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

orney's Office during pre-indictment presentations and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit

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

orney's Office during pre-indictment presentations and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit

JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK. MARTIN WEINBERG, AND JAY LEFKOWITZ COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel,

pre-indictment presentations and ongoing plea negotiations." Gov't Resp. at 8 (citing In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (1st Cir. 2003)). But the case the Government cites stands for no such broad proposition. Rather, that case involved a situati

venors/Appellants ON APPEAL FROM AN ORDER OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA BRIEF OF INTERVENORS/APPELLANTS ROY BLACK, MARTIN G. WEINBERG, AND JEFFREY EPSTEIN Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf 201 South Biscayne Boulevard Suite 1300

34, 40 In re Sealed Case, 716 F.3d 603 (D.C.Cir. 2013) 54 In re Six Grand Jury Witnesses, 979 F.2d 939 (2d Cir. 1992), cert. denied sub nom. XYZ Corp. v. United States, 509 U.S. 905 (1993) 22 Jasper v. State, 871 So.2d 729 (Miss. 2004) 43 *Jaffee v. Redmond, 518 U.S. 1 (1996) passim Keen

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.

purpose of securing legal advice or assistance. United States v. Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege protects only those communications that are confidential and are made for the pu

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.

purpose of securing legal advice or assistance. United States I Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. I United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege protects only those communications that are confidential and are made for the pur

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

purpose of securing legal advice or assistance. United States v. Sehaltenbrand, 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States, 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege protects only those communications that are confidential and are made for the purp

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

istrict court should consider it in the first instance. Reversed. C.A.1 (Mass.),2003. In re Keeper of Records (Grand Jury Sub- poena Addressed to XYZ Corp.) 348 F.3d 16, 62 Fed. R. Evid. Serv. 1032 END OF DOCUMENT O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. Page 17 https://web2.westlaw.