Epstein Secrets

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

ere petitioners sought to vacate plea agreement which made no provision for restitution in deference to pending civil litigation); United States v. Aguirre-Gonzalez, 597 F.3d 46 (1st Cir. 2010) (relying on the "strong interest in the finality of criminal sentences" to reject mandamus under the Act where a defend

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

ere petitioners sought to vacate plea agreement which made no provision for restitution in deference to pending civil litigation); United States v. Aguirre-Gonzalez, 597 F.3d 46 (1st Cir. 2010) (relying on the "strong interest in the finality of criminal sentences" to reject mandamus under the Act where a defen

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

here petitioners sought to vacate plea agreement which made no provision for restitution in deference to pending civil litigation); United States'. Aguirre-Gonzalez, 597 F.3d 46 (1st Cir. 2010) (relying on the "strong interest in the finality of criminal sentences" to reject mandamus under the Act where a defend

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

been recognized as parties, and the Federal Rules of Criminal Procedure do not allow them to intervene as panics to a prosecution.); United States' Aguirre-Gonzalez, 597 F.3d 46, 53 (1st Cir. 2010) ("Notwithstanding the rights reflected in the restitution statutes, crime victims arc not panics to a criminal sen

1 1:09 PM To: . (USAFLS Cc: (USAFLS); (USAFLS) Subject: Article in today's Palm Beach Daily News (USAFLS); (USAFLS); (USAFLS) A response by Roy Black to Alex's letter. I note that this is an extrajudicial statement by Roy Black where he says, without any qualifying statement that it was their opin

18 USC 3771(f)(2)(D)) "Where a statute expressly provides a particular remedy or remedies, a court must be chary of reading others into it." U.S. v. Aguirre-Gonzalez, 597 F.3d 46, 54 (1st Cir. 2010) (quoting TAMA v. Lewis, 444 U.S. 11, 19 (1979)). Why don't we get together tomorrow face-to-face and talk it throu

AM To: . (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) Subject: Conversation with Roy Black - Redacted Materials Colleagues, I just spoke with Roy Black regarding the U.S. Attorney's Correspondence materials the victims seek to have unredacted. I told him we advised Cassell we had no independent obje

18 USC 3771(f)(2)(D)) "Where a statute expressly provides a particular remedy or remedies, a court must be chary of reading others into it." U.S. v. Aguirre-Gonzalez, 597 F.3d 46, 54 (1st Cir. 2010) (quoting TAMA v. Lewis, 444 U.S. 11, 19 (1979)). Why don't we get together tomorrow face-to-face and talk it throu

ng. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the terms of the Agreement. Again, no one r

en recognized as parties, and the Federal Rules of Criminal Procedure do not allow them to intervene as parties to a prosecution.); United States'. Aguirre-Gonzalez, 597 F.3d 46, 53 (1st Cir. 2010) ("Notwithstanding the rights reflected in the restitution statutes, crime victims are not parties to a criminal se