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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
orts because "[a]bsent complete and honest reports, effective accident evaluation may be impaired and the prevention of future accidents hampered." Southern Railway Co. v. Lanham, 403 F.2d 119, 131 (5th Cir.1968). H. THE COMMON LAW MEDIATION PRIVILEGE It seems self-evident that no system of mediation can function
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
eports because (a)bsent complete and honest reports, effective accident evaluation may be impaired and the prevention of future accidents hampered. Southern Railway Co. v. Lanham, 403 F.2d 119, 131 (5th Cir.1968). H. The Common Law Mediation Privilege It seems self-evident that no system of mediation can function
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
orts because "[a]bsent complete and honest reports, effective accident evaluation may be impaired and the prevention of future accidents hampered." Southern Railway Co. v. Lanham, 403 F.2d 119, 131 (5th Cir.1968). H. THE COMMON LAW MEDIATION PRIVILEGE It seems self-evident that no system of mediation can function
Entities connected to both Jane Doe and Southern Railway Co.

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONLeon Black
PERSON
Jay Lefkowitz
PERSONMartin Weinberg
PERSONthe Eleventh Circuit
ORGANIZATIONHerman
PERSON
the Fifth Circuit
ORGANIZATIONSantobello
PERSONthe Northern District
LOCATION
Columbia University
LOCATIONAguirre-Gonzalez
PERSONJaffee
PERSON
Armstrong
PERSONFederal Rule of Criminal
ORGANIZATIONthe Second Circuit's
ORGANIZATIONPeterson
PERSONBlackledge v. Allison
PERSON