DataSet-9
EFTA00771165
8 pg
Defendants' Draft of 10/7/09
For Settlement Purposes Only
Confidential & Inadmissible Under NY CPLR 4547, FRE 408 and Other Applicable Law
SETTLEMENT AGREEMENT AND GENERAL RELEASE
THIS SETTLEMENT AGREEMENT AND GENERAL RELEASE (the "Agreement") is
ente…
DataSet-9
EFTA00731219
8 pg
Defendants' Draft of 10/7/09
For Settlement Purposes Only
Confidential & Inadmissible Under NY CPLR 4547, FRE 408 and Other Applicable Law
SETTLEMENT AGREEMENT AND GENERAL RELEASE
THIS SETTLEMENT AGREEMENT AND GENERAL RELEASE (the "Agreement") is
ente…
DataSet-9
EFTA01074684
2 pg
…with
respect to Interests, a separate Capital Account will be established for each
Interest purchased (i.e. each capital contribution made).
May 2005 Offering Memorandum.
This evidence is inadmissible. To begin with, the document was created in May 2005
five…
DataSet-9
EFTA00808719
7 pg
…203, dated November 8, 2017, is accurate.
2
EFTA00808720
ARGUMENT
Inadmissible and Prejudicial
First, Epstein objects to any…
DataSet-9
EFTA00207623
2 pg
…on Mr. Epstein's behalf believing they are irrelevant to
the civil litigation, certainly inadmissible, and that their production chills the candor of plea negotiations
in future cases thus the order violates the spirit of FRE 410 and 408. We…
DataSet-9
EFTA00872905
2 pg
…say they were inadvertently
disclosed and must be returned i.e. inadmissible which is a lawyer's first move when his emails/work product were
disseminated. Seems different than the Rothstein emails which may have come from a separate discovery…
DataSet-9
EFTA00872901
2 pg
…and must be returned i.e. inadmissible which is a lawyer's first move when his emails/work product were disseminated.
Seems different than the Rothstein emails which may have come from a separate discove roduction. Not to in
anyway…
DataSet-9
EFTA00799054
1 pg
…Permit.
Your application has been examined with reference to the possibility of issuing a temporary
resident permit to overcome your criminal inadmissibility described in paragraph 36(2)(b) of the
Immigration and Refugee Protection Act because you have been convicted…
DataSet-9
EFTA00715709
8 pg
…endorse or espouse terrorist activity" is
"ineligible for visas or admission" to the U.S. [8 U.S.C. 1182 - INADMISSIBLE ALIENS, 2006
Edition, Supplement 5] PMW has documented Jibril Rajoub's continual vocal support for terrorism
in its special…
DataSet-9
EFTA00213861
2 pg
…on Mr. Epstein's behalf believing they are irrelevant to
the civil litigation, certainly inadmissible, and that their production chills the candor of plea negotiations
in future cases thus the order violates the spirit of FRE 410 and 408. We…
DataSet-9
EFTA00802137
2 pg
…THC/PM Response in Opposition to Law of Case Motion 9/28/17
to Strike
23. Chet Response in Opposition to Motion to Strike based on 9/28/17
Reliance on Inadmissible Evidence
24. Scarola Notice of Hearing to hear: …
DataSet-9
EFTA00207639
3 pg
…on Mr. Epstein's behalf believing they are irrelevant to
the civil litigation, certainly inadmissible, and that their production chills the candor of plea negotiations
in future cases thus the order violates the spirit of FRE 410 and 408. We…
DataSet-9
EFTA00207601
2 pg
…on Mr. Epstein's behalf believing they are irrelevant to
the civil litigation, certainly inadmissible, and that their production chills the candor of plea negotiations
in future cases thus the order violates the spirit of FRE 410 and 408. We…
DataSet-9
EFTA00589822
1 pg
…alleged "participation in Epstein's
criminal conduct" referenced in paragraph 16 of the Complaint.
Edwards and Cassell object to this request as being vague, overbroad, and unreasonably
burdensome, as well as seeking irrelevant and inadmissible evidence and information not
…
DataSet-9
EFTA00076468
20 pg
…F. Supp. at 552. To that end, Rule 17(c) subpoenas cannot be used to obtain
documents that would be excluded on hearsay grounds or would otherwise be "inadmissible as
evidence at trial." United States v. Brown, No. 95 CR…
DataSet-9
EFTA01128700
7 pg
…but the copy of the transcript is not signed
and certified by the court reporter or otherwise authenticated and is therefore inadmissible.
Attachment "2" consists of an excerpt of 9-pages of the purported transcript of a deposition of a…
DataSet-9
EFTA00301881
23 pg
…R. CRIM. P. 11(0 ("the admissibility or inadmissibility of . a plea discussion and any
related statement is governed by Federal Rule of Evidence 410").
Obviously, the plaintiffs intend to use the plea negotiation letters "against" Mr. Epstein.
They protested…
DataSet-9
EFTA00589555
3 pg
…to the mediation. All statements made in mediator follow-up thereafter at anytime prior to
complete settlement of this matter are privileged settlement discussions and are non-
discoverable and inadmissible for any purpose including in any legal proceeding. I am…
DataSet-9
EFTA01098037
21 pg
…after intervention. Id. at
1262.
Additionally, no determination has been made by any court concerning the inadmissibility
of plea negotiations against Mr. Epstein under Rule 410, and the plaintiffs do not address this at all
in their papers. The only…
DataSet-9
EFTA00793359
6 pg
…883 So. 2d 387, 389 (Fla. 4`h DCA 2004). "Relevant evidence is inadmissible if its
probative value is substantially outweighed by the danger of unfair prejudice." § 90.403, Fla.
Stat.
Here, as the Court has already ruled, these extrinsic and…
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