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barred from delving further into the confidential plea negotiations. At the hearing on August 12, 2011, the Court heard oral argument from Attorney Black, who 'The United States uses the term "confidential" plea negotiations as a term of art. By definition, all plea negotiations are confidential and,
rty. In plea negotiations, the need for "counsel to discuss matters in an uninhibited fashion" is even more important. See Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928, 930 (2d Cir. 1979). Likewise, where a defendant is facing the loss of liberty, he has an even 10 EFTA00600200 Case 9:08-cv-
barred from delving further into the confidential plea negotiations. At the hearing on August 12, 2011, the Court heard oral argument from Attorney Black, who 'The United States uses the term "confidential" plea negotiations as a term of art. By definition, all plea negotiations are confidential and,
rty. In plea negotiations, the need for "counsel to discuss matters in an uninhibited fashion" is even more important. See Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928, 930 (2d Cir. 1979). Likewise, where a defendant is facing the loss of liberty, he has an even 10 EFTA00657048 Case 9:08-cv-
endant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT O
on privilege where litigants can "rely on the confidential treatment of everything that transpires during mediation ...." Lake Utopia Paper Ltd. v. Connelly 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. Penns
NITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenors/Appellants ON APPEAL FROM A
27 *Lafler v. Cooper, 132 S. Ct. 1376 (2012) 8, 12 Long v. Raymond Corp., 245 Fed. Appx. 912 (11th Cir. 2007) 6 Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir. 1979), cert. denied, 444 U.S. 1076 (1980) 34,37,38 Marino v. Ortiz, 484 U.S. 301 (1988) 52 Mezu v. Morgan State Uni
ll the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to inte
able to poker players in a high-stakes game than adversaries attempting to arrive at a just solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.I979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a
l the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to inte
privilege where litigants can rely on the confidential treatment of everything that transpires during mediation . . . . Lake Utopia Paper Ltd. v. 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. Pennsylv
l the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to inter
able to poker players in a high-stakes game than adversaries attempting to arrive at a just solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.I979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a
Entities connected to both Leon Black and Connelly Containers

Jeffrey Epstein
PERSONRoy Black
PERSON
United States
LOCATIONJack Goldberger
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Bradley Edwards
PERSON
Jay Lefkowitz
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Scarlett Johansson
PERSONSouthern District
LOCATION
Paul Cassell
PERSON
Supreme Court
ORGANIZATION
Robert Mueller
PERSONSrebnick
PERSON
Salt Lake City
LOCATION
Columbia University
LOCATION
S.J. Quinney College of Law
ORGANIZATION
the University of Utah
ORGANIZATION