Epstein Secrets

Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG

and trust," and because their confidentiality serves significant public and private ends, they are properly subject to a common law privilege under Federal Rule of Evidence 501. Similar privileges, which are "rooted in the imperative need for confidence and trust" and which serve significant public and private ends, have b

Document 169 Entered on FLSD Docket 04/23/2012 Page 1 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, 1. Plaintiffs, UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENOR

ications, either written or oral, made during the course of a mediation. Our decision whether to apply this mediation privilege .. . is governed by Federal Rule of Evidence 501 [and] Jaffee'. Redmond, 518 U.S. 1 (1996) . . . Recognizing that only those documents prepared for purposes of the confidential mediation are prote

Document 106 Entered on FLSD Docket 10/10/2011 Page 1 of 27 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE O

(1) Federal Rule of Evidence 410 or (2) a purported "common law privilege" for "plea negotiations" that the attorneys ask the Court to create under Federal Rule of Evidence 501. The defense arguments are meritless for multiple, independent reasons. With regard to Rule 410, the defense attorneys' efforts to invoke Rule 410

ted States District Judge cc. All counsel 4 EFTA00177810 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERN Liac, 14-1 \ftPPEAL , Intervenors Roy 1 Jeffrey Epstein

ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges." Adkins v. Christie, 488 F.3d 1324, 132

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. [FNI] FNI. The background and focus of the federal grand Jury investigation is set forth in greater detail in an la camera submission of facts su

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. (FN1) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in cantera submission of facts s

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court fords this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

hat certain officers of the Buffalo Police Department violated federal criminal civil tights laws during and after the arrest of Mr. Aiken and Mr. Johnson. [FN I) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in COMM submission of facts sur

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENORS' MOTION FOR STAY PENDING APPEAL Intervenors Roy Black

ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges!" Adkins v. Christie, 488 F.3d 1324, 132

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. (F141) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in camera submission of facts s

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. IFNI] FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in camera submission of facts su

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela