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victims"), by and through undersigned counsel, to respond in opposition to Intervenors' Motion for Stay Pending Appeal (DE 193). The intervenors — Jeffrey Epstein and his team of defense lawyers (hereinafter referred to collectively as "Epstein") -- have requested a stay of the Court's order requiring disclos
otion for Stay Pending Appeal (DE 193). The intervenors — Jeffrey Epstein and his team of defense lawyers (hereinafter referred to collectively as "Epstein") -- have requested a stay of the Court's order requiring disclosure of correspondence connected with plea negotiations on behalf of Epstein relatin
Stay Pending Appeal (DE 193). The intervenors — Jeffrey Epstein and his team of defense lawyers (hereinaf
baseless and thus Epstein cannot demonstrate a likelihood of success on the merits and the other requirements for obtaining a stay pending appeal. I. EPSTEIN CANNOT TAKE AN INTERLOCUTORY APPEAL OF THIS COURT'S DISCOVERY ORDER. Epstein has asked the Court for a stay "pending appeal." (DE 193 at I). This r
nt the victims to read the correspondence. Epstein must present evidence that he will be injured if the victims read the correspondence. See, e.g., Northeastern Florida Chapter of Ass'n of General Contractors of America I. City of Jacksonville, Fla., 896 F.2d 1283, 1286 (11th Cir. 1990) ("Because plaintiff presente
ane Doe No. 2 ("the victims") respectfully file this opposition to the motion for a stay pending appeal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referred to as "Epstein"). At issue is correspondence between federal prosecutors and Epstein's criminal defense
the motion for a stay pending appeal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referred to as "Epstein"). At issue is correspondence between federal prosecutors and Epstein's criminal defense attorneys concerning plea negotiations. The victims have a
peal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referre
orrespondence. Epstein must present evidence that he will be injured — and injured irreparably — if the victims read the correspondence. See, e.g., Northeastern Florida Chapter of Ass 'rt of General Contractors of America City of Jacksonville, Fla., 896 F.2d 1283, 1286 (11th Cir. 1990) ("Because plaintiff presented
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
are concerned, the irreparable injury inheres in their very disclosure. See Motion at and cases cited therein. The single case cited by plaintiff, Northeastern Florida Chapter of of Gen. Contractors of America v. City of Jacksonville, 896 F.2d 1283 (11th Cir. 1990), did not involve privileged or confidential comm
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
ncerned, the irreparable injury inheres in their very disclosure. See Motion at 15-17, and cases cited therein. The single case cited by plaintiff, Northeastern Florida Chapter of Ass'n of Gen. Contractors of America v. City of Jacksonville, 896 F.2d 1283 (11th Cir. 1990), did not involve privileged or confidential
Entities connected to both Jeffrey Epstein and Northeastern Florida
Leon Black
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Michael Cohen
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Wilbur Ross
PERSON
Scarlett Johansson
PERSONRoy Black
PERSONNadia Marcinkova
PERSON
Jacksonville
LOCATION
Supreme Court
ORGANIZATION
Alberto Gonzales
PERSONFISTOS & LEHRMAN
ORGANIZATIONRubin
PERSONthe Eleventh Circuit
ORGANIZATIONO'Brien
PERSONSrebnick
PERSON