Epstein Secrets

ca, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should app

PORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of A

defendant's life and liberty. 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 EFTA0

ca, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should app

PORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of A

defendant's life and liberty. 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 EFTA0

V-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the he

MENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FO

and recognizing a mediation 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. 1

ssue in this matter. CONCLUSION For all the foregoing reasons, the requested stay pending appeal should be granted. Respectfully submitted, /s/ Martin G. Weinberg Martin G. Weinberg 20 Park Plaza, Suite 1000 Boston Massachusetts 02116 /s/ Roy Black Roy Black Black, Srebnick, Kornspan & Stumpf 201 South

INTRODUCTION Appellants Roy Black, Martin Weinberg, and Jeffrey Epstein hereby request that this Co

t 2, do not diminish the force of the serious issues raised in this case. 14 EFTA00583752 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). When a defendant is facing loss of liberty, he has an even greater "need for confid

rguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and i

d recognizing a mediation 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 1.SIFtip.2d 1164, 1173 1998); She

rguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and i

d recognizing a mediation 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 1.SIFtip.2d 1164, 1173 1998); She