Epstein Secrets

lbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "l

This Improper Motion Practice And Have No Demonstrable Need For More Several depositions have occurred over the last 4 weeks wherein it appears Mr. Edwards already has the information he seeks responsive to these requests, which is likely the reason Mr. Edwards has not filed any affidavits supporting t

C. v. Johnson, 534 F.Supp.2d 63, 66-67 (D.D.C. 2008), quoting United States v. Davis, 617 F.2d 677, 683 (D.C.Cir. 1980). See, Q,g., United States v. Mezzanatto, 513 U.S. 196, 205, 207 (1995)(purpose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant,"

the NP A is a list which delineates alleged victims. Once the NP A was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Number IO seeks information that may vio

.E.C. v. Johnson, 534 F.Supp.2d 63, 66-67 (D.D.C. 2008), quoting United States v. Davis, 617 F.2d 677,683 (D.C.Cir. 1980). See, M,, United States v. Mezzanatto, 513 U.S. 196,205,207 (l 995)(purpose of the rules is to encourage plea bargaining, and rules "creat[ e ], in effect, a privilege of the defendant,

rsons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923

development of testimonial privileges .. . `governed by the principles of common law as they may be interpreted ... in the light of reason and 6 In Mezzanatto, the defendant challenged the admissibility of plea negotiation statements he made to a prosecutor, who had conditioned his willingness to enter int