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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
mpromised by any disclosure, regardless of whether the communications are later excluded as evidence in proceedings in this case. The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant 5 EFTA00205564 Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2
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
inadmissibility would be compromised by any disclosure whether or not it was later excluded as evidence against the intervenor. The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant settled and was dismissed from the lawsuit. The remaining defendants later moved to
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
e inquiry must have some evidentiary value before an order to compel disclosure of otherwise inadmissible material will issue ). The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant settled and was dismissed from the lawsuit. The remaining defendants later moved to
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
he inquiry must have some evidentiary value before an order to compel disclosure of otherwise inadmissible material will issue"). The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant settled and was dismissed from the lawsuit. The remaining defendants later moved to
Entities connected to both Jane Doe and Bottaro

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