Epstein Secrets

oggs, 741 N.W.2d 1D Alaska: Alaska Rule Evid. 410; Arizona: Ariz. R. Crim. P. 17.4; Arkansas: Ark. R. Evid. 410; California: Cal. Evid. Code §1153; Colorado: Cob. R. Evid. 410; Delaware: Del. R. Evid. 410; Florida: Fla. Stat. Ann. §90.410; Hawaii: Hawaii R. Evid. 410; Idaho: Idaho R. Evid. 410; Illinois

tion. B. The Private Interests at Stake Are Profoundly Important. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee, 518 U.S. at 10, and maintaining their confidentiality advances significant private as well as public interests. There is an "imperative need" that

ure, they will necessarily refrain from making admissions and concessions, either of fact or law, which could later harm their clients. Thus, as in Jaffee, the "evidence" which would be available for later discovery would likely never come into being. Fourth, there is a strong consensus in the states

gress rejected in enacting Rule 501, only one of which appears on this Court's summary in Adkins of the most important considerations identified in Jaffee - over the most important consideration, the strong public and private interests at stake. The Goodyear Tire analysis is far more consonant with th

prepared with pending litigation in mind, the primary motivation behind the creation of such reports was for use in the normal course of business); Colorado ex rel. Woodard Schmidt-Tiago Construction Co„ 108 F.R.D. 731, 734-35 (D. Cob. 1985) (absent additional evidence, no work product protection for re

rican Airlines had made "a • compelling argument for recognition of a limited common law privilege for the ASAP materials." Id. at 1533. Relying on Jaffee, Judge Marcus found that he had the ability "to recognize new privileges, consistent with Rule 501 of the Federal Rules of Evidence, in cases arisin

Sacramento, California to parents and father, date of birth currently resides in California and her mother, date of birth currently resides in Colorado. moved to Palm Beach County, Florida with her parents when she was four years old and returned to California at age 11. She returned to Florida at

Office in Fort Lauderdale, Florida. UNCLASSIFIED 403 EFTA02858265 UNCLASSIFIED To: Miami From: Miami Re: ??31E-MM-108062, 03/11/2011 Edwards, Jaffee and Fisten provided information about crimes uncovered during the lengthy civil investigation of EPSTEIN by Mr. Edwards' office. These allegations