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ed Mr. Epstein's rights and privileges, Mr. Epstein and his counsel intervened to assert their rights, both in the district court, and on appeal to the Eleventh Circuit. See Doe No. 1, supra. That there would be no judgment against Mr. Epstein at the end of this CVRA litigation, however, was understood throughout t
is a disagreement between two contracting parties, courts cannot simply re-write agreements between them to change the terms. Cf. United States v. Fernandez, 960 F.2d 771, 773 (9'h Cir. 1991) (district court erred in rejecting one paragraph of the plea agreement rather than accepting or rejecting the en
pen exchange of information to promote significant private and public interests. They are: the decision of Judge Marcus, before he was appointed to the Eleventh Circuit, denying discovery and recognizing a privilege for airline pilots who report incidents and violations, In Re Air Crash Near Cali, Colombia, 959 F.
to persuade the judge or the jury is ... far less important than his ability to persuade the prosecutor" during plea negotiations. United States'. Fernandez, 2000 WL 534449 (S.D.N.Y. May 3, 2000) at *1 . Counsel's failure to discharge his duties during plea negotiations is malpractice: "[l]t is malprac
pen exchange of information to promote significant private and public interests. They arc: the decision of Judge Marcus, before he was appointed to the Eleventh Circuit, denying discovery and recognizing a privilege for airline pilots who report incidents and violations, In Re Air Crash Near Cali, Colombia, 959 F.
to persuade the judge or the jury is .. . far less important than his ability to persuade the prosecutor" during plea negotiations. United States'. Fernandez, 2000 WL 534449 (S.D.N.Y. May 3, 2000) at *1. Counsel's failure to discharge his duties during plea negotiations is malpractice: "Mt is malpractic
ain language, the NPA has no application to prosecutors in other judicial districts, such as the Southern District of New York. See United States v. Fernandez, No. 17-CR- 167 (JMF), 2017 WL 6372783 at *2 (S.D.N.Y. 2017) ("The Second Circuit has squarely held that "[w]hen the express terms of a plea agreeme
Page: EFTA00021447 →. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that
Page: EFTA00021451 →ain language, the NPA has no application to prosecutors in other judicial districts, such as the Southern District of New York. See United States v. Fernandez, No. 17-CR- 167 (JMF), 2017 WL 6372783 at *2 (S.D.N.Y. 2017) ("The Second Circuit has squarely held that "[w]hen the express terms of a plea agreeme
Page: EFTA00022551 →. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that
Page: EFTA00022555 →Entities connected to both the Eleventh Circuit and Fernandez

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Scarlett Johansson
PERSON
Bradley Edwards
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSONthe Southern District
LOCATIONJack Goldberger
PERSON
George W. Bush
PERSON
Paul Cassell
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSON
Julie K. Brown
PERSON
A. Marie Villafana
PERSON
Supreme Court
ORGANIZATIONMartin Weinberg
PERSON