ane Doe 2 to release materials that are plainly the privileged opinion work-product of the attorneys, that constitute settlement negotiations under Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11, and that contain information about matters occurring before the grand jury, which are strictly confidenti

rs argued that the work-product privilege 5 EFTA00209389 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

rs argued that the work-product privilege 5 EFTA00209430 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

specifically noted this evidentiary problem with Epstein's claim. The District Court gave as one reason for rejecting Epstein's contention based on Federal Rule of Evidence 410 that the rule does not even possibly protect "general discussions of leniency and statements made in the hope of avoiding a federal indictment - ar

argued that the work-product privilege 5 EFTA00209636 Case: 13-12923 Date Filed: 04/18/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

argued that the work-product privilege 5 EFTA00209745 Case: 13-12923 Date Filed: 04/18/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

P. 24(b), the intervenors moved for protective orders. The intervenors argued that the work-product priv- ilege protects their correspondence; that Federal Rule of Evidence 410 and Feder- al Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jur

al as that information is within the penumbra of the protections of Federal Rules of Evidence 408 and 410. Moreover, despite Plaintiffs contention, Federal Rule of Evidence 410 is applicable because negotiations did not end with a federal plea. Furthermore, Federal Rule of Evidence 408 is applicable given that 18 U.S.C. 22

discovery of the correspondence between the U.S. and Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that th

ons and settlement communications have no tradition of being publically accessible," and that "serious Sixth Amendment implications," the spirit of Federal Rule of Evidence 410, and the "environment of confidentiality" fostered by 10 EFTA00606597 Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page

against him because of Rule 410 of the Federal Rules of Evidence. See Exhibit A to Epstein's Mot. to Intervene, DE #93-1 (arguing that pursuant to Federal Rule of Evidence 410, Epstein is entitled to some sort of protective order). If this pleading has a familiar ring to it, it is because Epstein has presented it to this

against him because of Rule 410 of the Federal Rules of Evidence. See Exhibit A to Epstein's Mot. to Intervene, DE #93-1 (arguing that pursuant to Federal Rule of Evidence 410, Epstein is entitled to some sort of protective order). If this pleading has a familiar ring to it, it is because Epstein has presented it to this

ons and settlement communications have no tradition of being publically accessible," and that "serious Sixth Amendment implications," the spirit of Federal Rule of Evidence 410, and the "environment of confidentiality" fostered by 10 EFTA00674425 Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page

r discovery of the correspondence between the M. and Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure I I create a privilege for plea negotiations, barring release of the correspondence. They also argued that t

r discovery of the correspondence between the U.S. and Epstein’s attorneys during the plea negotiations. Epstein’s attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that the

ane Doc 2 to release materials that are plainly the privileged opinion work-product of the attorneys, that constitute settlement negotiations under Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure II, and that contain information about matters occurring before the grand jury, which arc strictly confidenti

y of the correspondence between the United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the