Epstein Secrets

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

at a therapist's ability to help a patient "is completely dependent" upon the patient's "willingness and ability to talk freely." Id. at 10, quoting Advisory Committee's Notes to Proposed Rules, 56 F.R.D. 183, 242 (1972). The Court found that the psychotherapist-patient privilege is "rooted in the imperative need fo

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

ability to help a patient "is completely EFTA00301870 dependent" upon the patient's "willingness and ability to talk freely." Id. at 10, quoting Advisory Committee's Notes to Proposed Rules, 56 183, 242 (1972). The Court found that the psychotherapist-patient privilege is "rooted in the imperative need for confi

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

ability to help a patient "is completely EFTA00301893 dependent" upon the patient's "willingness and ability to talk freely." Id. at 10, quoting Advisory Committee's Notes to Proposed Rules, 56 183, 242 (1972). The Court found that the psychotherapist-patient privilege is "rooted in the imperative need for confi

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

at a therapist's ability to help a patient "is completely dependent" upon the patient's "willingness and ability to talk freely." Id. at 10, quoting Advisory Committee's Notes to Proposed Rules, 56 F.R.D. 183, 242 (1972). The Court found that the psychotherapist-patient privilege is "rooted in the imperative need fo