Epstein Secrets

ral principle that all relevant evidence is admissible at trial, see Fed.R.Evid. 402, its limitations are not to be read broadly." United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005). The plain language of the rule is narrowly written to cover only a "statement made in the course of plea discussi

repackage their proposed privilege as a "common law mediation" privilege. Supplemental Briefing at 16. There is no need for such a privilege in the Southern District of Florida to protect true mediation. A local rule already protects confidentiality in court-annexed mediation. See Local Rule 16.2(G)(2). Epstein'

the mark. Any statements in the EVCP's files are unlikely to be inconsistent in light of the context in which they were made. See United States v. Barrow, 400 F.3d 109, 123 (2d Cir. 2005) (citing United States v. Strother, 49 F.3d 869, 875 (2d Cir. 1995) for the proposition that an omission in a prior

U.S. Department of Justice United States Attorney Southern District of New York The SihioJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 November 18, 2021 BY E-MAIL The Honorable Alison J. Na

sense because a "moving party must not only justify those depositions it wishes to take, but also the depositions it has already taken." Id. (citing Barrow v. Greenville Indep. Sch. Dist., 202 F.R.D. 480, 482 (N.D.Tex. 2001)). This rule is in place because "a party could indirectly circumvent the cap o

-07433-RWS Document 189 Filed 06/06/16 Page 10 of 11 associated with attending any deposition occurring outside 100 miles of the Courthouse for the Southern District of New York pursuant to S.D.N.Y L.Civ.R. 30.1. Dated: June 6, 2016. Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374)