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-

20 Park Plaza Suite 1000 Boston, MA 02116 Telephone: (617) 227-3700 Fax: (617) 338-9538 By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 [email protected] On behalf of Jeffrey Epstein 17 EFTA00600031 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page

DOE 2, 1. Plaintiffs, UNITED STATES OF AMERICA, : Defendant. EPSTEIN'S REPLY IN SUPPORT OF SUPPLEMENTAL PROTECTIVE ORDER There is no doubt that the Eleventh Circuit has held that Epstein's plea negotiation and settlement communications are not privileged. We acknowledged this throughout our initial filing. Howe

r No. 0042201 jperczek@ royblack.com On behalf of Jeffrey Epstein MARTIN G. WEINBERG, P.C. By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 owlmgw @att.net On behalf of Jeffrey Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was filed by my of

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-

Bar No. 0042201 [email protected] On behalf of Jefrey Epstein MARTIN G. WEINBERG, P.C. By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 [email protected] On behalf of Jay Epstein 17 EFTA00210733 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 18 o

pon learning that the Court would consider rescission in fashioning the remedy in this case (assuming, of course, that plaintiffs Courts, including the Eleventh Circuit, have recognized the propriety of intervention to litigate remedy. See, e.g., Benjamin ex reL Yock v. Department of Public Welfare, 701 F.3d 938 (3

ARTIN G. WEINBERG, ■. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 By: _/s/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 11 EFTA00617890

DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, : Defendant. EPSTEIN'S REPLY IN SUPPORT OF SUPPLEMENTAL PROTECTIVE ORDER There is no doubt that the Eleventh Circuit has held that Epstein's plea negotiation and settlement communications are not privileged. We acknowledged this throughout our initial filing. Howe

Suite 1000 Boston, MA 02116 Telephone: (617) 227-3700 EFTA00583387 Fax: (617) 338-9538 By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 [email protected] On behalf of Jay Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was filed by my office