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rivilege under Rule 501)." Substantial constitutional and policy considerations, viewed under "the light of reason and experience" as Rule 501 and Jaffee command, support a common-law privilege over Mr. Epstein's plea negotiation letters and emails. A. The Attorneys Relied Upon The Correct Legal Sta
gent than in other circuits. [DE 106 at 15]. The 1982 standard the plaintiffs accuse us of hiding was effectively overruled by the Supreme Court in Jaffee, a 1996 case we cited throughout our supplemental filing. Indeed, we referred to Jaffee as "perhaps the leading case addressing Rule 501 and the com
ications, either written or oral, made during the course of a mediation. Our decision whether to apply this mediation privilege .. . is governed by Federal Rule of Evidence 501 [and] Jaffee'. Redmond, 518 U.S. 1 (1996) . . . Recognizing that only those documents prepared for purposes of the confidential mediation are prote
merican 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
and trust," and because their confidentiality serves significant public and private ends, they are properly subject to a common law privilege under Federal Rule of Evidence 501. Similar privileges, which are "rooted in the imperative need for confidence and trust" and which serve significant public and private ends, have b
American 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 EFTA00301917 he had the ability to recognize new privileges, consistent with Rule 501 of the Federal Rules of Evidence,
—and because their continued confidentiality serves significant public and private ends, they are properly subject to a common law privilege under Federal Rule of Evidence 501. Similar privileges, which are rooted in the imperative need for confidence and trust and which serve significant public and private ends, have bee
Entities connected to both Jaffee and Federal Rule of Evidence 501

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATIONLeon Black
PERSONMartin Weinberg
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONRoy Black
PERSON
Scarlett Johansson
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Jay Lefkowitz
PERSON
Supreme Court
ORGANIZATION
Donald Trump
PERSON
Julie K. Brown
PERSONFBI
ORGANIZATION
Paul Cassell
PERSON
Columbia University
LOCATIONHerman
PERSON
Southern District of New York
ORGANIZATION