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ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion
orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as
and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to
ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion
orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as
and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to
1 Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Austral
e District Court in similar circumstancesr I Exhibit B, at 35-36. Edwards supported this last statement with the following authorities: See, e.g., Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414, 1429 (3d Cir. 1991) (Westinghouse's disclosure of work product materials to the Justice Department d
Entities connected to both Jack Goldberger and Westinghouse Electric Corp.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONLeon Black
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSONSouthern District
LOCATIONRoy Black
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATIONWeiss
PERSON