Epstein Secrets

ningful and irreparable chill" to the fr 'mplete disclosures" that result in negotiated resolution of criminal matters. In re Air Crash Near Cali, Colombia, 957 F.2d at 1533. For these reasons, lea negotiations are properly subject to a common law privilege under Rule 501. aV. 7 II. THE SEVERE AND IRR

o permit the 10 EFTA00205369 unrestrained candor which produces effective plea discussions between the . .. government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

ningful and irreparable chill" to the fr 'mplete disclosures" that result in negotiated resolution of criminal matters. In re Air Crash Near Cali, Colombia, 957 F.2d at 1533. For these reasons, lea negotiations are properly subject to a common law privilege under Rule 501. aV. 7 II. THE SEVERE AND IRR

o permit the 10 EFTA00205349 unrestrained candor which produces effective plea discussions between the . .. government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

ence and trust" and which serve significant public and private ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reiclzhold Chemicals, Inc. v. Textron, Inc., 157 F

im.P. I I (eX6) is to permit the unrestrained candor which produces effective plea discussions between the . . . government and the ... defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

dence and trust" and which serve significant public and private ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 MI. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reichold Chemicals, Inc. v. Textron, Inc., 157 . 5

0 and 11(e)(6) is to permit the unrestrained candor which produces effective plea discussions between the ... government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 . 507, GET PAGE (February

ence and trust" and which serve significant public and private ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (M. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reichold Chemicals, Inc. v. Textron, Inc., 157 =. 5

0 and 11(e)(6) is to permit the unrestrained candor which produces effective plea discussions between the ... government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 . 507, GET PAGE (February

and irreparable chill" to the "frank and complete disclosures" that result in negotiated resolution of criminal matters. In re Air Crash Near Cali, Colombia, 957 F.2d at 1533. For these reasons, plea negotiations are properly subject to a common law privilege under Rule 501. II. THE SEVERE AND IRREMEDI

uccess on appeal. 5 EFTA00177820 unrestrained candor which produces effective plea discussions between the . .. government and the . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

ence and trust" and which serve significant public and private ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reichhold Chemicals, Inc.. Textron, Inc., 157 F.R.

P. 1 I (c)(6) is to permit the unrestrained candor which produces effective plea discussions between the . . . government and the . . . defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)

ecognize new privileges, consistent with Rule 501 of the Federal Rules of Evidence, in cases arising under federal law." In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529, 1533 (S.D. FL. Feb. 7, 1997). 9 EFTA00177948 • Case 9:08-cv-80736-KAM Document 94 Entered on FLSD Docket 09/02/2011 Page 10

Crim.P. 11(eX6) is to permit the unrestrained candor which produces effective plea discussions between the . . . government and the ... defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507 (February 1978)