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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
very of admissible evidence and the defendants have not made any showing to the contrary, this justification for [discovery] must fail. Id.; accord Reist, 2010 WL 4940096 at '2 (recognizing the "chilling effect" that discovery can have on the willingness of parties to enter into settlement negotiation
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
ery of admissible evidence and the defendants have not made any showing to the contrary, this justification for [discovery] must fail. Id.; accord Reist, 2010 WL 4940096 at *2 (recognizing the "chilling effect" that discovery can have on the willingness of parties to enter into settlement negotiation
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
very of admissible evidence and the defendants have not made any showing to the contrary, this justification for [discovery) must fail. Id.; accord Reist, 2010 WL 4940096 at '2 (recognizing the chilling effect that discovery can have on the willingness of parties to enter into settlement negotiations
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
ery of admissible evidence and the defendants have not made any showing to the contrary, this justification for [discovery] must fail. Id.; accord Reist, 2010 WL 4940096 at *2 (recognizing the "chilling effect" that discovery can have on the willingness of parties to enter into settlement negotiation
Entities connected to both Jane Doe and Reist

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