Epstein Secrets

ult in a disposition of the charges in the next several days." [CVRA Petition, DE 1, 13]. Claiming to be wrongfully excluded from those discussions, Jane Doe 1 asserted the violation of her CVRA rights to confer with federal prosecutors; to be treated with fairness; to receive timely notice of relevant cou

ntiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence Jane Doe #1 and Jane Doe &filed by United States of America. (Lee, Dexter) (Entered: 05/30/2011) 06/17/2011 fd Notice of Supplemental Authority ma& Plaintiffs MOTION for Sum

uccess on appeal. 5 EFTA00177820 unrestrained candor which produces effective plea discussions between the . .. government and the . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

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

o permit the 10 EFTA00205369 unrestrained candor which produces effective plea discussions between the . .. government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

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

o permit the 10 EFTA00205349 unrestrained candor which produces effective plea discussions between the . .. government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LE

im.P. I I (eX6) is to permit the unrestrained candor which produces effective plea discussions between the . . . government and the ... defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

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

using the evidence "against" him. The words "not ... admissible against the defendant" refer to "the purpose for which [the evidence] is offered." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, 77 F.R.D. 507, 538 (February 1978) (emphasis added). The plaintiffs' technical argum

ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negotiations as substantive evidence in their quest to inva

0 and 11(e)(6) is to permit the unrestrained candor which produces effective plea discussions between the ... government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 . 507, GET PAGE (February

ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non- Prosecution Agreement [DE 51], as well as their motion t

0 and 11(e)(6) is to permit the unrestrained candor which produces effective plea discussions between the ... government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 . 507, GET PAGE (February

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

Crim.P. 11(eX6) is to permit the unrestrained candor which produces effective plea discussions between the . . . government and the ... defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)