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to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiation
as all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps a record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming
to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context. The free availability in discovery to civil plaintiffs of communications
as all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps a record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming
to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiation
as all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps a record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming
to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context. The free availability in discovery to civil plaintiffs of communications
as all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps a record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming
Entities connected to both Goodyear Tire and U.S. Customs and Border Patrol

Jeffrey Epstein
PERSON
United States
LOCATION
Harry Reid
PERSONMartin Weinberg
PERSON
Jes Staley
PERSONSecond Circuit
ORGANIZATIONthe Southern District
LOCATIONJoe Recarey
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Samantha Power
PERSONJack Goldberger
PERSONMaria Farmer
PERSON
Paul Cassell
PERSONChiles Power Supply, Inc.
ORGANIZATION
Harvey Weinstein
PERSON
Jay Lefkowitz
PERSONBarrow
PERSONOur Court of Appeals
ORGANIZATION
Scarlett Johansson
PERSON