Epstein Secrets

lement agreement at trial under Fed. R. Evid. 403).3 And because plea negotiations, "if publicly released, could be damaging to reputation and 'See Wagner v. Wastiffs, Case No. 2:08-cv-431 (S.D. Ohio May 14, 2013), 2013 U.S. Dist. LEXIS 68349 (denying motion to compel discovery of settlement agreement

EQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS `GOOD CAUSE' Citing Brown v. Advantage Eng I, Inc., 960 F.2d 1013 (11th Cir. 1992), and Wilson v. American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth "the extraordinary circumstances or particularized needs necessitating a

lement agreement at trial under Fed. R. Evid. 403).3 And because plea negotiations, "if publicly released, could be damaging to reputation and 3See Wagner" Wastiffs, Case No. 2:08-cv-431 (S.D. Ohio May 14, 2013), 2013 U.S. Dist. LEXIS 68349 (denying motion to compel discovery of settlement agreement on

EQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS `GOOD CAUSE' Citing Brown I. Advantage Eng g, Inc., 960 F.2d 1013 (11th Cir. 1992), and Wilson I. American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth "the extraordinary circumstances or particularized needs necessitating a

t the dissemination and use of discovery concerning settlement discussions, even if the communications themselves are not privileged. See 3 But see Wagner v. Wastiffc, Case No. 2:08-cv-431 (S.D. Ohio May 14, 2013), 2013 U.S. Dist. LEX1S 68349 (denying motion to compel discovery of settlement agreement

REQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS >GOOD CAUSE= Citing Brown v. Advantage Eng=g, Inc, 960 F.2d 1013 (11th Cir. 1992), and Wilson v American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth Athe extraordinary circumstances or particularized needs necessitating a