DataSet-9
EFTA01098365
9 pg
…confidential, not discoverable, and
inadmissible as evidence at any proceeding in this case.
I. MANDATORY AND DISCRETIONARY INTERVENTION ARE PROPER
Intervention is proper as a matter of right under Federal Rule of Civil Procedure 24(a)
because Mr. Epstein has…
DataSet-9
EFTA01078948
14 pg
…and unreasonably
burdensome, as well as seeking irrelevant and inadmissible evidence and information not
reasonably calculated to lead to the discovery of admissible evidence. Edwards and Cassell have
collected many pages of documents pointing to Dershowitz's involvement in Epstein…
DataSet-9
EFTA01107917
18 pg
…therefore violate
the Constitution. In addition to and without waiving his constitutional
privileges, the information sought is privileged and confidential, and
inadmissible to the terms of the deferred prosecution agreement, Federal
Rule of Evidence 410 and 408, and § 90.410…
DataSet-9
EFTA01206558
14 pg
…and unreasonably
burdensome, as well as seeking irrelevant and inadmissible evidence and information not
reasonably calculated to lead to the discovery of admissible evidence. Edwards and Cassell have
collected many pages of documents pointing to Dershowitz's involvement in Epstein…
DataSet-9
EFTA00222049
24 pg
…would therefore violate the
Constitution. In addition to and without waiving his constitutional privileges, the
information sought is privileged and confidential, and inadmissible pursuant to
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and
408, and …
DataSet-9
EFTA00205763
5 pg
…P. 11(0; (2) that because the Jane Does are seeking inadmissible evidence, they bear a burden of
showing a proper basis for discovery; (3) that the plea negotiations are irrelevant because the Jane Does are not
entitled to invalidate…
DataSet-9
EFTA01098146
17 pg
…discussions . . .if the discussions did not
result in a guilty plea . . . .' which are inadmissible in proceedings against the defendant making
them under Rule 410." (DE 188 at 5) (citing United States v. Paden, 908 F.2d 1229, 1235 (5th
Cir…
DataSet-9
EFTA01098060
19 pg
…KAM Document 115 Entered on FLSD Docket 10/31/2011 Page 3 of 19
precludes the lawyers and Mr. Epstein from litigating the inadmissibility and privileged nature of
the defense plea negotiation letters and emails. The plaintiffs are mistaken.
First…
DataSet-9
EFTA01098211
19 pg
…Mc Veigh, 119 F.3d 806, 813 (10th Cir.
1997) (there is no constitutional right to access inadmissible evidence).
Finally, as argued earlier, there can be no valid particularized need when Jane Doe 1 and Jane
Doe 2 seek relief…
DataSet-9
EFTA00208448
10 pg
…Evid. 408(b) (while settlement discussions are generally inadmissible, they are
permissible for purposes other than proving the validity of a claim).
7
EFTA00208454
Case 9:08-cv…
DataSet-9
EFTA00209632
24 pg
…a plea of guilty, later
withdrawn; a plea of nolo contendere; or an offer to plead guilty or nolo
contendere to the crime charged or any other crime is inadmissible in any civil or
criminal proceeding."), with Fed. R. Evid…
DataSet-9
EFTA01098114
11 pg
…Crim. P. 11(0 provides, "The admissibility or inadmissibility of a plea, a plea
discussion, and any related statement is governed by Federal. Rule of Evidence 410."
'Federal Rule of Evidence 410 (a) provides in pertinent part:
(a) Prohibited Uses…
DataSet-9
EFTA00209385
24 pg
…a plea of guilty, later
withdrawn; a plea of nolo contendere; or an offer to plead guilty or nolo
contendere to the crime charged or any other crime is inadmissible in any civil or
criminal proceeding."), with Fed. R. Evict…
DataSet-9
EFTA00600191
12 pg
…P. 11(0; (2) that because the
Jane Does are seeking inadmissible evidence, they bear a burden of showing a proper basis for
discovery; (3) that the plea negotiations are irrelevant because the Jane Does are not entitled to
invalidate…
DataSet-9
EFTA01098622
16 pg
…therefore violate
the Constitution. In addition to and without waiving his constitutional
privileges, the information sought is privileged and confidential, and
inadmissible to the terms of the deferred prosecution agreement, Federal
Rule of Evidence 410 and 408, and § 90.410…
DataSet-9
EFTA01168971
12 pg
…P. 11(0; (2) that because the
Jane Does are seeking inadmissible evidence, they bear a burden of showing a proper basis for
discovery; (3) that the plea negotiations are irrelevant because the Jane Does are not entitled to
invalidate…
DataSet-9
EFTA00301909
15 pg
…discussions ); Fed. R. Crim. P. 11(f) ( 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…
DataSet-9
EFTA01199102
11 pg
…Crim. P. 11(0 provides, "The admissibility or inadmissibility of a plea, a plea
discussion, and any related statement is governed by Federal. Rule of Evidence 410."
'Federal Rule of Evidence 410 (a) provides in pertinent part:
(a) Prohibited Uses…
DataSet-9
EFTA01106963
20 pg
…119
F.3d 806, 813 (10th Cir. 1997) (there is no constitutional right to access inadmissible evidence).
Finally, as argued earlier, there can be no valid particularized need when Jane Doe 1 and
Jane Doe 2 seek relief that is…
DataSet-9
EFTA00205542
13 pg
…Mc Veigh, 119 F.3d 806, 813 (10th Cir.
1997) (there is no constitutional right to access inadmissible evidence).
Finally, as argued earlier, there can be no valid particularized need when Jane Doe 1 and Jane
Doe 2 seek relief…
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