Epstein Secrets

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

he inadmissible evidence is likely to lead to admissible evidence." Reist v. Source Interlink Co., 2010 WL 4940096 at *2 (M.D. Fla. Nov. 29, 2010); Bottaro v. Hatton Assocs., 96 F.R.D. 158, 159-60 (E.D.N.Y. 1982) ("the object of the inquiry must have some evidentiary value before an order to compel disclosure of otherwi

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

the inadmissible evidence is likely to lead to admissible evidence." Reist v. Source Interlink Co., 2010 WL 4940096 at *2 (M. Fla. Nov. 29, 2010); Bottaro v. Hatton Assocs., 96 158, 159-60 1982) ("the object of the inquiry must have some evidentiary value before an order to compel disclosure of otherwise inadmissibl

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

the inadmissible evidence is likely to lead to admissible evidence." Reist v. Source Interlink Co., 2010 WL 4940096 at *2 (M. Fla. Nov. 29, 2010); Bottaro v. Hatton Assocs., 96 158, 159-60 1982) ("the object of the inquiry must have some evidentiary value before an order to compel disclosure of otherwise inadmissibl