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intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective order and his opposition to the motions of the plaintiffs for production, use, and disclosure of his plea
ntervene. Established case law as well as sound and substantial policy considerations prohibit disclosure of the letters and emails prepared by Mr. Epstein's lawyers during plea negotiations with the government, and require that the letters and emails that Jane Doe 1 and Jane Doe 2 already have remain
morandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective
disclosure of the letters and emails prepared by Mr. Epstein's lawyers during plea negotiations with the gove
kely to lead to admissible evidence." Reist v. Source Interlink Co., 2010 WL 4940096 at *2 (M.D. Fla. Nov. 29, 2010); Bottaro v. Hatton Assocs., 96 F.R.D. 158, 159-60 (E.D.N.Y. 1982) ("the object of the inquiry must have some evidentiary value before an order to compel disclosure of otherwise inadmissible
Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeff
sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 51. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non-Pr
Intervenor Jeffrey Epstein s Motion For a Protective Order And Oppo
during the criminal investigation [DE 50 at 51. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D
kely to lead to admissible evidence. Reist v. Source Interlink Co., 2010 WL 4940096 at '2 (M.D. Fla. Nov. 29, 2010); Bottaro v. Hatton Assocs., 96 F.R.D. 158, 159-60 (E.D.N.Y. 1982) ( the object of the inquiry must have some evidentiary value before an order to compel disclosure of otherwise inadmissible
ter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND IN LIMINE OF UNRELATED SETTLEMENTS Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves for a protectiv
NTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND IN LIMINE OF UNRELATED SETTLEMENTS Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) on the production and disclosure of any additional confidentia
OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT
And again, the degree of financial exposure that Mr. Epstein was facing is reflected by the settlements of al
(denying motion to compel production of documents containing information about confidential settlement discussions); Bottaro v. Hatton Assocs., 96 F.R.D. 158, 160 (ED. N.Y. 1982) (denying motion to compel production of settlement agreement); Grove Fresh Distribs., Inc. v. John Labatt, Ltd., 888 F. Supp. 1
Entities connected to both Jeffrey Epstein and F.R.D. 158
Leon Black
PERSON
United States
LOCATIONJane Doe
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSONPeterson
PERSONHerman
PERSON
Columbia University
LOCATIONPensacola
LOCATIONSantobello
PERSON
the Fifth Circuit
ORGANIZATION
Armstrong
PERSONAguirre-Gonzalez
PERSONJaffee
PERSONHobson
PERSONAcker
PERSONHawkman
PERSONABA Model
ORGANIZATIONFederal Rule of Evidence 501
ORGANIZATIONVinson
PERSON