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Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz [DE 78] at 6. Second, also in opposing the intervention of attorneys Black, Weinberg, and Lefkowtiz, the plaintiffs argued that "[o]nly Epstein has an interest in the validity of the non-prosecution agreement . . . ." Jane Doe I and Jane Doe 2's R
ment of inconvenience does not go far because many of the issues raised by Mr. Epstein parallel the issues raised by attorneys Black, Weinberg, and Letkowitz as well as those raised during the August 12, 2011 hearing, and Jane Doe 1 and Jane Doe 2 do not have to file their responsive pleadings addressing
ment 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 Epstein." Jane D
materials (if any) could be only to Jeffrey Epstein." Jane Doe 1 and Jane Doe 2's Response To Motion To Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz [DE 78] at 6. Second, also in opposing the intervention of attorneys Black, Weinberg, and Lefkowtiz, the plaintiffs argued that "[o]nly Epstein has
rrive at a just solution of a civil dispute." Lake Utopia Paper Ltd.'. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a conference before oral argument, to hopefully settle their dispute. The Circ
DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the hearing on August 12,
INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDE
rive at a just solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a conference before oral argument, to hopefully settle their dispute. The Circ
s LLP tried to prevent the financier from having to report to New York City police regularly or appear in a public sex-offender database. Attorneys Jay Lefkowitz and Sandra Musumeci recruited the former state prosecutor in Florida who oversaw the original investigation of Mr. Epstein to speak with assistant d
. Epstein avoided the most onerous sex-offender requirements in New York, having established his primary residence in the U.S. Virgin Islands. Mr. Lefkowitz and Ms. Musumeci didn't respond to calls and emails seeking comment. A spokesman for Manhattan District Attorney Cyrus Vance Jr. said Mr. Epstein's
ff in the New York State Office of the Metropolitan Transportation Authority Inspector General. Milton was the longest-serving circuit executive in the Second Circuit's history and the first woman to hold the post. A 2001 graduate of New York University School of Law, Jordan began his legal career as clerk to Circu
s LLP tried to prevent the financier from having to report to New York City police regularly or appear in a public sex-offender database. Attorneys Jay Lefkowitz and Sandra Musumeci recruited the former state prosecutor in Florida who oversaw the original investigation of Mr. Epstein to speak with assistant d
. Epstein avoided the most onerous sex-offender requirements in New York, having established his primary residence in the U.S. Virgin Islands. Mr. Lefkowitz and Ms. Musumeci didn't respond to calls and emails seeking comment. A spokesman for Manhattan District Attorney Cyrus Vance Jr. said Mr. Epstein's
ff in the New York State Office of the Metropolitan Transportation Authority Inspector General. Milton was the longest-serving circuit executive in the Second Circuit's history and the first woman to hold the post. EFTA00092950 A 2001 graduate of New York University School of Law, Jordan began his legal career as
atts-that4ane-Dee-1-ancl4ane-Dee-2-alrea ma . confidemiel,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. EFTA00301857
rrive at a just solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.I979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a conference before oral argument, to hopefully settle their dispute. The Circ
e 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. EFTA00301881
rrive at a just solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.I979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a conference before oral argument, to hopefully settle their dispute. The Circ
Entities connected to both Jay Lefkowitz and the Second Circuit's

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONKirkland & Ellis LLP
ORGANIZATIONLeon Black
PERSONRoy Black
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Ken Starr
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONSouthern District
LOCATIONFBI
ORGANIZATION
Paul Cassell
PERSON