Jane Doe #1 and Jane Doe #2 respond to the motion for protective orders filed by defense attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz, and intervenor Jeffrey Epstein. The response argues against the application of Federal Rule of Evidence 410 and a proposed 'common law privilege' to protect plea bargaining correspondence from discovery. The document also addresses the Government's claim of work product protection over the correspondence.
documents/EFTA01081982.pdf
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