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d Epstein re-file this reply, which is identical to the reply that was previously filed during the litigation on intervention. We only add that, in Lafler' Cooper, 132 S. Ct. 1376 (2012) and Missouri.. Frye, 132 S. Ct. 1399 (2012), the United States Supreme Court flatly rejected the arguments by Jane D
ications, either written or oral, made during the course of a mediation. Our decision whether to apply this mediation privilege .. . is governed by Federal Rule of Evidence 501 [and] Jaffee'. Redmond, 518 U.S. 1 (1996) . . . Recognizing that only those documents prepared for purposes of the confidential mediation are prote
m of trials," it is insufficient simply to point to the guarantee of a fair trial as a backstop that inoculates any errors in the pretrial process. Lafler v. Cooper, 132 S. Ct. 1376, 1388 (2012); Missouri v. Frye, 132 S. Ct. 1399, 1407 (2012). In Lafler and Frye, the Supreme Court ruled that the Sixth
ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which 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, 132
t inoculates any errors in the pretrial process. !after v. Cooper, 132 S. Ct. 1376, 1388 (2012); Missouri v. Frye, 132 S. Ct. 1399, 1407 (2012). In Lafler and Frye, the Supreme Court ruled that the Sixth Amendment right to effective assistance of counsel "extends to the plea bargaining process" and tha
ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which 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, 132
Entities connected to both Lafler and Federal Rule of Evidence 501

Jeffrey Epstein
PERSONLeon Black
PERSON
United States
LOCATION
Kenneth Marra
PERSONJane Doe
PERSON
Bradley Cooper
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSONRoy Black
PERSON
Michael Cohen
PERSON
Jay Lefkowitz
PERSON
Supreme Court
ORGANIZATION
Department of Justice
ORGANIZATIONHawkman
PERSONHerman
PERSON
Columbia University
LOCATIONSantobello
PERSONPerlman
PERSONTrammel
PERSON
Chris Christie
PERSON