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e foregoing reasons, the Court should deny plaintiffs' motion to dismiss. Respectfully submitted, /s/ Roy Black Roy Black Jackie Perczek Black, Srebnick, Komspan & Stumpf /s/ Martin G. Weinberg Martin G. Weinberg Intervenor/Appellants and Attorneys for Intervenor/Appellants CERTIFICATE OF SERVICE

Y BLACK ET AL., Intervenor/Appellants INTERVENORS' RESPONSE TO MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf Martin G. Weinberg EFTA00209465 Case: 13-12923 Date Filed: 07/12/2013 Page: 2 of 25 TABLE OF CONTENTS INTRODUCTION AND FA

e deposition testimony. plaintiff, who was the privilege holder rather than the deponent, could appeal that decision after final judgment. Notably, the Wilson Court stated that "when the person who asserts a privilege is a non-litigant," "an appeal from a final judgment [will] be inadequate." In Holt-Orstedi Ci

Y BLACK ET AL., Intervenor/Appellants INTERVENORS' RESPONSE TO MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf 201 South Biscayne Boulevard Martin G. Weinberg EFTA00209534 Case: 13-12923 Date Filed: 07/12/2013 Page: 2 of 25 TABLE OF

e deposition testimony. plaintiff, who was the privilege holder rather than the deponent, could appeal that decision after final judgment. Notably, the Wilson Court stated that "when the person who asserts a privilege is a non-litigant," "an appeal from a final judgment [will] be inadequate." In Holt-Orstedi Ci

SOUTHERN DISTRICT OF FLORIDA BRIEF OF INTERVENORS/APPELLANTS ROY BLACK, MARTIN G. WEINBERG, AND JEFFREY EPSTEIN Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Tel: (305) 371-6421 Fax: (305)358-2006 [email protected] jp

e deposition testimony, plaintiff, who was the privilege holder rather than the deponent, could appeal that decision after final judgment. Notably, the Wilson Court stated that "when the person who asserts a privilege is a non-litigant," "an appeal from a final judgment [will] be inadequate." In Holt-Orsted v.

Court should deny plaintiffs' motion to dismiss. Respectfully submitted, hi Roy Black hi Martin G. Weinberg Roy Black Martin G. Weinberg Black, Srebnick, Kornspan & 20 Park Plaza, Suite 1000 Stumpf Boston, Massachusetts 02116 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Interven

e deposition testimony, plaintiff, who was the privilege holder rather than the deponent, could appeal that decision after final judgment. Notably, the Wilson Court stated that "when the person who asserts a privilege is a non-litigant," "an appeal from a final judgment [will] be inadequate." In Holt-Orsted v.