Epstein Secrets

as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Pla

t marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Pla

is already in hand? Sic also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. EFTA00317225 Case 9:08-cv-80119-KAM

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 to promote plea negotiations by permitting defendants to talk to prosecutor

rt marked as an Exhibit by Plaintiffs counsel at Detective Recarey's deposition as well as certain message pads Pla

y in hand? See also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiffs counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. Case 9:08-cv-80119-KAM Document

], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence if410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote plea negotiations by permitting defendants to talk to prosecuto

sely the type of testimony the presumptive limit is intended to prevent. Similarly, the expected deposition testimony of former Palm Beach Detective Joe Recarey and former Palm Beach Police Chief Michael Reiter are duplicative of each other. 4 Mr. Rodgers deposition, held last Friday and requiring a separate

ion testimony of former Palm Beach Detective Joe Recarey and former Palm Beach Police Chief Michael Reiter

sense because a "moving party must not only justify those depositions it wishes to take, but also the depositions it has already taken." Id. (citing Barrow v. Greenville Indep. Sch. Dist., 202 F.R.D. 480, 482 (N.D.Tex. 2001)). This rule is in place because "a party could indirectly circumvent the cap o