Epstein Secrets

ORDER OF THE UNITED STATES DISTRICT COURT FOR THE 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

n the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923 Date Filed: 08/05/2013

come of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923 Date Filed: 08/05/2013 Page: 3 of

RS/APPELLANTS ROY BLACK, MARTIN G. WEINBERG, AND JEFFREY EPSTEIN Roy Black Jackie Perczek Black, Srebni

ly pursued their civil monetary remedies against Mr. Epstein to completion — plaintiffs sought to use that co

the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its opportunity to do so in the future." Id. at 239. The same is true here. The Court found no appellate jurisdict

ed. R. Evid. 501 4, 16 iv EFTA00209469 Case: 13-12923 Date Filed: 07/12/2013 Page: 6 of 25 INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its 10 EFTA00209479 Case: 13-12923 Date Filed: 07/12/2013 Page: 16 of 25 opportunity to do so in the future."

ed. R. Evid. 501 4, 16 iv EFTA00209538 Case: 13-12923 Date Filed: 07/12/2013 Page: 6 of 25 INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its 10 EFTA00209548 Case: 13-12923 Date Filed: 07/12/2013 Page: 16 of 25 opportunity to do so in the future."

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

e impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non- party, would have lost its opportunity to do so in the future." Id. at 239. The same is true here. The Court found no appellate jurisdict

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4, . Instead, he pled guilty to two state offenses, one of which was a fel

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

e impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non- party, would have lost its opportunity to do so in the future." Id. at 239. The same is true here. The Court found no appellate jurisdict

07 (emphasis added). This conclusion underscores that inapplicability of Mohawk in the present circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to the litigation, having intervened solely for the limited purpose of seeking to prevent the disclosu

circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to

the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its opportunity to do so in the future." hi. at 239. The same is true here. The Court found no appellate jurisdict

07 (emphasis added). This conclusion underscores the inapplicability of Mohawk in the present circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to the litigation, having intervened solely for the limited purpose of seeking to prevent the disclosu

ircumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to

the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise the issue in an interlocutory appeal, Quellos, as a non-party, would have lost its opportunity to do so in the future." Id. at 239. The same is true here. The Court found no appellate jurisdict

Asia, providing some geographic diversification. Jeffrey Altman Alp: 0.2 Overseas Fund Ltd. MBZ 1996 Tru

ents and special purpose fund investments primarily with the 1996 Trust, MBZ 1983 Family Trust, general partners and investment managers underlying Quellos absolute return and private capital funds of funds. MBZ Crut MorganStanley SmithBarney 146 EFTA00283598 Mortimer B. Zuckerman and Related Enti