4
Shared Docs
4
Same-Page
8 / 4
Mentions
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
), the district court in California became the first federal court to adopt the mediation privilege as federal common law under Rule 501. Relying on Lake Utopia Paper as well as a number of other decisions addressing the confidentiality of settlement negotiations, Folb held that "the need for confidentiality and
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
), the district court in California became the first federal court to adopt the mediation privilege as federal common law under Rule 501. Relying on Lake Utopia Paper as well as a number of other decisions addressing the confidentiality of settlement negotiations, Folb held that "the need for confidentiality and
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 district court in California became the first federal court to adopt the mediation privilege as federal common law under Rule 501. Relying on Lake Utopia Paper as well as a number of other decisions addressing the confidentiality of settlement negotiations, Folb held that "the need for confidentiality and
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 district court in California became the first federal court to adopt the mediation privilege as federal common law under Rule 501. Relying on Lake Utopia Paper as well as a number of other decisions addressing the confidentiality of settlement negotiations, Folb held that "the need for confidentiality and
Entities connected to both Jay Lefkowitz and Lake Utopia Paper

Jeffrey Epstein
PERSONLeon Black
PERSONRoy Black
PERSON
Kenneth Marra
PERSON
United States
LOCATIONJane Doe
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSONHerman
PERSONthe Eleventh Circuit
ORGANIZATION
Columbia University
LOCATIONFederal Rule of Criminal
ORGANIZATIONSantobello
PERSONthe Northern District
LOCATION
the Fifth Circuit
ORGANIZATIONABA Model
ORGANIZATION
Armstrong
PERSONJaffee
PERSONHawkman
PERSONAguirre-Gonzalez
PERSON