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

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

es. Epstein's motion to quash was filed on July 17, 2007 before the close of business. See Gov't Resp. at 1. Riley was informed of these matters by Roy Black, Esquire. and did not appear in reliance on the Government's agreement with Roy Black. I Undersigned counsel has been out of the country and just

in its entirety. Respectfully submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, PA. 201 South Biscayne Boulevard, Suite 1300 Miam 1prida 33131 By ROY BLA K, Florida Bar No. Counsel for Jeffrey Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 17, 2007, a true and correct copy of the forgi

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modern work- product doctrine, holding that: [lin performing his various duties, how

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

litigation.' United States v. Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman v. Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawyer is bou

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

rials prepared by an attorney `acting for his client in anticipation of litigation,"' United States v. Nobles, 422 U.S. 225, 237-38 (1975), quoting Hickman v. Taylor, 329 U.S. 495, 508 (1947), which applies in both civil and criminal litigation: Although the work-product doctrine most frequently is asserted as a

cording to information obtained by the local police, one or more of the women so engaged was under the age of 18 at the relevant time. Affidavit of Roy Black, Esq., sworn to July 17, 2007, annexed ("Black Aft") ¶3. Following a 16 month investigation, on July 17, 2006, Mr. Epstein was charged under Florid

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor,. 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modem work- product doctrine, holding that: (flu performing his various duties, how

a, LEAD ATTORNEY, United States Attorney's Office, West Palm Beach. FL; Dexter Lee, LEAD ATTORNEY, United States Attorney's Office, Miami, FL. For Roy Black, Intervenor: Jacqueline Perczek, Roy Eric Black, Black Srebnick Kornspan & Stumpf, Miami, FL; Jay P. Lefkowitz, PRO HAC VICE, Kirkland & Ellis, LLP,

"it is essential that a lawyer work with a certain r 161 degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510, 67 S. Ct. 385, 91 L. Ed. 451 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a part

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

ain hidden in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor, 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re