Epstein Secrets

OHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court stay its order of June 18, 2013 (Doc. 188), denying th

federal courts to `continue the evolutionary development of [evidentiary] privileges.' Adkins g Christie, 488 F.3d 1324, 1328 (11th 2007), quoting Trammel I United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 41001s that the accused is encouraged candidly to discuss his or her situat

OHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court stay its order of June 18, 2013 (Doc. 188), denying th

federal courts to `continue the evolutionary development of [evidentiary] privileges.' Adkins g Christie, 488 F.3d 1324, 1328 (11th 2007), quoting Trammel I United States, 445 U.S. 40, 47 (1980). The "central feature" of Rule 41001s that the accused is encouraged candidly to discuss his or her situat

REBNICK, KORNSPAN & STUMPF, P.A. n By /S/ 1 ROY BLACK, ESQ. Florida Bar No. 126088 JACKIE PERCZEK, ES

ivilege," and to provide the court "with the flexibility to develop rules of privilege on a case-by-case basis, and leave the door open to change." Trammel, 445 U.S. at 47. Whatever the circumstances may be in other cases in the future, the facts of this case, when "interpreted in the light of reason an

trict court to compel the United States to produce all requested discovery about the plea negotiations. Epstein and his criminal defense attorneys, Roy Black and Martin Weinberg, moved to intervene for the limited purpose of challenging the disclosure and use of the correspondence they wrote during plea

would achieve a `public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth.' Id. (quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912). The Supreme Court has identified several considerations relevant to whether a court should recognize an eviden

trict court to compel the United States to produce all requested discovery about the plea negotiations. Epstein and his criminal defense attorneys, Roy Black and Martin Weinberg, moved to intervene for the limited purpose of challenging the disclosure and use of the correspondence they wrote during plea

would achieve a `public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth.' Id. (quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912). The Supreme Court has identified several considerations relevant to whether a court should recognize an eviden

trict court to compel the United States to produce all requested discovery about the plea negotiations. Epstein and his criminal defense attorneys, Roy Black and Martin Weinberg, moved to intervene for the limited purpose of challenging the disclosure and use of the correspondence they wrote during plea

would achieve a `public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth." Id. (quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912). The Supreme Court has identified several considerations relevant to whether a court should recognize an eviden

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

r was to provide the courts with the flexibility to develop rules of privilege on a case-by-case basis . . . and to leave the door open to change." Trammel, 445 U.S. at 47 (internal quotation marks omitted). In Jaffee v. Redmond, 518 U.S. 1 (1996), the Supreme Court explored the considerations which g

trict court to compel the United States to produce all requested discovery about the plea negotiations. Epstein and his criminal defense attorneys, Roy Black and Martin Weinberg, moved to intervene for the limited purpose of challenging the disclosure and use of the correspondence they wrote during plea

would achieve a `public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth.' Id. (quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912). The Supreme Court has identified several considerations relevant to whether a court should recognize an eviden

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.

luding relevant evidence has a public good transcending the normally predominant principle of utilizing all rational means for ascertaining truth." Trammel v. United States , 445 U.S. 40, 50 (1980) (internal quotation omitted). See also In re Grand Jury Subpoena , 274 F.3d 563, 571 (1st Cir. 2001) ("Be