Epstein Secrets

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

al loyment ir. tunity practices, Banks v. Lockheed-Georgia Co., 53 . 283 .1971); to accounting records, New York Stock Exchange v. Sloan, 22 Fed.R.Serv.2d (Callaghan) 500 ( .1980); to securities law, In re Crazy Eddie Securities Litigation, 792 F.Supp. 197 li .1992); to academic peer reviews, Keyes

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

opportunity practices, Banks v. Lockheed-Georgia Co., 53 F.R.D. 283 (N.D.Ga.1971); to accounting records, New York Stock Exchange v. Sloan, 22 Fed.R.Serv.2d (Callaghan) 500 (S.D.N.Y.1980); to securities law, In re Crazy Eddie Securities Litigation, 792 F.Supp. 197 (E.D.N.Y.1992); to academic peer revie

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

al loyment ir. tunity practices, Banks v. Lockheed-Georgia Co., 53 . 283 .1971); to accounting records, New York Stock Exchange v. Sloan, 22 Fed.R.Serv.2d (Callaghan) 500 ( .1980); to securities law, In re Crazy Eddie Securities Litigation, 792 F.Supp. 197 li .1992); to academic peer reviews, Keyes

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

t=EleventhCircuit&destination... 9/26/2011 EFTA00178007 Page 1 of 27 Westlaw. 95 S.Ct. 2160 422 U.S. 225, 95 S.Ct. 2160, 45 L.Ed.2d 141, 20 Fed.R.Serv.2d 547 (Cite as: 422 U.S. 225, 95 S.O. 2160) Supreme Court of the United States Reversed. UNITED ST ES, Petitioner, Robert Lee NOBLES. No. 74-634