Epstein Secrets

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

and trust," and because their confidentiality serves significant public and private ends, they are properly subject to a common law privilege under Federal Rule of Evidence 501. Similar privileges, which are "rooted in the imperative need for confidence and trust" and which serve significant public and private ends, have b

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

ications, either written or oral, made during the course of a mediation. Our decision whether to apply this mediation privilege .. . is governed by Federal Rule of Evidence 501 [and] Jaffee'. Redmond, 518 U.S. 1 (1996) . . . Recognizing that only those documents prepared for purposes of the confidential mediation are prote

RIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK. MARTIN WEINBERG, AND JAY LEFKOWITZ COME NOW Ja

(1) Federal Rule of Evidence 410 or (2) a purported "common law privilege" for "plea negotiations" that the attorneys ask the Court to create under Federal Rule of Evidence 501. The defense arguments are meritless for multiple, independent reasons. With regard to Rule 410, the defense attorneys' efforts to invoke Rule 410

l the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to inte

—and because their continued confidentiality serves significant public and private ends, they are properly subject to a common law privilege under Federal Rule of Evidence 501. Similar privileges, which are rooted in the imperative need for confidence and trust and which serve significant public and private ends, have bee

ORDER grantin8/2i Motion for Extension of Time to File Response/Reply to supplemental briefing in support o£54, MOTION to Intervene of ii ?o, [11 ,Black,Mar i fisiaLi ejkowitz. Responsesdueby1011 011 0/2 . Signed by Judge on 9/28/2011. (ir) (Entered: 09282011) 09/29/2011 .121 Unopposed MOTION for

ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges." Adkins v. Christie, 488 F.3d 1324, 132

os. MISC-J-86.183-14, MISC-J-86-183- 4, Susan H. Black, J., which denied motions to suppress subpoenas.

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

os. MISC-J-86-183-14, MISC-J-86.183. 4, Susan H. Black, J., which denied motions to suppress subpoenas.

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court fords this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

os. MISC-J-86-183-14, MISC-J-86.183- 4, Susan H. Black, J., which denied motions to suppress subpoenas.

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

' MOTION FOR STAY PENDING APPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epst

ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges!" Adkins v. Christie, 488 F.3d 1324, 132

os. MISC-J-86-183-14, MISC-J-86-183- 4, Susan H. Black, J., which denied motions to suppress subpoenas.

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela