Epstein Secrets

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be

dence will remain confidential until the court has had an adequate opportunity to review the materials and enter a ruling. -2- FOWUUt WERE BURNETT, PS. • AMASS POINT - WEST TOWER, SUITE 901, 777 SO01N ELAOLER BEM, WIM PALM BUREN, FLORIDA 33401 • (561) 8020044 EFTA00206610 Case 9:08-cv-80893-KAM Document 2

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be

dence will remain confidential until the court has had an adequate opportunity to review the materials and enter a ruling. -2- FOWUUt WERE BURNETT, PS. • AMASS POINT - WEST TOWER, SUITE 901, 777 SO01N ELAOLER BEM, WIM PALM BUREN, FLORIDA 33401 • (561) 8020044 EFTA00213903 Case 9:08-cv-80893-KAM Document 2

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be

dence will remain confidential until the court has had an adequate opportunity to review the materials and enter a ruling. -2- FOWUUt WERE BURNETT, PS. • AMASS POINT - WEST TOWER, SUITE 901, 777 SO01N ELAOLER BEM, WIM PALM BUREN, FLORIDA 33401 • (561) 8020044 EFTA00235287 Case 9:08-cv-80893-KAM Document 2