Epstein Secrets

rey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 6(e) Box #3 P-012056 Thru P-012088 Affidavit of Roy Black, F-sq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United State

ith handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Ro Black to and m Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upo

gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio

ng as precedent in the Eleventh Circuit. $.0 Bonner v. City of Prichard, Ala , 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 19439748.2 EFTA00180297 Rov BLACK HOWARD M. SREBNICK Scorer A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ BLACK SREBNICK KORNSPAN STU

rs to deal with than a transfer of a state community control matter. RB/wg Very Roy Black Black, Srebnick, Komspan & Stumpf, P.A. EFTA00180299 ROY BLACK HOWARD M. SREBNICK Scan A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ BLACK SREBNICK KORNSPAN STUMP

laim against Robson must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. Cf. Churr

a, LEAD ATTORNEY, United States Attorney's Office, West Palm Beach. FL; Dexter Lee, LEAD ATTORNEY, United States Attorney's Office, Miami, FL. For Roy Black, Intervenor: Jacqueline Perczek, Roy Eric Black, Black Srebnick Kornspan & Stumpf, Miami, FL; Jay P. Lefkowitz, PRO HAC VICE, Kirkland & Ellis, LLP,

gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio

(USAFLS) From: Roy Black < Sent: Wednesda , Februa 11, 2015 8:50 AM To: (USAFLS) Subject: RE: Your phone call Great. Speak to you then. Original Message From: (U

pursuing a damages action against the government for violation of the [CVRA], and there is no implied private right of action under the [CVRA]." 3B Wright & , Fed. Prac. & Proc. Crim. § 932 (4th ed. 2014); see 18 U.S.C. § 3771(d)(6) ("Nothing in this chapter shall be construed to authorize a cause of

ts that private eyes were posing as police officers. When they told Epstein's local attorney, Guy Frons tin, he said he investigators worked for Roy Black, the high-powered Miami lawyer who has defended the likes of Rush limbaugh and William Kennedy Smith. While the private eyes were conducting a p

onflict. lb accept the bait. as the Israelis did in assaulting Leb- anon and as America did in Iraq. is to risk stepping into a trap. As Law- rence Wright says in his new book, The Zooming Tower, the master of this approach is Osama bin Laden: "His strategy was to continually at- tack until the U.S.

"harm from the release of the materials (if any) could be only to Jeffrey Epstein." Jane Doe 1 and Jane Doe 2's Response To Motion To Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz [DE 78] at 6. Second, also in opposing the intervention of attorneys Black, Weinberg, and Lefkowtiz, the plaint

D.Me.2001) federal courts apply federal law when ad ressing the work product doctrine, even in di- versity cases lacking any federal ques- tion); 8 Wright, Miller & Marcus, Feder- al Practice and Procedure: Civil 2d. § 2023 (2d ed. 1994) ("At least since the adoption of Rule 26(13)(3) in 1970, it has

NICK, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Office: (305) 371-6421 Fax: (305) 358-2006 By /S/ ROY BLACK, ESQ. Florida Bar No. 126088 JACKIE PERCZEK, ESQ. Florida Bar No. 0042201 23 EFTA00177962 Page I of 55 Westlaw Page I 531 F.3d 197 (Cite a

ted a `very lim- ited and seemingly judicious restriction,' 501 F.2d, at 151, nevertheless considered it versible *230 error. Citing United States Wright, 160 U.S.App.D.C. 57, 68, 489 .2d 1181, 1192 (1973), the court found that the Fifth Amendment prohibited the disclosure condition imposed in this

d. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy Black is among his clientele. air eves and ad telephone contact with either just after I attempted to interview them, or just prior. A background was

racy claim against must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).10 10 This case is governed by the general rule. Cf. Churr

laints that private, eyes were posing as police officers. When they told Epstein’s local attorney, Guy Eronstin, he said the investigators worked for Roy Black, the high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William Kennedy Smith. While the private eyes were conducting a parall

ral courts, but more recently, it has faced some appropriate criticism. The rule of abatement is best explained in the Second Circuit case of U.S, v. Wright. In that Wright case, two defendants had pled guilty to embezzlement and tax evasion. Both defendants appealed, but one of the defendants died while

L TO A FRIEND DIGG IT RE0011 4)PERMALMK Sources tell Page Six that Epstein's high- POwered lawyers - including Alan Dershowitz. Gerald Lefcourt. Roy Black and Kenneth Starr - have been negotiating a deal with federal prosecutors who are probing. among other things. whether the gray-haired money manag

ig (COMBAT) Williams, Karl (Belle Glade) Williams, Sherry (DOVE) Wilson-Lindsay, K (ATTF/Fel W) Withrow, Noreen (Fell) Woods, Anita (INTAKE) Wright, Nakia (COMBAT) Wyatt, Teresa (DOVE) Vance, Sherry (Juv M) Yeaw, Steven (HOM) Yodbut, Anton (COMBAT) Zacks, Paul (Felony) Zieba, Michelle