3
Shared Docs
3
Same-Page
5 / 3
Mentions
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
s and emails that Jane Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56), as well as during the August 12, 2011 hearing.
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
9:08-cv-80736-KAM Document 93 Entered on FLSD Docket 09/02/2011 Page 3 of 9 First, they argued in their opposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is the real party in interest" and that "harm from the release of the materials (if any) could be only to Jeffrey
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
s and emails that Jane Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56], as well as during the August 12, 2011 hearing.
Entities connected to both Reichhold and Black, Weinberg

Jeffrey Epstein
PERSONLeon Black
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSONHerman
PERSON
Columbia University
LOCATIONJaffee
PERSON
Scarlett Johansson
PERSONStanding Committee On Rules of Practice And Procedure
ORGANIZATIONABA Model
ORGANIZATIONRoy Black
PERSONPeterson
PERSONPensacola
LOCATIONVinson
PERSONHobson
PERSONFederal Aviation Regulations
ORGANIZATIONTextron, Inc.
ORGANIZATION