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ce attorney. did you over 7 talk to hist 8 A. 9 0. Did you ever talk to Alan Dershovits about any 10 Of these hatters? Me, sir. 12 O. Or Roy Slack? 13 A. Me, sir. 14 0. Now. l'n lei* going back Over Dome different IS things that you sent lead. 16 You laid that there we a POIndex that y
1 Have you ever beard of • 12 KS. EtELI-1 Thank you. You're right. 1) ME WITNESS: I know that hid nand was Cony. 14 but 1 don't know if it was Santiago Of I 15 don't otmembet the last MM. I never *poke TO 16 hire. except ask his to Mee his CM Ond tine. 17 BY KR. COITTON: 14 And Old Mf. got
Ina Oa* 5l4W useerramennen 15611 $22-7506 1 2 3 4 6 7 S Pwes 99 BY Mt. COITION: Ass. [sell used -- she referred to • Tony -- KS. ELELL: Santiago. OWE WITNESS: Monaco. 10 BY It. COITION: 11 Have you ever beard of • 12 KS. EtELI-1 Thank you. You're right. 1) ME WITNESS: I know that hid
THERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant, ROY BLACK, et al., Intervenors. / INTERVENORS' MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER AND INCORPORATED MEMORANDUM OF LAW Intervenors Roy Black, Mar
orney for Intervenors CERTIFICATE OF SERVICE I HERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this 2ad day of May, 2014. /s/Rov Black Roy Black -13- EFTA00191302 Case 9:08,,80736-KAM Document 247-4 Entered on FLSD Docket 05/02/2014 Page 1 of 6 COMPOSITE EXHIBIT 4 EFTA00191303
ct the Intervenors from "annoyance, embarrassment, oppression, or undue burden or expense." See Looney, 2014 U.S. Dist. LENS 48349, at *5; Irizarry- Santiago'. Essilor Industries, 293 F.R.D. 100, 104 (D. P.R. 2013). The Intervenors include not only the third-party client whose non-prosecution agreement is
"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
ting Plaintiff's business -- were made available to and used by attorneys does not protect them from disclosure or turn them into work product. See Santiago i Miles, 121 F.R.D. 636, 642 (W.D.N.Y. 1988) (no work product protection where, although computer reports may have been prepared with pending litig
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
l, Susan (Fel 3) Rudman, Douglas (Juv M) Russ, Debbie (Gun Club) Russell, Paula (DOVE-GC) Sabel, Linda (Bello Glade)Sallsbury, Craig (COMBAT) Santiago, Cheryl (Eco Crime) Santamaria, Michelle (HOM) Satcher, Linda (Appeals) Satcher, Lisa (Fel U) Sauvola, Nicole (Belie Glade) Scharaga, Joan (
Entities connected to both Roy Black and Santiago
Leon Black
PERSON
Jeffrey Epstein
PERSONJack Goldberger
PERSON
Jay Lefkowitz
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
A. Marie Villafana
PERSONMartin Weinberg
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Jeffrey Sloman
PERSON
Ken Starr
PERSONGerald Lefcourt
PERSONthe Southern District
LOCATION
Prince Andrew
PERSONMaria Farmer
PERSON
George W. Bush
PERSON