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10; South Dakota: S.D.C.L. §19-12-12; Tennessee: Tenn. R. Evid. 410; Texas: Texas R. Evid. 410; Utah: Utah R. Evid. 410; Vermont: Vt. R. Evid. 410; Virginia: Va. S.Ct. Rule 3A:8; Washington: Wa. R. Evid. 410; West Virginia: W. Va. R. Evid. 410; Wisconsin: Wisc. Stat. Ann. §904.10; Wyoming: W.R. Crim. P.
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
me Court, an Associate Deputy Attorney General with the U.S. Justice Department (1986-88), and an Assistant U.S. Attorney for the Eastern District of Virginia (1988 to 1991). Cassell joined the faculty at the University of Utah College of Law in 1992, where he taught full time until he was sworn in as a U.S
ionship, unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States viola
ly 20 years old. Epstein did not like her and did not want her brought again. Rivera added that Marsh was a heavy drug user. Miller also introduced Virginia Last Name Unknown (LNU), aka Jenny to Epstein. Virginia LNU was younger than Rivera and visited Epstein's residence one time. Virginia LNU had a S
merican 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
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK panne nee eee X VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. poe nen nee nee eee eee eee xX Defendant’s Response in Opposition to Plaintiff’s O
Page: HOUSE_OVERSIGHT_011463 →RT SOUTHERN DISTRICT OF NEW YORK panne nee eee X VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHI
Page: HOUSE_OVERSIGHT_011463 →DISTRICT OF NEW YORK panne nee eee X VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXW
Page: HOUSE_OVERSIGHT_011463 →cione v. Hustler Magazine, Inc., 800 F.2d 298, 303 (2d Cir. 1986)... ce eeeeeesesseeseeeseeeeeees 13 ill HOUSE_OVERSIGHT_011466 --- PAGE BREAK --- Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923, 135 L.Ed.2d 337 (1996) oe ceeeescesseeeseerseeesees 22 Kadant Johnson Inc. v. D’Amico, No. CIV.A. 10-2869, 2
Page: HOUSE_OVERSIGHT_011467 →Microsoft Word - 2017.03.16 Deft Resp IO to Ptfs Omnibus Motn in Limine (MASTER).docx
T SOUTHERN DISTRICT OF NEW YORK wn eee ee eee xX VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXW
Page: HOUSE_OVERSIGHT_014788 →T SOUTHERN DISTRICT OF NEW YORK wn eee ee eee xX VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHI
Page: HOUSE_OVERSIGHT_014788 →ISTRICT OF NEW YORK wn eee ee eee xX VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXW
Page: HOUSE_OVERSIGHT_014788 →d Cir. 1986)... ccccccecceeeeees 13 iil HOUSE_OVERSIGHT_014791 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 749 Filed 03/17/17 Page 5 of 9 Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923, 135 L.Ed.2d 337 (1996) oo... cece eeeeees 22 Kadant Johnson Inc. v. D'Amico, No. CIV.A. 10-2869, 2012 WL 219
Page: HOUSE_OVERSIGHT_014792 →Entities connected to both Virginia Giuffre and Jaffee

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSON
New York
LOCATION
Joe Biden
PERSONthe Southern District
LOCATION
Marc Rich
PERSON
Prince Charles
PERSONMaria Farmer
PERSON
Stephen Hawking
PERSON