Epstein Secrets

lemental Briefing, the Attorney Intervenors discuss a series of common law privileges, including a "mediation privilege" that has been recognized by the Second Circuit, the Central District of California, and the Western District of Pennsylvania, relying on a decision of Judge Marcus. As quoted by the Intervenors,

5-5202 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-mail: [email protected]

lemental Briefing, the Attorney Intervenors discuss a series of common law privileges, including a "mediation privilege" that has been recognized by the Second Circuit, the Central District of California, and the Western District of Pennsylvania, relying on a decision of Judge Marcus. As quoted by the Intervenors,

5-5202 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-mail: [email protected]

and seek Rule 11 sanctions for the allegations. But as a non-party, he lacks standing to bootstrap his way into this case via a Rule 11 motion. As the Second Circuit has explained: 3 EFTA00795276 Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05)16:2011 Page 4 of 8 Although the language of Rule 11

the following using the Court's CM/ECF system: ssistant U.S. Attorneys Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. Boulevaitl, Suite 1300 7 EFTA00795280 Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05)16.2011 Page 8 of 8

ould effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EF

ne Boulevard, 34th Floor Miami, Flo ' Telephone; Facsimile: Attorney or u poenaed Parties Riley Kiraly and William Riley ov Black. Esa. Black, Srebnick, Kornspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 1 Telephone; Facsimile: Attorney or ntervenor Jeffrey Epstein EFTA0