Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the hearing on August 12, 2011, the Court directed the proposed intervenors to file additional briefing on their argument that plea negotiations are privileged and not subject to discovery or use as evidence in these proceedings. Proposed intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of h is motion fora protective order and his opposition to the motions of the plaintiffs for production, use, and disclosure of his plea negotiations. If allowed to intervene, the lawyers would incorporate these arguments into their motion for a protective order, which was attached to their initial motion to intervene. Established case law as well as sound and substantial policy considerations prohibit disclosure of the letters and emails prepared by Mr. Epstein's lawyers during plea negotiations with the government, and require that the letters and emails that Jane Doe I and Jane Doe 2 already have remain confidential. In support of their position, proposed intervenors submit this memorandum EFTA02753778