g and signed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). 06.20.2018 EFTA00040594 Page 3 Bates Start Bates End Confidential

g and signed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). Very truly yours, United States Attorney for the Southern District of

g and signed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). 0620.2018 EFTA00099136 Page 3 Bates Start Bates End Confidential N

m of trials," 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

ulates any errors in the pretrial process. b&. Lafler I. Cooper, 132 S. Ct. 1376, 1388 (2012); Missouri I. Frye, 132 S. Ct. 1399, 1407 (2012). In Lafler and Frye, the Supreme Court ruled that the Sixth Amendment right to effective assistance of counsel "extends to the plea bargaining process" and tha

ulates any errors in the pretrial process. b&. Lafler I. Cooper, 132 S. Ct. 1376, 1388 (2012); Missouri I. Frye, 132 S. Ct. 1399, 1407 (2012). In Lafler and Frye, the Supreme Court ruled that the Sixth Amendment right to effective assistance of counsel "extends to the plea bargaining process" and tha

protective orders and their objections to disclosure and use of plea negotiations by Jane Doe 1 and Jane Doe 2. The limited intervenors also submit Lafler and Frye in direct support of their arguments that the Court should recognize a common-law privilege in this case under Rule 501 in part because ple

d Epstein re-file this reply, which is identical to the reply that was previously filed during the litigation on intervention. We only add that, in Lafler' Cooper, 132 S. Ct. 1376 (2012) and Missouri.. Frye, 132 S. Ct. 1399 (2012), the United States Supreme Court flatly rejected the arguments by Jane D

19 In re Professionals Direct Ins. Co., 578 F.3d 432 (6th Cir. 2009) 19 In re Sealed Case, F.3d 2013 WL 2120157 13 (D.C.Cir. March 5, 2013) Lafler. Cooper, 132 S.Ct. 1376 (2012) 5 Marino I. Ortiz, 484 U.S. 301 (1988) 12 Mezul. Morgan State University, 495 Fed. Appx. 286 (4th Cir. 2012) . 14

19 In re Professionals Direct Ins. Co., 578 F.3d 432 (6th Cir. 2009) 19 In re Sealed Case, F.3d 2013 WL 2120157 13 (D.C.Cir. March 5, 2013) Lafler. Cooper, 132 S.Ct. 1376 (2012) 5 Marino I. Ortiz, 484 U.S. 301 (1988) 12 Mezul. Morgan State University, 495 Fed. Appx. 286 (4th Cir. 2012) . 14

s is "a system o f pleas, not a system of trials." 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 right to effective assistance of counsel "extends to the plea bargaining process" and th

t inoculates any errors in the pretrial process. !after 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 right to effective assistance of counsel "extends to the plea bargaining process" and tha

vernment were paradigmatic efforts, consistent with the Sixth Amendment right to effective assistance of counsel during plea bargaining, see, e.g., Lafler v. Cooper, 132 S.Ct. 1376 (2012), to engage in settlement discussions falling within the core protections of Rule 410. The district court also rejec

"Plea bargains are . . . central to the administration of the criminal justice system" because ours is "a system of pleas, not a system of trials." 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

m of trials," 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

vernment were paradigmatic efforts, consistent with the Sixth Amendment right to effective assistance of counsel during plea bargaining, see, e.g., Lafler v. Cooper, 132 S.Ct. 1376 (2012), to engage in settlement discussions falling within the core protections of Rule 410. The district court also rejec