Epstein Secrets

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

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

has an interest in the validity of the non-prosecution agreement . . . ." Jane Doe I and Jane Doe 2's Response To Motion To Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz [DE 78] at 4. And third, in their "Motion to Use Correspondence To Prove Violations of The Crime Victim 's Rights Act And To Hav

pposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is the real par

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

t with the *226 defense by decid- ing after two years that it wanted a new ex- pert. Id. The court also denied as premature Fell's motion to exclude Weiner's testi- mony, holding that the nature and scope of Webees anticipated rebuttal testimony was unclear but that, even without interviewing Fell, hi

factors concerning sentencing." Id. Accordingly, the court declined to rule on admissibility prior to the government's disclosure of the scope of Weiner's projected testimony. Pursuant to the court's April 7 2005 or- der, Wetzel interviewed Fell and prepared a report explaining his findings. Fell, 2

. 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

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

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