Epstein Secrets

nors have already fully addressed this issue, including this Court's reasoning, in their Motion at . As they pointed out there, in United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement, not to state charges as here, renderin

are concerned, the irreparable injury inheres in their very disclosure. See Motion at and cases cited therein. The single case cited by plaintiff, Northeastern Florida Chapter of of Gen. Contractors of America v. City of Jacksonville, 896 F.2d 1283 (11th Cir. 1990), did not involve privileged or confidential comm

. . . which are inadmissible in proceedings against the defendant making them under Rule 410." DE 188 at 5 (emphasis added) (citing United States' Paden, 908 F.2d 1229, 1235 (5th Cir. 1990) (statements made during negotiations that resulted in a final plea of guilty not protected under Rule 410), ce

orrespondence. Epstein must present evidence that he will be injured — and injured irreparably — if the victims read the correspondence. See, e.g., Northeastern Florida Chapter of Ass 'rt of General Contractors of America City of Jacksonville, Fla., 896 F.2d 1283, 1286 (11th Cir. 1990) ("Because plaintiff presented

a guilty plea . . . .' which are inadmissible in proceedings against the defendant making them under Rule 410." (DE 188 at 5) (citing United States' Paden, 908 F.2d 1229, 1235 (5th Cir. 1990) (statements made during negotiations that resulted in a final plea of guilty not protected under Rule 410), ce

nt the victims to read the correspondence. Epstein must present evidence that he will be injured if the victims read the correspondence. See, e.g., Northeastern Florida Chapter of Ass'n of General Contractors of America I. City of Jacksonville, Fla., 896 F.2d 1283, 1286 (11th Cir. 1990) ("Because plaintiff presente

rs have already fully addressed this issue, including this Court's reasoning, in their Motion at 6-9. As they pointed out there, in United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement, not to state charges as here, renderin

ncerned, the irreparable injury inheres in their very disclosure. See Motion at 15-17, and cases cited therein. The single case cited by plaintiff, Northeastern Florida Chapter of Ass'n of Gen. Contractors of America v. City of Jacksonville, 896 F.2d 1283 (11th Cir. 1990), did not involve privileged or confidential