Epstein Secrets

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

r some of the cost of remediating the land. The defendants sought reports that Reichhold had prepared describing possible environmental violations. Reichhold asserted that these documents were protected by "the privilege of self-critical analysis." Id. at 524. This privilege, "also known as the self-evalu

contamination of groundwater on and under, and storm water runoff from, an industrial plant site it owns in Pensacola, Florida." 157 F.R.D. 523-24. Reichhold brought an action against former owners of the plant site, to recover some of the cost of remediating the land. The defendants sought reports that R

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

f the cost of remediating the land. The defendants sought reports that Reichhold had prepared describing its own possible environmental violations. Reichhold asserted that these documents were protected by the privilege of self-critical analysis. Id. at 524. This privilege, also known as the self-evaluat

ef Judge Vinson and the Common Law Privilege Of Reporting Environmental Hazards and Violations Reichhold Chemicals involved a Consent Order between Reichhold and the Florida Department of Environmental Regulation. The Order obligated Reichhold to investigate and remediate the contamination of groundwate

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

contamination of groundwater on and under, and storm water runoff from, an industrial plant site it owns in Pensacola, Florida." 157 F.R.D. 523-24. Reichhold brought an action against former owners of the plant site, to recover some of the cost of remediating the land. The defendants sought reports that R

r some of the cost of remediating the land. The defendants sought reports that Reichhold had prepared describing possible environmental violations. Reichhold asserted that these documents were protected by "the privilege of self-critical analysis." Id. at 524. This privilege, "also known as the self-evalu

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

f the cost of remediating the land. The defendants sought reports that Reichhold had prepared describing its own possible environmental violations. Reichhold asserted that these documents were protected by "the privilege of self-critical analysis." Id. at 524. This privilege, "also known as the self-eval

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

f the cost of remediating the land. The defendants sought reports that Reichhold had prepared describing its own possible environmental violations. Reichhold asserted that these documents were protected by "the privilege of self-critical analysis." Id. at 524. This privilege, "also known as the self-eval