Epstein Secrets

counsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States'. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

refers to Federal Rule of Evidence 50!, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges.' Adkins g Christie, 488 F.3d 1324, 1328 (11th 2007), quoting Trammel I United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 41001s that t

counsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States'. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

refers to Federal Rule of Evidence 50!, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges.' Adkins g Christie, 488 F.3d 1324, 1328 (11th 2007), quoting Trammel I United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 41001s that t

M Document 188 Entered on FLSD Docket 06/18/2013 Page 5 of 11 proceedings against the defendant making them under Rule 410. See e.g United States v. 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

nly whcn it would achieve a public good transcending the normally predominant principle of utilizing all rational means for ascertaining the truth, Adkins v. Christie, 488 F.3d 1324 (11" Cir. 2007), citing United States v. Nixon, 418 U.S. 683, 710, 94 S. Ct 3090, 3108, 41 L.Ed. 2d 1039 (1974)( privileg

. 2012) 24, 25 *United States v. Mezzanatto, 513 U.S. 196 (1995) 6, 14, 28, 53 United States v. Nobles, 422 U.S. 225 (1975) 20 United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), cert. denied, 498 U.S. 1039 (1991) 26 United States v. Robertson, 582 F.2d 1356 (5th Cir. 1978) 24 vii EFTA0020

MPLIANCE 60 CERTIFICATE OF SERVICE 61 iii EFTA00209662 Case: 13-12923 Date Filed: 08/05/2013 Page: 7 of 75 TABLE OF AUTHORITIES Cases Adkins v. Christie, 488 F.3d 1324 (11th Cir. 2007), cert. denied, 552 U.S. 1131 (2008) 6, 30, 33, 45 Baker v. Secretary, U.S. Dep't of Transportation, 45

M Document 188 Entered on FLSD Docket 06/18/2013 Page 5 of 11 proceedings against the defendant making them under Rule 410. See e.g United States v. Paden, 908 F.2d 1229, 1235 (5ih Cir. 1990)(statements made during negotiations that resulted in a final plea of guilty not protected under Rule 410), cer

ict -2, this court declines the intervenors' invitation to expand Rule 410 by crafting a federal common law privilege for plea discussions. See e.g. Adkins v. Christie, 488 F.3d 1324 (11ih Cir. 2007)(declining to recognize medical peer review privilege in federal discrimination cases); Weiss ex reL Est

ounsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges." Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007), quoting Trammel v. United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 410 "is

ounsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges!" Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007), quoting Trammel v. United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 410 "is

the government led to Epstein's plea of guilty in state court. In the sole case cited by the district court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

ed by reference to Fed. R. Evid. 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges.'" Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007), quoting Trammel v. United States, 445 U.S. 40, 47 (1980). The Supreme Court has recognized that

counsel and the government led to Epstein plea of guilty in state court. In the sole case cited by the Court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 5 EFTA00584595 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein ent

efers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges!" Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007), quoting Trammel v. United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 410 "is