Epstein Secrets

From: Paul Cassell c To: Jackie Perczek < Cc: USAFLS , "Brad Edwards InSAFLS)" Subject: RE: Position on Motion to Treat MTD as Equivalent to Jurisdictional Question Date: Tue, 06 Aug

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

From: Jackie Perczek <JPerczek®royblack.com> To: Paul Cassell <[email protected]> " r" "Brad Edwards (bradgpathtojustice.com)" <[email protected]> Subject:

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

From: "I To: Paul Cassell <[email protected]>, Jackie Perczek <[email protected]> Cc: 11( >, "Brad Edwards Subject: RE: Position on Motion to Treat MTD as Equivalent to Jurisdictional Question Date: Tue,

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

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

tead Must be Challenged (If Necessary) at the Conclusion of a Case. 11 B. The District Court's Discovery Order is Not Immediately Appealable Under Perlman. 14 II. EPSTEIN HAS NOT PROVEN ANY INJURY WHICH WOULD WARRANT THIS COURT'S EXERCISE OF APPELLATE JURISDICTION 18 CONCLUSION 20 EFTA00209570

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

r may materially advance the ultimate termination of the litigation."' Instead, Epstein claims that he is entitled to an interlocutory appeal under Perlman' United States, 247 U.S. 7 (1918). Epstein claims that "questions of privilege and confidentiality asserted by non-parties to the litigation are pa