Epstein Secrets

NS Pursuant to 11th Cir. R. 26.1, Intervenor/Appellants hereby certify that the following persons 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

. The prior civil discovery order relied upon by Judge Marra, DE188:3-4, resulted from the efforts of the civ

he 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 the Supreme Court's teaching in Jaffee than is MTSG. In Baker v. Secretary, U.S. Dept of Transportation, 452 F

itz do not seek intervention to litigate whether the [CVRA) was violated and if so, against whom a remedy is appropriate (DE56 at 5). District Judge Marra granted the attorneys' motion, allowing limited intervention to "assert[] a claim that the documents in question may be privileged" (DE158 at 1-2).

hom a remedy is appropriate (DE56 at 5). District Judge Marra granted the attorneys' motion, allowing limited

ases, the press sought access to pit-trial settlement procedures, asserting a First Amendment right of access, and the courts denied such access. In Goodyear Tire 2 The CVRA itself provides that a "person accused of the crime may not obtain any form of relief under this chapter." 18 U.S.C. § 3771(d)(1). 5 E

oe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON EFTA00317246 Case 9:08-cv-80119-KAM Do

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiation

A FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTE

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be

A FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTE

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be

FREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARRA/JOHNSON Related cases: 08-80232, 08-08380, 08-8

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context. The free availability in discovery to civil plaintiffs of communications

A FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTE

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be