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-

1 (S.D. Ohio May 14, 2013), 2013 U.S. Dist. LEXIS 68349 (denying motion to compel discovery of settlement agreement on relevancy grounds); Duncan,. Phoenix Supported Living, Inc., No. 2:05-cv-1 (W.D.N.C. Sept. 12, 2006), 2006 US. Dist. LEXIS 66742, at "9-11 (finding settlement communications non-discoverable as "not .. likely

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-

(S.D. Ohio May 14, 2013), 2013 U.S. Dist. LEXIS 68349 (denying motion to compel discovery of settlement agreement on relevancy grounds); Duncan v. Phoenix Supported Living, Inc., No. 2:05-cv-1 (W.D.N.C. Sept. 12, 2006), 2006 US. Dist. LEXIS 66742, at "9-11 (finding settlement communications non-discoverable as "not .. likely

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

(S.D. Ohio May 14, 2013), 2013 U.S. Dist. LEXIS 68349 (denying motion to compel discovery of settlement agreement on relevancy grounds); Duncan v. Phoenix Supported Living, Inc., No. 2:05cvl W.D. ( N.C. Sept. 12, 2006), 2006 U.S. Dist. (continued...) -5- EFTA00605755 rarely admissible as evidence at trial, see, e.g, Lase