Epstein Secrets

08/05/2013 Page: 14 of 75 Wa. R. Evid. 410 42 W. Va. R. Evid. 410 42 Wisc. Stat. Ann. §904.10 4

tion. B. The Private Interests at Stake Are Profoundly Important. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee, 518 U.S. at 10, and maintaining their confidentiality advances significant private as well as public interests. There is an "imperative need" that

ure, they will necessarily refrain from making admissions and concessions, either of fact or law, which could later harm their clients. Thus, as in Jaffee, the "evidence" which would be available for later discovery would likely never come into being. Fourth, there is a strong consensus in the states

gress rejected in enacting Rule 501, only one of which appears on this Court's summary in Adkins of the most important considerations identified in Jaffee - over the most important consideration, the strong public and private interests at stake. The Goodyear Tire analysis is far more consonant with th

is day of December, 2017. THE HONORABLE DONALD W. HAFELE CIRCUIT COURT JUDGE SERVICE LIST EFTA00

nsel for Defendant/Counter-Plaintiff Bradley J. Edwards Co-Counsel for DefendantlCounter-Plaintiff Bradley J. Edwards Bradley J. Edwards Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, . 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33401 Marc S. Nurik Law Offices of Marc S. Nurik On

is day of December, 2017. THE HONORABLE DONALD W. HAFELE CIRCUIT COURT JUDGE SERVICE LIST Jack S

350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33401 Marc S. Nurik Law Offices of Marc S. Nurik O

is day of December, 2017. THE HONORABLE DONALD W. HAFELE CIRCUIT COURT JUDGE SERVICE LIST Jack S

350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33401 Marc S. Nurik Law Offices of Marc S. Nurik O

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

ge is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee' Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to pre

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

ge is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee' Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to pre

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

ge is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to p

er, -VS- SCOTT individually, EDWARDS, L.M., E.W., Intervenors. ROTHSTEIN, BRADLEY J. individu

350 444 West Railroad Avenue West Palm Beach FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33401 Marc S. Nurik Law Offices of Marc S. Nurik O

08- 80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Hagle

the Parent-Child Center, Inc. and Dr. Serge Thys are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee'. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00182846 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 4 of 8 a k. v

ers' website. Holdings: The District Court, Paul W. Grimm, United States Magistrate Judge, held tha

rican Airlines had made "a • compelling argument for recognition of a limited common law privilege for the ASAP materials." Id. at 1533. Relying on Jaffee, Judge Marcus found that he had the ability "to recognize new privileges, consistent with Rule 501 of the Federal Rules of Evidence, in cases arisin