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ntiality in their settlement/plea communications with the government and their concomitant protection from disclosure to the plaintiffs. See, e.g., Ross v. City of Memphis, 423 F.3d 596, 599 (6th Cir. 2007)(Perlman jurisdiction "does not depend on the validity of the appellant's underlying claims for relief'); Gill v.
ttorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's counsel during the course of the negotiations. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100) at 2 ("To the knowledge of the government, the Jane Does have only received the portions of the corres
ntiality in their settlement/plea communications with the government and their concomitant protection from disclosure to the plaintiffs. See, e.g., Ross v. City of Memphis, 423 F.3d 596, 599 (6th Cir. 2007)(Perlman jurisdiction "does not depend on the validity of the appellant's underlying claims for relief'); Gill v.
ct privilege, it stopped short of advocating the recognition of a settlement/plea negotiation privilege under Rules 410 and 501. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100). The government's institutional interests differ significantly from those of attorneys who Plaintiffs
ntiality in their settlement/plea communications with the government and their concomitant protection from disclosure to the plaintiffs. See, e.g., Ross v. City of Memphis, 423 F.3d 596, 599 (6th Cir. 2007)(Perlman jurisdiction "does not depend on the validity of the appellant's underlying claims for relief'); Gill v.
ttorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's counsel during the course of the negotiations. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100) at 2 ("To the knowledge of the government, the Jane Does have only received the portions of the corres
Entities connected to both Ross v. City of Memphis and Response to Supplemental Briefing

Jeffrey Epstein
PERSONJane Doe
PERSONPerlman
PERSONDickson
PERSONO'Brien
PERSONLoan Corp.
ORGANIZATION
United States
LOCATION
Michael Cohen
PERSON
Wilbur Ross
PERSONMohawk Industries, Inc.
ORGANIZATIONKrane
PERSONHolt-Orsted
ORGANIZATION
Carpenter
PERSONthe Wilson Court
ORGANIZATIONNadia Marcinkova
PERSON
Kenneth Marra
PERSON
Alberto Gonzales
PERSONSweeney
PERSONthe Ninth Circuit's
ORGANIZATIONSealed Case
PERSON