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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
counsel to discuss matters in an uninhibited fashion often leading to settlement ...." Id. at 930. Ten years later, in Folb v. Motion Picture hid. Pension & Health Plans, 16 F.Supp.2d 1164, 1998), the district court in California became the first federal court to adopt the mediation privilege as federal common law
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
counsel to discuss matters in an uninhibited fashion often leading to settlement ...." Id. at 930. Ten years later, in Folb v. Motion Picture hid. Pension & Health Plans, 16 F.Supp.2d 1164, 1998), the district court in California became the first federal court to adopt the mediation privilege as federal common law
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
of liberty, he has an even greater "need for confidentiality and trust between participants in a [plea negotiation]." Folb v. Motion Picture Indus. Pension & Health Plans, 161 F.Supp.2d 1164, 1175 (M. Cal. 1998).Discovery and use of plea negotiations will cause "a meaningful and irreparable chill" to the "frank and c
Entities connected to both Jane Doe and Pension & Health Plans

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONLeon Black
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSONMartin Weinberg
PERSONthe Eleventh Circuit
ORGANIZATIONHerman
PERSON
Bradley Cooper
PERSONEmmy Taylor
PERSON
the Fifth Circuit
ORGANIZATIONthe Northern District
LOCATIONSantobello
PERSON
Columbia University
LOCATIONJaffee
PERSONAguirre-Gonzalez
PERSONHickman
PERSON
Armstrong
PERSON