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

nnelly Containers, Inc., 608 F.2d 928 (2d Cir.1979); Folb v. Motion Picture Incl. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldone v. Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation v. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan

with the fact that many federal district courts rely on the success of ADR proceedings to minimize the size of their dockets." Id. More recently in Sheldone v. Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000), the court relied on Jaffee and on Judge Marcus' decision in In re Air Crash

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

Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979); Folb v. Motion Picture Ind. Pension & Health Plans, 16 F.Supp.2d 1164, 1173 (C.D.Ca. 1998); Sheldone v. Pennsylvania Turnpike Comm n, 104 F.Supp.2d 511, (W.D.Pa. 2000); Microsoft Corporation v. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal Jan. 6,

with the fact that many federal district courts rely on the success of ADR proceedings to minimize the size of their dockets. Id. More recently in Sheldone v. Pennsylvania Turnpike Commission, 104 F.Supp.2d 511, (W.D.Pa. 2000), the court relied on Jaffee and on Judge Marcus decision in In re Air Crash

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

td. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979); Folb v. Motion Picture Ind. Pension & Health Plans, 16 1.SIFtip.2d 1164, 1173 1998); Sheldone v. Pennsylvania Turnpike 104 F.Supp.2d 511, 2000); Microsoft Corporation v. Suncrest Enterprise, 2006 WL 929257 Cal Jan. 6, 2006). E. JUDGE M

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

td. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979); Folb v. Motion Picture Ind. Pension & Health Plans, 16 1.SIFtip.2d 1164, 1173 1998); Sheldone v. Pennsylvania Turnpike 104 F.Supp.2d 511, 2000); Microsoft Corporation v. Suncrest Enterprise, 2006 WL 929257 Cal Jan. 6, 2006). E. JUDGE M