Epstein Secrets

161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LE

n information that the state has and will use against the defendant is not simply a matter of common sense, . . . it is the duty of the lawyer ...." Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp).2 The constitution also requires that crimi

ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negotiations as substantive evidence in their quest to inva

the state has and will use against the defendant is not simply a matter of common sense, . . . it is the duty of the lawyer .. . ." EFTA00301867 Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp).' The constitution also requires that crim

Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeffrey Epstein opposes the motion of Jane Doe 1 and Jane Doe 2 for dislcosure of all the

formation that the state has and will use against the defendant is not simply a matter of common sense, . . . it is the duty of the lawyer . . . . Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4 4.1 (2d ed. 1982 Supp).O The constitution also requires that crim

ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non- Prosecution Agreement [DE 51], as well as their motion t

the state has and will use against the defendant is not simply a matter of common sense, . . . it is the duty of the lawyer .. . ." EFTA00301890 Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp).' The constitution also requires that crim

d Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and Disclosure of Plea Negotiations (Doc. 162); Notice of Supplemental Authority of the United States Supreme Court (Doc. 163);

nment, especially information that the government intends to use against the client. Failure to do so constitutes ineffective assistance of counsel. Rompilla v. Beard, 545 U.S. 374 (2005). "The notion that defense counsel must obtain information that the state has and will use against the defendant is no