Epstein Secrets

ED that: Plaintiffs Motion for Protective Order is hereby GRANTED. DONE AND ORDERED this day of June, 2009. Copies to all Counsel of Record and KENNETH A. MARRA United States District Judge EFTA00201400

RN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, VS. PSTEIN and De

e, C.M.A.'s treatment records from the Inc. and are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00201395 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 4 of 8 C.M.A. vs. Epste

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

dentiality on which defense counsel have reasonably relied for many decades in negotiating with government attorneys on behalf of their clients. In Jaffee v. Redmond, 518 U.S. 1 (1996), the Supreme Court focused on four primary considerations governing the recognition of privileges under Rule 501: the needs of t

thout notifying the victims Their case is pending in U.S. District Court in Wesl Palm Beach. The 24-page published opinion says U.S. District Judge Kenneth Marra did not err in his June 2013 ruling, when he ordered the correspondence turned over to the victims. "Sweetheart plea' `We're now going to get a co

ublished opinion says U.S. District Judge Kenneth Marra did not err in his June 2013 ruling, when he orde

ge is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiat

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

on FLSD Docket 04/17/2012 Page 10 of 23 A. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffee v. Redmond, 518 U.S. 1 (1996), is perhaps the leading case addressing Rule 501 and the common-law principles underlying the recognition of testimonial privileg

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

oof of guilt." Herman, 544 F.2d at 797. D. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffee v. Redmond, 518 U.S. 1, 5-6 (1996), is perhaps the leading case addressing Federal Rule of Evidence 501 and the common-law principles underlying the recognitio

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

oof of guilt." Herman, 544 F.2d at 797. D. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffee v. Redmond, 518 U.S. 1, 5-6 (1996), is perhaps the leading case addressing Federal Rule of Evidence 501 and the common-law principles underlying the recognitio

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, petitioners, VS.

e admitted in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee v. Redmond, 518 U.S. 1, 10 (1996), and maintaining their confidentiality advances significant public and private ends. Discovery and use of plea negotiations

id not apply to pre-indictment negotiations with potential federal defendants. After Jane Doe No. 2 joined the initial petition, the district court (Marra, J.) found that both women qualified as “crime victims” under the CVRA. The district court later_rejected the government's argument that the act only

ege is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15 (1996}—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiatio

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

e admitted in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee v. Redmond, 518 U.S. 1, 10 (1996), and maintaining their confidentiality advances significant public and private ends. Discovery and use of plea negotiations

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

n FLSD Docket 09/02/2011 Page 10 of 24 A. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffee v. Redmond, 518 U.S. 1 (1996), is perhaps the leading case addressing Rule 501 and the common-law principles underlying the recognition of testimonial privileg