S. Dist. LEXIS 160337, at **51-54 (barring parties from relyi

seeking protection." Id. 2. THE COMMON-LAW RIGHT OF ACCESS a. There Is No Common-Law Right To Access Materials Exchanged In Discovery Even though the Eleventh Circuit held that the plea and settlement negotiations in this case are subject to discovery, this Court has correctly ruled that there is no public common-

aserDynamics, Inc.'. Quanta Computer, Inc., 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement agreement at trial); Apple, Inc. Samsung Electronics Co., Case No. 11-CV-01846-LHK (N.D. Cal. Nov. 7, 2013), 2013 U.S. Dist. LEXIS 160337, at **51-54 (barring parties from relying

seeking protection." Id. 2. THE COMMON-LAW RIGHT OF ACCESS a. There Is No Common-Law Right To Access Materials Exchanged In Discovery Even though the Eleventh Circuit held that the plea and settlement negotiations in this case are subject to discovery, this Court has correctly ruled that there is no public common-

erDynamics, Inc. v. Quanta Computes; Inc., 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement agreement at trial); Apple, Inc. v. Samsung Electronics Co., Ltd., Case No. 11-CV-01846- LHK (N.D. Cal. Nov. 7, 2013), 2013 U.S. Dist. LEXIS 160337, at **51-54 (barring parties from

enors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the Eleventh Circuit. However, on April 14, 2014, the Eleventh Circuit affirmed the Court's rulings using the same rationales. -3- EFTA00605753 II. ARGUMENT Althoug