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

27 *Lafler v. Cooper, 132 S. Ct. 1376 (2012) 8, 12 Long v. Raymond Corp., 245 Fed. Appx. 912 (11th Cir. 2007) 6 Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir. 1979), cert. denied, 444 U.S. 1076 (1980) 34,37,38 Marino v. Ortiz, 484 U.S. 301 (1988) 52 Mezu v. Morgan State Uni

1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern D

rty. In plea negotiations, the need for "counsel to discuss matters in an uninhibited fashion" is even more important. See Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928, 930 (2d Cir. 1979). Likewise, where a defendant is facing the loss of liberty, he has an even 10 EFTA00600200 Case 9:08-cv-

1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern D

rty. In plea negotiations, the need for "counsel to discuss matters in an uninhibited fashion" is even more important. See Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928, 930 (2d Cir. 1979). Likewise, where a defendant is facing the loss of liberty, he has an even 10 EFTA00657048 Case 9:08-cv-

UTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs,

on privilege where litigants can "rely on the confidential treatment of everything that transpires during mediation ...." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979); Folb v. Motion Picture Incl. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldone v. Penns

UTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs,

able to poker players in a high-stakes game than adversaries attempting to arrive at a just solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.I979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a

UTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs,

able to poker players in a high-stakes game than adversaries attempting to arrive at a just solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.I979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a