Epstein Secrets

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,

te and a neutral assessment of the relative strengths of the opposing positions." Sheldon v. Pennsylvania Turnpike Comm'n, 104 F. Supp. 2d 511, 513 (W.D. Pa. 2000). In other words, the parties are allowed to disclose documents and information normally covered by the attorney work product privilege without fea

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,

te and a neutral assessment of the relative strengths of the opposing positions." Sheldon v. Pennsylvania Turnpike Comm'n, 104 F. Supp. 2d 511, 513 (W.D. Pa. 2000). In other words, the parties are allowed to disclose documents and information normally covered by the attorney work product privilege without fea

endant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT O

on 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. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Re

OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited in

privile e. Nevertheless, we find persuasive the reasoning set forth by the court in Sheldone I. Pennsylvania Turnpike Comnen, 104 F. Supp. 2d 511 (W.D. Pa. 2000), and by other courts that have adopted the federal mediation privilege." Software Tree LLC RedHat Inc., 2010 WL 2788202 at *4 (E.D.Tex. June 24,

their opposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is th

tion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldon I. Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Repo

sing the CM/ECF system. Respectfully submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 South Bi

Motion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldon Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation'. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Rep