Epstein Secrets

ce in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confident

iosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?5 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out)

purposes underlying Rule 408 are essentially the same as those underlying Rules ll(f) and 410: "to encourage non-litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (I Ith Cir. 1976). See, M-, Stockman v. Oakcrest Dental Center, P. C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose

ce in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confident

iosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?3 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out)

derlying Rule 408 are essentially the same as those underlying Fed. R. Crim, P. 11 (f) and 410: "to encourage non- litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th Cir. 1976). See, Lls·, Stockman v. Oakcrest Dental Center, P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose

unications from disclosure to third parties outside the negotiation process. 3. Whether this Court has jurisdiction of this appeal under Perlman v. United States, 247 U.S. 7 (1918). EFTA00209671 Case: 13-12923 Date Filed: 08/05/2013 Page: 16 of 75 STATEMENT OF THE CASE AND STATEMENT OF FACTS In Septembe

tomary practices of the defense and prosecution function, entitled to assume would remain confidential and would not be disclosed to third parties. See United States v. Deloitte UP, 610 F.3d 129, 141 (D.C.Cir. 2010)(court "examine[s] whether the disclosing party had a reasonable basis for believing that the reci

cial efficiency it fosters is lost. Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003)(emphasis added)! See Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th The Federal Circuit declined to recognize a settlement negotiation privilege in In re MTSG, Inc., 675 F.3d 1337