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

04/17/2012 Page 11 of 23 of disclosure may impede the development of the confidential relationship necessary for successful treatment." Id. at 10. Following Jaffee, three important sets of decisions have recognized privileges under Rule 501 to protect information that is exchanged in an environment that encoura

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

hat "the mere possibility of disclosure may impede the development of the confidential relationship necessary for successful treatment." Id. at 10. Following Jaffee, three important sets of decisions have recognized privileges under Rule 501 to protect information that is exchanged in an environment that encoura

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. In further sup

hat the mere possibility of disclosure may impede the development of the confidential relationship necessary for successful treatment. Id. at 10. Following Jaffee, three important sets of decisions have recognized privileges under Rule 501 to protect information that is exchanged in an environment that encour

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

hat "the mere possibility of disclosure may impede the development of the confidential relationship necessary for successful treatment." Id. at 10. Following Jaffee, three important sets of decisions have recognized privileges under Rule 501 to protect information that is exchanged in an environment that encoura