Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Black, Martin

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to days of settlement/plea

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Black, Martin

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to days of settlement/plea

M Document 330 Entered on FLSD Docket 07/06/2015 Page 1 of 51 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. OPINION AND ORDER This cause is before the Court on various discovery re

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman I. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

e entered into a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for admissions, interrogatories and requests for production that were propounded on Defendant Epstein.

nsidered the facts alleged in the Complaints, the elements needed to convict Epstein of ' Rule 26(b)(3) was adopted in 1970 to codify the holding in Hickman I. Taylor, 329 U.S. 495 (1947). 10 EFTA00222437 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 11 of 14 a crime, the particul

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

been viewed as a `limitation on the trial court's broad discre- tion as to evidentiary questions at trial.' Ante, at 169. The problem discussed in Hickman I. Taylor arose precisely because, in addition to accelerating the time when a Page 19 party could obtain evidentiary matter from his adversary,PNI the new