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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 Jeffrey Epstein opposes the motion of Jane Doe 1 and Jane Doe 2 for dislcosure of all the
f Counsel Whether to negotiate a plea or contest a criminal charge is ordinarily the most important single decision in any criminal case. Soria v. Keane, 99 F.3d 492 (DATE). In the age of the Sentencing Guidelines, with the draconian sentences called for in federal criminal cases, minimum mandatorie
a second day. The New York bank, the nation's largest, has been sued by the government of the U.S. Virgin Islands and two women, both identified as Jane Doe, who say they were abused by Epstein. The lawsuits contend JPMorgan should have seen evidence of Epstein's sex trafficking and avoided profiting fr
taff Writer), Associated Press (04/18, Staff Writer), Axios (04/18, Knutson), CNN (04/18, Halasz), NBC News (04/18, Talmazan), New York Post (04/18, Keane), The Hill (04/18, Mueller), Washington Examiner (04/18, Brest), BBC News (04/18, Rosenberg, Kim), Reuters (04/18, Faulconbridge, Osborn), USA TODAY
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);
l includes counsel's informed opinion as to what pleas should be entered." United States v. Villar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Boria v. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992). Counsel also has a constit
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);
l includes counsel's informed opinion as to what pleas should be entered." United States v. Villar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Boria v. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992). Counsel also has a constit
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
unsel includes counsel's informed opinion as to what pleas should be entered." United Stalest Pillar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Borial. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992). Counsel also has a consti
Entities connected to both Jane Doe and Keane

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSONSouthern District
LOCATION
Salt Lake City
LOCATION
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Virginia Giuffre
PERSONRoy Black
PERSON