Epstein Secrets

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

g the course of a mediation. Our decision whether to apply this mediation privilege .. . is governed by Federal Rule of Evidence 501 [and] Jaffee'. Redmond, 518 U.S. 1 (1996) . . . Recognizing that only those documents prepared for purposes of the confidential mediation are protected by the mediation pr

te the correspondence [DE 51]; the government's response to the motion [DE 60]; petitioners' reply to the government's response [DE 74]; intervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's o

Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 8 of 11 interests to outweigh the need for probative evidence."Jaffee v. Redmond, 518 U.S. 1, 9-19,116 S. Ct.1923, 135 L.Ed. 2d 337 (1996); Trammel v. United States, 445 U.S. 40, 47,100 S. Ct. 906, 63 L.Ed.2d 186 (1980). Recogn

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

ted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee' Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent disco

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

ted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee' Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent disco

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

d in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent disco

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

ed in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee'. Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent disco

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,

in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee v. Redmond, 518 U.S. 1, 10 (1996), and maintaining their confidentiality advances significant public and private interests. Numerous courts have recognized a

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

Docket 09/02/2011 Page 10 of 23 A. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffe4. Redmond, 518 U.S. 1 (1996), is perhaps the leading case addressing Rule 501 and the common-law principles underlying the recognition of testimonial privileg