Epstein Secrets

Atlomey JOE TITONE Florida Bar No. 203882 F ee HARVEY RUVIN CLERK OF COURTS DEPUTY CLERK AMERICANS WIT

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

., 148 D. F.R. 275, 278 .Kan.1993); 4 Jack B. Weinstein and Margaret A. Berger, Wein- stein's federal Evi

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

iff Attorney JOE IfTONE Florita Bar No. 203882 HARVEY RUMN CLEM( OF COURTS O .1mM On Atoka Comm 1/31

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