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purposes underlying Rule 408 are essentially the same as those underlying Rules ll(f) and 410: "to encourage non-litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (I Ith Cir. 1976). See, M-, Stockman v. Oakcrest Dental Center, P. C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose
des Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection und
derlying Rule 408 are essentially the same as those underlying Fed. R. Crim, P. 11 (f) and 410: "to encourage non- litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th Cir. 1976). See, Lls·, Stockman v. Oakcrest Dental Center, P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose
ocket entries. Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth t
cial efficiency it fosters is lost. Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003)(emphasis added)! See Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th The Federal Circuit declined to recognize a settlement negotiation privilege in In re MTSG, Inc., 675 F.3d 1337
ver his strenuous objection, to produce documents given to him by the government during the course of his settlement/plea negotiations with it. See Jane Doe #2 v. Epstein, No. 08-80119-MARRA, Doc. 462. In response to that order, settlement negotiation correspondence authored by government prosecutors (
Entities connected to both Reichenbach and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
United States
LOCATIONMaria Farmer
PERSON
Adam D. Horowitz
PERSON
Salt Lake City
LOCATIONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSONIsidro Manuel Garcia
PERSON
Jay Lefkowitz
PERSONMermelstein & Horowitz
ORGANIZATIONSpencer Kuvin
PERSON
Supreme Court
ORGANIZATION
Harvey Weinstein
PERSON
Bradley Cooper
PERSONSecond Circuit
ORGANIZATION
Justin Trudeau
PERSONSouthern District of Florida
LOCATION