Epstein Secrets

ent 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARR A/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NPA is

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

to defend themselves if no disposition agreement is reached"); Fed. R. Crim. P. 11, Advisory Committee Notes, 1979 Amendment ("the purpose of Fed. R. Ev. 410 and Fed. R. Crim. P. 11(eX6) [now Rule 11(f)] is to promote the unrestrained candor which produces effective plea discussions")) Additional il

d therefore insulates the particular parties to a settlement discussion FRE 410(4) is particularly directed to communications in matters which, like Epstein's, did not result in a plea of guilty to ni t federal charge. Fla. Stat. §90.410 provides parallel protections in state criminal matters. Epstein p

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

to defend themselves if no disposition agreement is reached"); Fed. R. Crim. P. 11, Advisory Committee Notes, 1979 Amendment ("the purpose of Fed. R. Ev. 410 and Fed. R. Crim. P. 11(e)(6) [now Rule 11(0] is to promote the unrestrained candor which produces effective plea discussions"),I Additional i

d therefore insulates the particular parties to a settlement discussion FRE 410(4) is particularly directed to communications in matters which, like Epstein's, did not result in a plea of guilty to ni t federal charge. Fla. Stat. §90.410 provides parallel protections in state criminal matters. Epstein p

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

to defend themselves if no disposition agreement is reached"); Fed. R. Crim. P. 11, Advisory Committee Notes, 1979 Amendment ("the purpose of Fed. R. Ev. 410 and Fed. R. Crim. P. 11(e)(6) [now Rule 11(0] is to promote the unrestrained candor which produces effective plea discussions"),I Additional i