Epstein Secrets

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

a, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reiclzhold Chemicals, Inc. v. Textron, Inc., 157 F.R.D. 522 (N.D. Fla. 1994); and by a number of district courts recognizing a mediation privilege which shields from disclosure and use mediation documents, l

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

tamination and other environmental violations to the Florida Department of Environmental Regulation, Reichold Chemicals, Inc. v. Textron, Inc., 157 F.R.D. 522 (N.D. Fla. 1994); and a number of district court decisions denying discovery and recognizing a mediation privilege where litigants can rely on the

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

mbia, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reichhold Chemicals, Inc.. Textron, Inc., 157 F.R.D. 522 (N.D. Fla. 1994); and by a number of district courts recognizing a mediation privilege which shields from disclosure and use mediation documents, l

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

. Chief Judge Vinson and the Common Law Privilege Of Reporting Environmental Hazards and Violations, Reichhold Chemicals, Inc. Textron, Inc., 157 F.R.D. 522 (NJ). Fla. 1994) Reichhold Chemicals involved a Consent Order between Reichhold and the Florida Department of Environmental Regulation. The Order o