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

mpromised by any disclosure, regardless of whether the communications are later excluded as evidence in proceedings in this case. The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant 5 EFTA00205564 Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2

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

inadmissibility would be compromised by any disclosure whether or not it was later excluded as evidence against the intervenor. The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant settled and was dismissed from the lawsuit. The remaining defendants later moved to

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

e inquiry must have some evidentiary value before an order to compel disclosure of otherwise inadmissible material will issue ). The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant settled and was dismissed from the lawsuit. The remaining defendants later moved to

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

he inquiry must have some evidentiary value before an order to compel disclosure of otherwise inadmissible material will issue"). The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant settled and was dismissed from the lawsuit. The remaining defendants later moved to