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

bly leaving the public exposed to danger) in order to lessen the risk of civil liability." Id. In recognizing the privilege, Judge Vinson relied on Bredice v. Doctor's Hospital, Inc., 50 F.R.D. 249 (D.D.C.1970), the first case to find a common law self-evaluation privilege. There, the hospital held sta

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

spital held staff meetings where the professional staff evaluated the treatment provided to patients. In a medical malpractice action, the estate of Bredice sought the minutes of the hospital's staff meetings where Bredice's treatment or death were discussed. The court denied the discovery, noting that

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

ibly leaving the public exposed to danger) in order to lessen the risk of civil liability." Id. In recognizing the privilege, Judge Vinson relied on Bredice v. Doctor's Hospital, Inc., 50 249 (=.1970), without opin., 479 F.2d 920 (1973), the first case to find a common law self-evaluation privilege.

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

ibly leaving the public exposed to danger) in order to lessen the risk of civil liability." Id. In recognizing the privilege, Judge Vinson relied on Bredice v. Doctor's Hospital, Inc., 50 249 (=.1970), without opin., 479 F.2d 920 (1973), the first case to find a common law self-evaluation privilege.