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P. 24.1 For purposes of this memorandum, those intervening parties will be separated into four "groups." A. Group 1: Attorneys Black, Weinberg, and Letkowitz The first group contains attorneys Roy Black, Martin Weinberg, and Jay Leflcowitz, who all represented Jeffrey Epstein in connection with a federal
parated into four "groups." A. Group 1: Attorneys Black, Weinberg, and Letkowitz The first group contains attorneys Roy Black, Martin Weinberg, and Jay Leflcowitz, who all represented Jeffrey Epstein in connection with a federal criminal investigation. The three moved for "limited" intervention "for the purpo
casions. His first "Motion for Limited Intervention" was filed in 2011 and was based on the same grounds advanced by Attorneys Black, Weinberg, and Lefkowitz (see DE93). The district court granted the motion and allowed Epstein to seek a protective order (DEI 59). Epstein's motion for protective order (D
o pre-trial settlement procedures, asserting a First Amendment right of access, and the courts denied such access. In Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit similarly recognized that "confidential settlement communications are a tradition in this country."
P. 24.1 For purposes of this memorandum, those intervening parties will be separated into four "groups." A. Group 1: Attorneys Black, Weinberg, and Lefkowitz The first group contains attorneys Roy Black, Martin Weinberg, and Jay Leflcowitz, who all represented Jeffrey Epstein in connection with a federal
parated into four "groups." A. Group 1: Attorneys Black, Weinberg, and Lefkowitz The first group contains attorneys Roy Black, Martin Weinberg, and Jay Leflcowitz, who all represented Jeffrey Epstein in connection with a federal criminal investigation. The three moved for "limited" intervention "for the purpo
to pre-trial settlement procedures, asserting a First Amendment right of access, and the courts denied such access. In Goodyear Tire & Rubber Co. I Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit similarly recognized that "confidential settlement communications are a tradition in this country."
a civil EFTA00211680 purposes of this memorandum, those parties will be separated into four "groups." A. Group 1: Attorneys Black, Weinberg, and Letkowitz The first group contains attorneys Roy Black, Martin Weinberg, and Jay Leflcowitz, who all represented Jeffrey Epstein in connection with a federal
parated into four "groups." A. Group 1: Attorneys Black, Weinberg, and Letkowitz The first group contains attorneys Roy Black, Martin Weinberg, and Jay Leflcowitz, who all represented Jeffrey Epstein in connection with a federal criminal investigation. The three moved for "limited" intervention "for the purpo
that a "person accused of the crime may not obtain any form of relief under this chapter." 18 U.S.C. § 3771(d)(1). 5 EFTA00211684 & Rubber Co.I Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit went further, finding that settlement communications were privileged and not discoverable.3 Id. At
compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would
a settlement privilege which insulates them not just from admission into evidence but from discovery as well. See, M, Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to settlement negotiations in bot
compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley. 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would
ettlement privilege which insulates them not just from admission into evidence but from discovery as well. See, Lls-, Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to settlement negotiations in bot
Entities connected to both Jay Lefkowitz and Chiles Power Supply, Inc.

Jeffrey Epstein
PERSONLeon Black
PERSONRoy Black
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
United States
LOCATIONJane Doe
PERSONMartin Weinberg
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSONRobert C. Josefsberg
PERSON
George W. Bush
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSON
Palm Beach
LOCATION
Harvey Weinstein
PERSONKatherine W. Ezell
PERSONScott Rothstein
PERSON
West Palm Beach
LOCATION