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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
s counsel to discuss matters in an uninhibited fashion often leading to settlement . ." Id. at 930. Ten years later, in Folb'. Motion Picture hid. Pension & Health Plans, 16 F. Supp. 2d 1164, (C.D.Ca. 1998), the district court in California became the first federal court to adopt the mediation privilege as federal c
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
counsel to discuss matters in an uninhibited fashion often leading to settlement ...." Id. at 930. Ten years later, in Folb v. Motion Picture hid. Pension & Health Plans, 16 F.Supp.2d 1164, 1998), the district court in California became the first federal court to adopt the mediation privilege as federal common law
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
counsel to discuss matters in an uninhibited fashion often leading to settlement ...." Id. at 930. Ten years later, in Folb v. Motion Picture hid. Pension & Health Plans, 16 F.Supp.2d 1164, 1998), the district court in California became the first federal court to adopt the mediation privilege as federal common law
Entities connected to both Jay Lefkowitz and Pension & Health Plans

Jeffrey Epstein
PERSONLeon Black
PERSONRoy Black
PERSON
Kenneth Marra
PERSON
United States
LOCATIONJane Doe
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSONHerman
PERSONthe Eleventh Circuit
ORGANIZATION
Bradley Cooper
PERSONEmmy Taylor
PERSON
Columbia University
LOCATIONFederal Rule of Criminal
ORGANIZATIONSantobello
PERSON
the Fifth Circuit
ORGANIZATIONthe Northern District
LOCATIONHickman
PERSONJaffee
PERSONABA Model
ORGANIZATION