Epstein Secrets

, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: [email protected] E-mail: ann.marie.c.villafanaeusdoj.gov Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 37106421 (30

egally.' When other plea arrangements have been negotiated in violation of law, they have been stricken by the courts. For example, United States v. Walker, 98 F.3d 944 (7th Cir. 1996), held that where a sentence on a new crime could not run concurrently with a probation revocation the defendant was th

011 Page 25 of 25 CERTIFICATE OF SERVICE The foregoing document was served on December 5, 2011, on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Martin G. Weinberg, P.C. 25 EFTA00204916

llegally.' When other plea arrangements have been negotiated in violation of law, they have been stricken by the courts. For example, United States. Walker, 98 F.3d 944 (7th Cir. 1996), held that where a sentence on a new crime could not run concurrently with a probation revocation the defendant was th

22011 Page 29 of 29 CERTIFICATE OF SERVICE The foregoing document was served on May 2, 2011, on the following using the Court's CM/ECF system: S Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. mom Martin G. Weinberg, P.C. Joseph L. Ackerman, Jr. Fowler White Burnett PA

en in situations where defendants may have relied on those arrangements. See Victims' Summary Judgment Mot. at 37-39 (citing, e.g., United States'. Walker, 98 F.3d 944 (7th Cir. 1996); United States. 25 EFTA00208008 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 26 of 29

CE I HEREBY CERTIFY that on July , 2007, the foregoing document and the Declaration of Joseph Recarey will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express.

this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United States v. Walker , 2007 WL 1743273 (2d Cir. Jun. 18, 2007). The court wrote: Even assuming the documents (or the handful of corrections and clarifications handwritt

CE I HEREBY CERTIFY that on July , 2007, the foregoing document and the Declaration of Joseph Recarey will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express.

d this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United States I Walker , 2007 WL 1743273 (2d Cir. Jun. 18, 2007). The court wrote: Even assuming the documents (or the handful of corrections and clarifications handwritt

/ECF system: Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 E-mail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 i i FL 33131 ia Martin G. Weinberg,

n in situations where defendants may have relied on those arrangements. See Victims' Summary Judgment Mot. at 37-39 (citing, e.g., United States v. Walker, 98 F.3d 944 (7th Cir. 1996); United States v. 25 EFTA00178081 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 26 of 2

udge Marra also had scheduled a hearing on Epstein's motion to quash grand jury subpoenas for the computer equipment removed from Epstein's home by Roy Black's investigator when they learned of the stale investigation. This was postponed to allow plea negotiations and eventually was withdrawn pursuant to th

elsewhere did expressly. In these circumstances, the traditional Ma against surplusage and redundancy apply with double force. See, e.g., Duncan'. Walker 533 U.S. 167, 174 (2001). The "legal disability" language in § 2255(b) should be interpreted to reference classic legal disabilities like insanity,

nity provisions" of the NPA and an endorsement by the Court that the USAO-SDFL is authorized to prosecute Mr. Epstein. Respectfully submitted, /s/Roy Black Roy Black, Esq. (FL Bar No. 126088) Jackie Perczek, Esq. (FL Bar No. 42201) BLACK SREBNICK & KORNSPAN P.A. 201 S. Biscayne Boulevard, Suite 13

ing in United States v. Walker, 98 F.3d 944 (761 Cir. 1996) — the case on which Petitioners primarily rely -- is entirely confused and off-base. In Walker, the issue was whether defendant, who was serving a sentence for a federal parole violation when he was indicted on a new federal charge, was entit

TE 1300. MIAMI. FL 33131 Telephone: SIM On behalf of (select one): 7eCCrey erste ;71 K Plaintiff K Defendant SEALED DOCUMENT TRACKING FORM Name: ROY BLACK, ESQ. Date sealed document filed: 8/7/2007 If sealed pursuant to statute, cite statute: GRAND JURY PROCEEDING If sealed pursuant to previously en

efendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EFTA00179118 United States v. Walker, 2007 WL 1743273 (2d Cir. Jun. 18, 2007). The court wrote: Even assuming the documents (or the handful of corrections and clarifications handwritte

to respond; g) mischaracterize Mr. Epstein's discussion of the Walke• case (DE 464:55-56), inasmuch as it was not the Seventh Circuit's ruling in Walker that Mr. Epstein claimed was "entirely confused," but rather the Petitioners' discussion of it in their initial submission. (DE 463:25); and h) a

will likely object. Respectfully submitted, /s/Roy Black Roy Black, Esq. (FL Bar No. 126088) Jackie Per