Epstein Secrets

)(4)." United States v. Okun, 2009 WL 790042 at *2 (E.D.Va. 2009). Still another decision at odds with the Government's position is United States v. Rubin, 2008 WL 2358591 (E.D.N.Y. 2008). This decision is instructive because it not only explains that victims have rights before the formal filing of ch

411 (E.D.N.Y. 2008)— specifically contradicts the Government's position that victims are not entitled to obtain information from the Government. In Rubin, crime victims argued that "the government has not provided information with which to pursue restitution in this ease." Id. at 425. The district co

Australian Ave., Suite 400 West Palm Beach, FL 33401 E-mail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 i i FL 33131 ia Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 B° sto MI n

t Palm Beach, FL 33401 E-mail: E-mail: [email protected] Attorneys for the Government Roy Black, Esq. Jackie Perczck, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Ivil m iami FL 33131 Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 S osto

ion of information, because the necessary information had apparently been produced. The Government actions in this case are a far cry from those in Rubin. Rather than providing the victims with material information (or even summaries of that information), the Government has simply stonewalled. The Co

411 (E.D.N.Y. 2008) - specifically contradicts the Government's position that victims are not entitled to obtain information from the Government. In Rubin, crime victims argued that "the government has not provided information with which to pursue restitution in this case." Id. at 425. The district co

The foregoing document was served on May 2. 2011. on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. /11111 Martin G. Weinberg, P.C. Joseph L. Ackerman, Jr. Joseph Ackerman, Jr. Fowler White Burnett PA II EFTA00208023

71(a)(4)." United States. Okun, 2009 WL 790042 at *2 (E.D.Va. 2009). Still another decision at odds with the Government's position is United States' Rubin, 2008 WL 2358591 (E.D.N.Y. 2008). This decision is instructive because it not only explains that victims have rights before the formal filing of ch

he foregoing document was served on May 2, 2011, on the following using the Court's CM/ECF system: S Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. mom Martin G. Weinberg, P.C. Joseph L. Ackerman, Jr. Fowler White Burnett PA _Pi • 29 EFTA00208012

ictims of their rights if the government has not verified to at least an elementary degree that a crime has actually taken place[.]" United States'. Rubin, 558 F.Supp. 2d 411, 419 (E.D.N.Y. 2008). I ANY AMENDMENT TO ADD JANE DOE NO. 3 AND JANE DOE NO. 4 WOULD NOT RELATE BACK UNDER RULE 15(c)(1)(B)

ul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # I and Jane Doe # 2 Roy Black Jackie Perczek Black, Srebnick, Komspan & Stumpf, P.A. Attorneys for Intervenors 25 Government Exhibit A Case No. 08-Ki736-CIV-MARRA EFTA00210593

("the U.S. Attorney didn't have an obligation under the CVRA to confer with [victims] until after was filed and a case opened"); United States v. Rubin, 558 F. Supp. 2d 411, 417 2008) ("the CVRA appears to simply accord [victims] standing to vindicate their rights as victims under the CVRA and to

n G. Weinberg cc: Assistant U.S. Attorney y's Office 500 South Australian Ave Suite 400 West Palm Beach, Florida 33401 Roy Black, Esq. Black, Srebnick, Komspan & Stumpf, 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 7 EFTA00621915