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

federal courts to `continue the evolutionary development of [evidentiary] privileges.' Adkins g Christie, 488 F.3d 1324, 1328 (11th 2007), quoting Trammel I United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 41001s that the accused is encouraged candidly to discuss his or her situat

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

federal courts to `continue the evolutionary development of [evidentiary] privileges.' Adkins g Christie, 488 F.3d 1324, 1328 (11th 2007), quoting Trammel I United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 41001s that the accused is encouraged candidly to discuss his or her situat

ea negotiation letters and emails. The plaintiffs are mistaken. First, collateral estoppel requires identity of parties and no such identity exists. Jane Doe 1 and Jane Doe 2 in this CVRA case were not parties to the federal damages case from which the Magistrate Judge's order originated, and neither were t

ivilege," and to provide the court "with the flexibility to develop rules of privilege on a case-by-case basis, and leave the door open to change." Trammel, 445 U.S. at 47. Whatever the circumstances may be in other cases in the future, the facts of this case, when "interpreted in the light of reason an

Street. N.W. Adams. Georgia 30303 John Ley Ckrtof Cost April 18, 2014 MEMORANDUM TO COUNSEL OR PARTIES Appeal Number: 13.12923-CC Case Style: Jane Doe'. Roy Black District Court Docket No: 9:08-cv-80736-KAM Far rules arid loans silt fern till uscourts.spy This Court requires all counsel to file d

would achieve a `public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth.' Id. (quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912). The Supreme Court has identified several considerations relevant to whether a court should recognize an eviden

treet. N.W. Adams. Geosgia 30303 Mee Ley Clerk of Court April 18, 2014 MEMORANDUM TO COUNSEL OR PARTIES Appeal Number: 13.12923-CC Case Style: Jane Doe'. Roy Black District Court Docket No: 9:08-cv-80736-KAM Far tales arid loans silt Raw ell I mamas say This Court requires all counsel to file docu

would achieve a `public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth.' Id. (quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912). The Supreme Court has identified several considerations relevant to whether a court should recognize an eviden

trict of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane Doe No. I and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the United States and Epstein. On September 24, 2007,

would achieve a `public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth." Id. (quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912). The Supreme Court has identified several considerations relevant to whether a court should recognize an eviden

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 (

r was to provide the courts with the flexibility to develop rules of privilege on a case-by-case basis . . . and to leave the door open to change." Trammel, 445 U.S. at 47 (internal quotation marks omitted). In Jaffee v. Redmond, 518 U.S. 1 (1996), the Supreme Court explored the considerations which g

trict of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane Doe No. I and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the United States and Epstein. On September 24, 2007,

would achieve a `public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth.' Id. (quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912). The Supreme Court has identified several considerations relevant to whether a court should recognize an eviden