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

r, and subject to any other conditions that it directs — of a grand-jury matter: (i) preliminarily to or in connection with a judicial proceeding." Federal Rule of Criminal Procedure 6(e) provides that the traditional rule of grand jury secrecy may be placed aside under certain circumstances to allow for disclosure. S

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

he United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the cowl should find that the m

08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATI

of 23 of law. Part I shows that the Court should deny disclosure and use of the plea negotiations by simple reference to Rule of Evidence 410 and Federal Rule of Criminal Procedure 11(0, without having to reach the other issues raised by the parties and the proposed intervenors. This is because during the hearing on

ystem. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami. Florida 33131 By /S/ ROY BLACK, ESQ. Florida Bar No. JACKIE PERCZEK, ESQ. Florida Bar No. On Behalf of Intervenors Roy Black and Jay Lefkowitz MARTIN G. WEINBERG, P.C. 20 Par

ernment and those prepared by the defense should remain confidential and subject to a protective order because they contain grand jury information. Federal Rule of Criminal Procedure 6(e)(2) prohibits disclosure of "a matter occurring before the grand jury." FED. R. CRIM. P. 6(e)(2). This prohibition has been read broad

igation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstein during the investigation, are filing this pleading to provide notice to t

ssemination of these letters because they contain information from the grand jury's investigation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstei

hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them. Dated: JEFFREY EPSTEIN Dated: ROY BLACK, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Page 4 of 4 EFTA00176678 — %/a-vedo — UNITED STATES DIST

nds that the amount of restitution owed to each victim will be determined at or before sentencing. 6. This Plea Agreement is governed, in pail, by Federal Rule of Criminal Procedure 11(c)(1)(C). The parties have agreed that the defendant's sentence imposed by the Court shall be two (2) yews' imprisonment to be followe

LEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFANA ASSISTANT UNITED STATES ATTORNEY By: JEFFREY EPSTEIN, DEFENDANT Date: By: ROY BLACK, ESQ. ATTORNEY FOR DEFENDANT Date: By: GERALD LEFCOURT, ESQ. COUNSEL TO DEFENDANT 7 EFTA00194618 UNITED STATES DISTRICT COURT SOUTHERN

nds that the amount of restitution owed to each victim will be determined at or before sentencing. 6. This Plea Agreement is governed, in part, by Federal Rule of Criminal Procedure 11(e)(1)(C). The parties have agreed that the defendant's sentence imposed by the Court shall be two (2) years' imprisonment to be follow

"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

n confidential. As such, they are protected by the constitutional right to effective assistance of counsel and the express language of Rule 410 and Federal Rule of Criminal Procedure 11(0. FED. R. EvID. 410 (discussions made during plea negotiations are "not, in any civil or criminal proceeding, admissible against the

igation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstein during the investigation, are filing this pleading to provide notice to t

ssemination of these letters because they contain information from the grand jury's investigation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstei