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-

that "[a] court may restrict distribution of discovery material even if there 'certainly is a public interest in knowing more' about 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. Rhine

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

Thus, "[a] court may restrict distribution of discovery material even if there `certainly is a public interest in knowing more' about 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. Rhine

", to the extent discernable, every case brought under §2422(b) in this district includes use of the intemet. There are only four reported cases in the Eleventh Circuit involving use of the phones only: three of them concern telephone calls to travel agencies advertising overseas underage sex touriand involved expli

, S. Ct. 1338 (2006); United States' Orrega, 363 F.3ds1093 (11th Cir. 2004); United States Miranda, 348 F.3d 1322 (11th Cir. 2003); United States I Tillman, 195 F.3 640 (11th Cir. 1999); United States , Pali!, supra, 338 F. d 1299 (11'h Cir. 2003); United States Garrett, 190 F.3 1220 (11th Cir. 1999);