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egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by t
f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.
idence stronger than in the context of a valid grand jury subpoena.'" In re Grand Jury Proceedings , 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case , 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena , 223 F.3d 213, 218 (3d Cir. 2000) ("One EFTA00211781 of the most signi
egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by t
f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.
idence stronger than in the context of a valid grand jury subpoena.'" In re Grand Jury Proceedings , 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case , 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena , 223 F.3d 213, 218 (3d Cir. 2000) ("One EFTA00222997 of the most signi
portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, except for a few short portions by Jack Goldberger — have been redacted"). 10 EFTA00583789 address Mr. Epstein's arguments regarding the recognition of a privilege under Fed. R. Civ. P. 501. As
ttorneys, except for a few short portions by Jack Goldberger — have been redacted"). 10 EFTA00583789 addr
n formally recognized is not a bar to Perlman jurisdiction. The controlling factor is whether the appellants assert a right or privilege, see In re Sealed Case, F.3d , 2013 WL 2120157 at *4 6 EFTA00583785 (D.C.Cir. March 5, 2013)("The Perlman doctrine permits appeals from some decisions that are not f
rrespondence written by 3 EFTA00584605 government attorneys — all of the writings of Mr. Epstein's attorneys, except for a few short portions by Jack Goldberger — have been redacted"). Once the CVRA action was re-activated — after plaintiffs had successfully pursued their civil monetary remedies against Mr.
torneys, except for a few short portions by Jack Goldberger — have been redacted"). Once the CVRA action was
ognized under Rule 501 is not a bar to Perlman jurisdiction. The controlling factor is whether the appellants assert a right or privilege, see In re Sealed Case, F.3d , 2013 WL 2120157 at *4 (D.C.Cir. March 5, 2013)("The Perlman doctrine permits appeals from some decisions that are not final but allow the
d solicitation offense is a felony. -3- EFTA00179102 pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of Epstein knew of the state investigation by the first week of
attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.'
evidence stronger than in the context of a valid grand jury subpoena.' In re Grand Jury Proceedings, 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case, 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena, 223 F.3d 213, 218 (3d Cir. 2000) ("One of the most significant, if not th
-013282 to 83). The entry here reads: "7/08/08 email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Goldberger's letter re victim notification." In responding to defense attorney Goldberger's letter about victim notification, the U.S. Attorney's Office had
s (including telephone logs and telephone billing statements) made by or received by Reinhart from Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any other person involved with the criminal defense of Jeffrey Epstein, including telep
). Communications Facilitating Crime-Fraud-Misconduct Not Covered - Any privilege would be subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985) (applying exception to attorney-client privilege); Cox v. Administrator U.S. Steel & Carnie, 17 F.3d 1386, 1422
1 Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Austral
to class counsel during settlement negotiated waived work product when tape sought by government as part of criminal 3 EFTA00806655 case); In re Sealed Case, 676 F.2d 793, 824-25 (D.C. Cir. 1982) (production of documents during settlement discussions with the SEC waived work product protection as to gra
2265 File folder entitled "JEGE & Hyperion from Goldberger OLY-46 & OLY-47" containing documents received i
inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document
Entities connected to both Jack Goldberger and Sealed Case

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONLeon Black
PERSON
George W. Bush
PERSON
Alexander Acosta
PERSONSouthern District
LOCATIONRoy Black
PERSON
United States
LOCATIONMaria Farmer
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION