Epstein Secrets

2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of America, by and through the undersigned Assistant United States Attorney, hereby fi

n attorney's work is for his client's advantage, opposing counsel or adverse parties should not gain the use of that work through discovery." In re John Doe, 662 F.2d 1073, 1081 (4i° Cir. 1981). As is required by the Sixth Amendment, a criminal defense attorney must exert his best efforts to convince the

2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of America, by and through the undersigned Assistant United States Attorney, hereby fi

n attorney's work is for his client's advantage, opposing counsel or adverse parties should not gain the use of that work through discovery." In re John Doe, 662 F.2d 1073, 1081 (4i° Cir. 1981). As is required by the Sixth Amendment, a criminal defense attorney must exert his best efforts to convince the

Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 E-mail: [email protected] Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 Email: pleading@royb

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Motor Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E. Rule 6(e) —

e charge of felony solicitation of prostitution,E1-9-fd to which Epstein pleaded not guilty in August 2006.11°7i Epstein's defense lawyers included Roy Black, Gerald Lefcourt, Harvard Law School professor Alan Dershowitz, and former U.S. Solicitor General Ken Starr l(io8l Linguist Steven Pinker also assi

were released. Two sets of additional sealed documents will be analyzed by a federal judge to determine whether they should also be made public. A "John Doe" asked the judge on September 3 to permanently keep the documents secret, claiming "unproven allegations of impropriety" could damage his reputatio

gle charge of felony solicitation of prostitution, 9-0 to which Epstein pleaded not guilty in August 2oo6.(1137) Epstein's defense lawyers included Roy Black, Gerald Lefcourt, Harvard Law School professor Alan Dershowitz, and former U.S. Solicitor General Ken Starr.ril°1 Linguist Steven Pinker also Epste

were released. Two sets of additional sealed documents will be analyzed by a federal judge to determine whether they should also be made public. A "John Doe" asked the judge on September 3 to permanently keep the documents secret, claiming "unproven allegations of impropriety" could damage his reputatio

le charge of felony solicitation of prostitution,[we'l to which Epstein pleaded not guilty in August 20o6..[J-cd Epstein's defense lawyers included Roy Black, GeraldLefcourt, Harvard Law School professor Alan Dershowitz, and former U.S. Solicitor General Ken Starr. 42 Steven Pinker also _ _ assisted.

were released. Two sets of additional sealed documents will be analyzed by a federal judge to determine whether they should also be made public. A "John Doe" asked the judge on September 3 to permanently keep the documents secret, claiming "unproven allegations of impro riety" could damage his reputatio

"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

(4th Cir.1992) (opinion work product "absolutely immune" from discovery); In re Martin Marietta Corp., 856 F.2d 619, 625 (4th Cir.1988); In re John Doe, 662 F. 2d 1073, 1080 ( 4th Cir. 1981), cert. denied 455 U.S. 1000, 102 *463 S.Ct. 1632, 71 L.Ed.2d 867 (1982) (opinion O 2011 Thomson Reuters. N

riding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P413860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon lifting of stay) N/A Suppl. Box 3 P-013861 Thru

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Moto• Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E Rule 6(c) —