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161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LE
04/17/2012 Page 11 of 23 of disclosure may impede the development of the confidential relationship necessary for successful treatment." Id. at 10. Following Jaffee, three important sets of decisions have recognized privileges under Rule 501 to protect information that is exchanged in an environment that encoura
ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negotiations as substantive evidence in their quest to inva
hat "the mere possibility of disclosure may impede the development of the confidential relationship necessary for successful treatment." Id. at 10. Following Jaffee, three important sets of decisions have recognized privileges under Rule 501 to protect information that is exchanged in an environment that encoura
Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeffrey Epstein opposes the motion of Jane Doe 1 and Jane Doe 2 for dislcosure of all the
hat the mere possibility of disclosure may impede the development of the confidential relationship necessary for successful treatment. Id. at 10. Following Jaffee, three important sets of decisions have recognized privileges under Rule 501 to protect information that is exchanged in an environment that encour
ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non- Prosecution Agreement [DE 51], as well as their motion t
hat "the mere possibility of disclosure may impede the development of the confidential relationship necessary for successful treatment." Id. at 10. Following Jaffee, three important sets of decisions have recognized privileges under Rule 501 to protect information that is exchanged in an environment that encoura
Entities connected to both Jane Doe and Following Jaffee

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONLeon Black
PERSON
Jay Lefkowitz
PERSONMartin Weinberg
PERSONthe Eleventh Circuit
ORGANIZATIONHerman
PERSON
the Fifth Circuit
ORGANIZATIONSantobello
PERSONthe Northern District
LOCATION
Columbia University
LOCATIONAguirre-Gonzalez
PERSONJaffee
PERSON
Armstrong
PERSONFederal Rule of Criminal
ORGANIZATIONthe Second Circuit's
ORGANIZATIONPeterson
PERSONBlackledge v. Allison
PERSON