Epstein Secrets

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-

could be damaging to reputation and privacy. The government clearly has a substantial interest in preventing this sort of abuse of its processes. Seattle Times Co. v. Rhinehard, 467 U.S. 20, 35 (1984). The Eleventh Circuit has "repeatedly acknowledged the private nature of discovery" and that "[a] court may re

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-

could be damaging to reputation and privacy. The government clearly has a substantial interest in preventing this sort of abuse of its processes. Seattle Times Co. Rhinehard, 467 U.S. 20, 35 (1984). The Eleventh Circuit has "repeatedly acknowledged the private nature of discovery" and that "[a] court may rest

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

out its contents." Tillman v. C.R. Bard, Inc., Case No. 3:13-cv-222-J-34JBT (M.D. Fla. March 13, 2014), 2014 U.S. Dist. LEXIS 41406, at *6, quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 31 (1984) Placing limitations on the dissemination and use of pretrial discovery is particularly important since "[t]he