The document is a legal reply filed by proposed intervenors Roy Black, Martin Weinberg, and Jay Lefkowitz in the case of Jane Doe 1 and Jane Doe 2 vs. United States of America. The reply argues against the plaintiffs' request for plea negotiation letters, asserting that the plaintiffs are not entitled to these documents to seek invalidation of the non-prosecution agreement with Jeffrey Epstein. The reply emphasizes that the plea negotiations are protected by attorney work-product privilege and common-law privilege under Rule 501. It also argues that collateral estoppel does not apply due to lack of identity of parties and issues. The document discusses the importance of plea negotiations in the criminal justice system and argues against the plaintiffs' interpretation of Rule 410, which governs the admissibility of plea negotiations.
documents/EFTA01106944.pdf
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