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ent 477 Entered on FLSD Docket 0226;2010 Page 1 of 24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARRA/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,
HE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of
n this regard and/or providing self-incriminating information is substantial, real and not merely imaginative. 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 full well, attached to
n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular
196, 205, 207 (1995)(puipose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence ¶410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is
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
196, 205, 207 (1995)(purpose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence 1410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005X"The underlying purpose of Rule 410 is t
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
(1995)(purpose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a EFTA00729521 privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence 1410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is
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
(1995)(purpose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a EFTA00586218 privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence 1410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is
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