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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'
(1) Federal Rule of Evidence 410 or (2) a purported "common law privilege" for "plea negotiations" that the attorneys ask the Court to create under Federal Rule of Evidence 501. The defense arguments are meritless for multiple, independent reasons. With regard to Rule 410, the defense attorneys' efforts to invoke Rule 410
EFTA00186707 U.S. Departme A- Justice U.S. Department of Justice United States Attorney Southern District of Florida Grand Jury Coordinator State Attorney's Office 15th Judicial Circuit of Florida West Palm Beach, Florida Re: Federal Grand Jury Subp
naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela
to pay such costs (28 USC 1825, Rule 17(b) Federal Rules of Criminal Procedure)" EFTA00186750 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 DELIVERY BY FACSIMILE Denise Coffman, Esq. Counsel to the Clerk of Cou
naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court fords this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela
5g: al 9l49 5/ if 3,w/a EFTA00277550 UU/U0, ,CUU0 ZU:41 rAA 001OULII01 UbAU Orb ty trJUUZ U.S. Department of Justice United States Attorney Southern District of Florida September 6, 2006 DELIVERY BY FACSIMILE Denise Coffman, Esq. Counsel to the Clerk of Court and Comptroller 15th Judicial Circuit of F
naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela
aterial) Descri don: r 9 EFTA01699656 09/06/2006 20:41 FAX 5618021787 USA° WPB FL i3002 U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY FACSIMILE est alm Beac F on. a Re: Federal Grand Jury Subpoena Dear 500 South Australian Ave., Suite 400 West Palm Beac
naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela
Entities connected to both Southern District and Federal Rule of Evidence 501

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONJane Doe
PERSON
Alexander Acosta
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Paul Cassell
PERSONLeon Black
PERSON
George W. Bush
PERSON
Michael Cohen
PERSONFBI
ORGANIZATIONMartin Weinberg
PERSON
Scarlett Johansson
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSON
Julie K. Brown
PERSONMaria Farmer
PERSON
David Boies
PERSON