Epstein Secrets

THERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, v. 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, Martin

CLUSION For all of the foregoing reasons, the Court should GRANT this motion and enter the requested Protective Order. Respectfully submitted, /s/Rov Black Roy Black Jackie Perczek BLACK, SREBNICK, KORNSPAN & STUMPF P A. -12- EFTA00605762 Attorneys for Intervenors Is/Martin G. Weinberg Martin G.

ervenors need not even demonstrate "good cause" in order to obtain relief. As the Hon. Karon Owen Bowdre, Chief Judge of the U.S. District Court for the Northern District of Alabama recently held: '(...continued) LEXIS 66742, at **9-11 (finding settlement communications non-discoverable as "not .. Likely to lead to

500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 February 11, 2010 DELIVERY BY ELECTRONIC MAIL Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for

basis for a prompt resolution of any issue not resolved by the parties through further discussions. Respectfully submitted, MARTIN WEINBERG, ESQ. ROY SLACK, ESQ. /wg cc: Jeffrey Sloman, Esq. Robert Senior, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. EFTA00194765 ROY BLACK HOWARD M. SREBNICK S

Individual Known to Defendant As 08MIST096.JPG and 08mist067.ipg Falso, 2009 WL 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York s Plaintiff has attempted to allege 6 counts pursuant to 18 U.S.C. §2255. If it is Plaintiff's position that she is entitled to the min

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

ve been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reiclzhold Chemicals, Inc. v. Textron, Inc., 157 F.R.D. 522 (N.D. Fla. 1994); and by a number of district courts recognizing a mediati

ROY BIACK HOWARD M. SREBNICK SCOTT A. KORNSPAN LARRY A. srumpt. MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ Jeff Sloman, Esq. United Stat

dividual Known to Defendant As 08MIST096.JPG and 08mist067.ive v. Falso, 2009 WL 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York 8 Plaintiff has attempted to allege 6 counts pursuant to 18 U.S.C. §2255. If it is Plaintiff's position that she is entitled to the min

ROY BIACK HOWARD M. SREBNICK Scott A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ Jeff Sloman, Esq. United State

dividual Known to Defendant As 08MIST096.JPG and 08mist067.ive v. Falso, 2009 WL 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York 8 Plaintiff has attempted to allege 6 counts pursuant to 18 U.S.C. §2255. If it is Plaintiff's position that she is entitled to the min

500 S. Australian Ave, Ste 400 West Palm Beach, FL 3340! (561)820-8711 Facsimile: (561) 820-8777 February 11, 2010 DELIVERY BY ELECTRONIC MAIL Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for

Individual Known to Defendant As 08M1ST096.JPG and 08mist067.jpg Falso, 2009 WL 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York Plaintiff has attempted to allege 6 counts pursuant to 18 §2255. If it is Plaintiff's position that she is entitled to the minimum dam

"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

com- puter system sold to corporation. After removal from state court to federal court in Minnesota on basis of diversity, followed by transfer to the Northern District of California, seller moved to dismiss claims as time barred. Following denial of ma tion, counsel for defendant was directed to submit memorandu

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

ents and violations, In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); the decision of Judge Vinson, now the Chief Judge in the Northern District of Florida, denying discovery and recognizing a privilege for a corporation that reports contamination and other environmental hazards and violatio