Epstein Secrets

e 9:08-cv-80736-KAM Document 100 Entered on FLSD Docket 09/27/2011 Page 2 of 12 has been waived. The United States further agrees that, in light of the Supreme Court's guidance on the Sixth Amendment Right to Counsel, the protections provided to civil mediation proceedings should extend to confidential plea negoti

ke City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 371-06421 Fax (305) 358-2006 E-ma

e 9:08-cv-80736-KAM Document 100 Entered on FLSD Docket 09/27/2011 Page 2 of 12 has been waived. The United States further agrees that, in light of the Supreme Court's guidance on the Sixth Amendment Right to Counsel, the protections provided to civil mediation proceedings should extend to confidential plea negoti

ke City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 371-06421 Fax (305) 358-2006 E-ma

ed "against" the defendant in a "proceeding," and that fairness not require "contemporaneous" introduction of all aspects of the negotiations). But the Supreme Court has made clear that courts must be "especially reluctant to recognize a privilege in an area where it appears that Congress has considered the relev

n the following using the Court's CM/ECF system: Assistant U.S. Attorneys West Palm Beach FL 33401 Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. BI k r ni k K rns an pf, P.A. iami, 27 EFTA00205754

contains attorney work produce and, if so, whether that work product privilege has been waived. The United States further agrees that, in light of the Supreme Court's guidance on the Sixth Amendment Right to Counsel, the protections provided to civil mediation and arbitration proceedings should extend to confident

EY EFTA00205765 t with the Cler to receive noti Brad Edwards, Esq., Paul G. Cassell a ttorneys or ane oe an ane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. ' P.A. EFTA00205766 Attorneys for Intervenors Jeffrey Epstein, Roy Black, Martin Weinberg, and Jay Lefkowitz fine United States uses the

ms. The victims made two principal arguments for dismissal: first, that this Court lacks jurisdiction over such an interlocutory appeal in light of the Supreme Court's recent decision in Mohawk Industries, Inc.'. Carpenter, 130 S. Ct. 599 (2009) (attorney-client privilege ruling not immediately appealable; any inj

05 CERTIFICATE OF SERVICE The foregoing document was served on July 16, 2013, on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. Martin G Weinberg, P.C. /s/ Paul G. Cassell Paul G. Cassell 1 EFTA00209506

iminal prosecutors seeking to force him to plead guilty to criminal charge. Moreover, the cases Epstein relies upon are older cases, decided before the Supreme Court's recent decision in Mohawk. The Mohawk decision makes clear that even as to highly sensitive attorney-client materials, "[a]ppellate courts can reme

28 CERTIFICATE OF SERVICE The foregoing document was served on July 12, 2013, on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. ,ill e• A et• 11 1 1 M ( ( Martin G. Weinberg Martin G. Weinberg, PC Paul G. Cassell EFT

S COURT LACKS JURISDICTION TO ENTERTAIN EPSTEIN'S INTERLOCUTORY APPEAL OF THE DISTRICT COURT'S DISCOVERY ORDER DIRECTED TO THE GOVERNMENT. 10 A. The Supreme Court's Recent Decision in Mohawk Makes Clear that Privilege Rulings During Discovery are Not Immediately Appealable But Instead Must be Challenged (If Nec

The foregoing document was served on July 2, 2013, on the following using the Court's CMJECF system: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. /s/ Paul G. Cassell Paul G. Cassell 22 EFTA00209594

picuously chosen to ignore recent controlling caselaw from the Supreme Court, which makes clear that an interlocutory appeal is not permitted. A. The Supreme Court's Recent Decision in Mohawk That Attorney-Client Privilege Rulings are Not Immediately Appealable Limits the Perlman Doctrine to Non-Litigants in a C

he foregoing document was served on June 28, 2013, on the following using the Court's CM/ECF system: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 16 EFTA00209615