EFTA00028880Set 8
2016-01-1123p6,182w
text of the co-
conspirator immunity provision.
Notwithstanding the bedrock principle that plea agreements are construed strictly against
the government, the government asks the Court to simply assume that ... Supp. 2d 1209
(S.D. Fla. 2012), where a corporation had entered into a plea agreement that immunized its
employees, the court held that one of those employees had standing ... United States v. Feldman, 939 F.3d 182 (2d Cir. 2019),
for the proposition that "plea agreements differ from commercial contracts" (Opp. 18), the
"differ[ence]" to which the Second Circuit
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028880.pdf
EFTA00595530Set 9
2010-10-2610p3,672w
Accordingly, the Court takes
judicial notice of the criminal Information [D.E. 1], the Plea Agreement [D.E. 69], and the Judgment [D.E.
290] filed in United States v. Rothstein ... well as the information [D.E. 1],
and plea agreement [D.E. 20-2r filed in United States v. Vilieges, 10.60126-WJZ (S.D. Fla. Apr. 27,
2010). These records were submitted ... Filed 12/14/10 Page 4 of 10
2. Rothstein's Criminal Information and Plea Agreement
In the Criminal Case, on December 1, 2009, Scott W. Rothstein, was charged in five
count
https://www.justice.gov/epstein/files/DataSet%209/EFTA00595530.pdf
EFTA00728201Set 9
2009-03-0253p14,628w
Fed.R.Evid. 408 and 410. These Rules cover the admissibility in evidence of
compromises and plea agreements; they do not set forth a privilege applicable to such agreements in
discovery ... plea of guilty to violations of Florida Criminal
Statutes, including without limitation, the operative plea agreement and any
amendments, revisions and supplements thereto.
Response: Defendant is asserting specific legal objections
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728201.pdf
EFTA00607113Set 9
2015-04-0646p12,645w
which they
-23-
EFTA00607135
consider a limited class of documents, like indictments, jury instructions, plea agreements
and plea colloquies, to determine which alternative formed the basis for a defendant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607113.pdf