Epstein Secrets

Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 11 of 18 ours is "a system of pleas, not a system of trials." Lajler v. Cooper, 132 S.Ct. 1376, 1388 (2012); Missouri v. Frye, 132 S. Ct. 1399, 1407 (2012). This system cannot function properly unless counsel are assured that

mit how that information is used in the litigation. We believe this Court's inquiry is guided generally by the following Eleventh Circuit cases: * Chicago Tribune Co. v. Bridgestone/Firestone Inc., 263 F.3d 1304 (11th Cir. 2001). * FTC v. Abbvie Prod. LLC, 713 F.3d 54, (11th Cir. 2013). * Newman v. Graddic, 696 F

s," it is insufficient simply to point to the guarantee of a fair trial as a backstop that inoculates any errors in the pretrial process. Lafler v. Cooper, 132 S. Ct. 1376, 1388 (2012); Missouri v. Frye, 132 S. Ct. 1399, 1407 (2012). In Lafler and Frye, the Supreme Court ruled that the Sixth Amendment

6/18/2013 Page 2 of 4 the asserted right of access against the other party's interest in keeping the information confidentiarRomero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11* Cir. 2001). In balancing the competing interests, the court appropriately considers "wheth

gains are . .. central to the administration of the criminal justice system@ because ours is Aa system of pleas, not a system of trials.@ Lafler v. Cooper, 132 S.Ct. 1376, 1388 (2012); Missouri v. Aye, 132 S. Ct. 1399, 1407 (2012). This system cannot function properly unless counsel are assured that t

it how that information is used in the litigation. We believe this Court=s inquiry is guided generally by the following Eleventh Circuit cases: * Chicago Tribune Co. v. Bridgestone/Firestone Inc., 263 F.3d 1304 (11th Cir. 2001). * FTC v. Ahhvie Products LLC, 713 F.3d 54, (11th Cir. 2013). * Newman v. Graddic, 69