Epstein Secrets

the issues and the defenses in the litigation"). W. The information simply falls under the "highly pr

al as that information is within the penumbra of the protections of Federal Rules of Evidence 408 and 410. Moreover, despite Plaintiffs contention, Federal Rule of Evidence 410 is applicable because negotiations did not end with a federal plea. Furthermore, Federal Rule of Evidence 408 is applicable given that 18 U.S.C. 22

E COURT OF APPEALS BUILDING 56 Forwilt Street. N.W. Adams. Georgia 30303 John Ley Ckrtof Cost Apr

rs argued that the work-product privilege 5 EFTA00209389 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

E COURT OF APPEALS BUILDING 56 Forwilt Street. N.W. Adams. Geosgia 30303 Mee Ley Clerk of Court A

rs argued that the work-product privilege 5 EFTA00209430 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

LE COURT OF APPEAIS BUILDING 56 Forwth Street. N.W. Mania. Georgia 30303 John Ley Clerk of Court

argued that the work-product privilege 5 EFTA00209636 Case: 13-12923 Date Filed: 04/18/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

way, men are but guilded loam, or painted clay." W. Shakespeare, RICHARD II, ACT 1, SCENE 1, lines 17

ane Doc 2 to release materials that are plainly the privileged opinion work-product of the attorneys, that constitute settlement negotiations under Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure II, and that contain information about matters occurring before the grand jury, which arc strictly confidenti

tion. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. B

y of the correspondence between the United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the