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apply the correct legal standard and follow the proper procedures in determining whether a protective order should issue. See Chicago Tribune Co. v. Bridgestone/Firestone, Inc. 263 F.3d 1304, 1309 (I I th Cir. 2001). A. Legal Standard Intervenor Epstein argues that the proper legal standard is the "good cause" standard
ons and settlement communications have no tradition of being publically accessible," and that "serious Sixth Amendment implications," the spirit of Federal Rule of Evidence 410, and the "environment of confidentiality" fostered by 10 EFTA00606597 Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page
apply the correct legal standard and follow the proper procedures in determining whether a protective order should issue. See Chicago Tribune Co. v. Bridgestone/Firestone, Inc. 263 F.3d 1304, 1309 (I I th Cir. 2001). A. Legal Standard Intervenor Epstein argues that the proper legal standard is the "good cause" standard
ons and settlement communications have no tradition of being publically accessible," and that "serious Sixth Amendment implications," the spirit of Federal Rule of Evidence 410, and the "environment of confidentiality" fostered by 10 EFTA00674425 Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page
ture of discovery" Looney I Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11'1' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process because the litigants and the court
y of the correspondence between the United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the
Entities connected to both Bridgestone/Firestone, Inc. and Federal Rule of Evidence 410

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSONLeon Black
PERSONRoy Black
PERSON
Kenneth Marra
PERSONMartin Weinberg
PERSON
United States
LOCATIONthe Southern District
LOCATION
Paul Cassell
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSONFBI
ORGANIZATION
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSON
Chris Christie
PERSON
Donald Trump
PERSONJack Goldberger
PERSONthe Eleventh Circuit Court of Appeals
ORGANIZATIONSrebnick
PERSON