Epstein Secrets

22011 Page 29 of 29 CERTIFICATE OF SERVICE The foregoing document was served on May 2, 2011, on the following using the Court's CM/ECF system: S Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. mom Martin G. Weinberg, P.C. Joseph L. Ackerman, Jr. Fowler White Burnett PA

that violation are embodied in an NPA. The mere fact that something is covered in an NPA does not block judicial review. See, e.g., United States' Castaneda, 162 F.3d 832, 834-35 (5th Cir. 1998) (reviewing issue of government's obligations under a NPA); United States' Hyles, 521 F.3d 946, 952 (8th Cir.

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

States, 445 U.S. 40 (1980) 29, 45 United States v. Al-Arian, 514 F.3d 1184 (11th Cir.), cert. denied, 555 U.S. 887(2008) 16 United States v. Castaneda, 162 F.3d 832 (5th Cir.1998) 16 vi EFTA00209665 Case: 13-12923 Date Filed: 08/05/2013 Page: 10 of 75 United States v. Cartwright, 413 F.3d

te in the settlement conference and should exercise that discretion. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. By: /s/ ROY BLACK, ESQ. Florida Bar No. 126088 [email protected] JACKIE PERCZEIC, ESQ. Florida Bar No. 042201 jperczek@ rovblack. corn On behalf of Jeffrey Eps

ct law. Under these principles, if a defendant lives up to his end of the bargain, the government is bound to perform its promises." United States Castaneda, 162 F.3d 832, 835-36 (5th Cir. 1998). Mr. Epstein has fully performed each and every one of his obligations under the nonprosecution agreement. To

remedy that would harm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et at, Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecution

t law. Under these principles, if a defendant lives up to his end of the bargain, the government is bound to perform its promises." United States v. Castaneda, 162 F.3d 832, 835-36 (5th Cir. 1998). The potential rescission remedy also has serious implications for Mr. Epstein's constitutional rights, as "[

/ECF system: Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 E-mail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 i i FL 33131 ia Martin G. Weinberg,

hat violation are embodied in an NPA. The mere fact that something is covered in an NPA does not block judicial review. See, e.g., United States v. Castaneda, 162 F.3d 832, 834-35 (5th Cir. 1998) (reviewing issue of government's obligations under a NPA); United States v. Myles, 521 F.3d 946, 952 (8th Cir

remedy that would harm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et al., Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecutio

t law. Under these principles, if a defendant lives up to his end of the bargain, the government is bound to perform its promises." United States v. Castaneda, 162 F.3d 832, 835-36 (5th Cir. 1998). The potential rescission remedy also has serious implications for Mr. Epstein's constitutional rights, as Id

INTRODUCTION Appellants Roy Black, Martin Weinberg, and Jeffrey Epstein hereby request that this Court stay the district court's order of June 18, 2013 (Doc. 188), Exhibit A hereto,

F.3d 1184, 1190 (11th Cir. 2008)("Due process requires the government to adhere to the promises it has made in a plea agreement"); United States v. Castaneda, 162 F.3d 832, 835-36 (5th Cir. 1998)("Nonprosecution agreements, like plea bargains, are contractual in nature, and are therefore interpreted in a