Epstein Secrets

on Picture Incl. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldone v. Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation v. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Re

mittee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507, 538 (February 1978) (emphasis added). Even though the plaintiffs claim that they would technically offer the plea negotiation letters against the

privile e. Nevertheless, we find persuasive the reasoning set forth by the court in Sheldone I. Pennsylvania Turnpike Comnen, 104 F. Supp. 2d 511 (W.D. Pa. 2000), and by other courts that have adopted the federal mediation privilege." Software Tree LLC RedHat Inc., 2010 WL 2788202 at *4 (E.D.Tex. June 24,

"the purpose for which [the evidence] is offered." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, 77 F.R.D. 507, 538 (February 1978) (emphasis added). The plaintiffs' technical argument that it is "not possible" to use the plea negotiations "against" Mr. Epst

tion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldon I. Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Repo

mittee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507, 538 (February 1978) (emphasis added). 4 EFTA00177890 •Case 9:08-cv-80736-KAM Document 93-1 Entered on FLSD Docket 09/02/2011 Page 5 of 24 Even

Motion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldon Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation'. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Rep

ittee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978) (emphasis added).' For these reasons, criminal defense lawyers negotiate with prosecutors in an environment of confidentiality, fos