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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
al courts to `continue the evolutionary development of [evidentiary] privileges." Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007), quoting Trammel v. United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 410 "is that the accused is encouraged candidly to discuss his or her situation in order to
red on FLSD Docket 06/18/2013 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARFCA JANE DOE #1 and JANE DOE #2, petitioners, vs. UNITED STATES OF AMERICA, respondent. ORDER GRANTING PETITIONERS' MOTION TO PROFFER GOVERNMENT CORRESPONDENCE IN SUPPORT O
13 Page 8 of 11 interests to outweigh the need for probative evidence."Jaffee v. Redmond, 518 U.S. 1, 9-19,116 S. Ct.1923, 135 L.Ed. 2d 337 (1996); Trammel v. United States, 445 U.S. 40, 47,100 S. Ct. 906, 63 L.Ed.2d 186 (1980). Recognizing that there is a presumption against privileges which may be overcome only whcn
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,
F.2d at 1004. Although Congress empowered the federal courts through Rule 501 to "continue the evolutionary development of testimonial privileges," Trammel v. United States, 445 U.S. 40, 47, 100 S. Ct. 906, 910 (1980), we disfavor newly minted privileges, which "contravene the fundamental principle that the public has
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 (
, 682 N.W.2d 578 (Minn. 2004) 43 State v. Boggs, 741 N.W.2d 492 (Iowa 2007) 42 State v. Trujillo, 93 N.M. 724, 605 P.2d 232 (N.M.1980) 43 Trammel v. United States, 445 U.S. 40 (1980) 29, 45 United States v. Al-Arian, 514 F.3d 1184 (11th Cir.), cert. denied, 555 U.S. 887(2008) 16 United States v. Castan
ered on FLSD Docket 06/18/2013 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, petitioners, VS. UNITED STATES OF AMERICA, respondent. ORDER GRANTING PETITIONERS' MOTION TO PROFFER GOVERNMENT CORRESPONDENCE IN SUPPORT O
Page 8 of 11 interests to outweigh the need for probative evidenc,e."Jaffee v. Redmond, 518 U.S. 1, 9-19, 116 S. Ct.1923, 135 L.Ed. 2d 337 (1996); Trammel v. United States, 445 U.S. 40, 47, 100 S. Ct. 906, 63 L.Ed.2d 186 (1980). Recognizing that there is a presumption against privileges which may be overcome only whe
d Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and Disclosure of Plea Negotiations (Doc. 162); Notice of Supplemental Authority of the United States Supreme Court (Doc. 163);
al courts to `continue the evolutionary development of [evidentiary] privileges!" Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007), quoting Trammel v. United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 410 "is that the accused is encouraged candidly to discuss his or her situation in order to
over 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. Once the CVRA action was re-activated — after plaintiffs had successfully pursued their civil monetary
l courts to `continue the evolutionary development of [evidentiary] privileges.'" Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007), quoting Trammel v. United States, 445 U.S. 40, 47 (1980). The Supreme Court has recognized that "Rules 410 and 11(e)(6) `creat[e], in effect, a privilege of the defendant . . . ."'
d Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and Disclosure of Plea Negotiations (Doc. 162); Notice of Supplemental Authority of the United States Supreme Court (Doc. 163);
al courts to `continue the evolutionary development of [evidentiary] privileges!" Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007), quoting Trammel v. United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 410 "is that the accused is encouraged candidly to discuss his or her situation in order to
Entities connected to both Jane Doe and Trammel v. United States

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATIONRoy Black
PERSON
Jay Lefkowitz
PERSONMartin Weinberg
PERSON
Donald Trump
PERSONFBI
ORGANIZATIONChambers
PERSONthe Eleventh Circuit
ORGANIZATION
Julie K. Brown
PERSON