Epstein Secrets

Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz [DE 78] at 6. Second, also in opposing the intervention of attorneys Black, Weinberg, and Lefkowtiz, the plaintiffs argued that "[o]nly Epstein has an interest in the validity of the non-prosecution agreement . . . ." Jane Doe I and Jane Doe 2's R

ment of inconvenience does not go far because many of the issues raised by Mr. Epstein parallel the issues raised by attorneys Black, Weinberg, and Letkowitz as well as those raised during the August 12, 2011 hearing, and Jane Doe 1 and Jane Doe 2 do not have to file their responsive pleadings addressing

ment 93 Entered on FLSD Docket 09/02/2011 Page 3 of 9 First, they argued in their opposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is the real party in interest" and that "harm from the release of the materials (if any) could be only to Jeffrey Epstein." Jane D

materials (if any) could be only to Jeffrey Epstein." Jane Doe 1 and Jane Doe 2's Response To Motion To Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz [DE 78] at 6. Second, also in opposing the intervention of attorneys Black, Weinberg, and Lefkowtiz, the plaintiffs argued that "[o]nly Epstein has

rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), the district court denied reliefunder the Crime Victims' Rights Act before any charges

/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERC, AND JAY LEFKOWITZ This is a motion pursuant to Federal Rule of Civil Procedure 24(a) by attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz, to intervene for the

INTERVENE OF ROY BLACK, MARTIN WEINBERC, AND JAY LEFKOWITZ This is a motion pursuant to Federal Rule of Civ

omcyJ ay Lefkowitz within the next few days, as soon as a certificate of good standing from the New York Bar arrives. Attorneys Black, Weinberg and Lcfkowitz do not seek intervention to litigate whether the Crime Victims' Rights Act was violated and if so, against whom a remedy is appropriate. Instead, t

trict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case °fin re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), the district court denied relief under the Crime Victims' Restitution Act before any ch

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 NEGOTIATIONS During the hearing on August 12,

INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDE

rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. hid. Dec. 8,2010), the district court denied relief under the Crime Victims' Rights Act before any charges

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 Park Plaza Suite 1000 Boston, MA 02116 By /S/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 On Behalf of

No. On Behalf of Intervenors Roy Black and Jay Lefkowitz MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1

trict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case ofln re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (RD. Ind. Dec. 8, 2010), the district court denied relief under the Crime Victims' Restitution Act before any cha

rs" within the meaning of Rule 6(e), then it likewise violated grand jury secrecy for government attorneys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters can only be made upon court order. See Fed. R. Crim. P. 6(c)(3)(E). Everything the victims are disc

eys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters

ges. It was at that point (at a minimum) that the Government should have extended to the victims their right to confer. To the same effect is In re Peterson, 2010 WL 5108692 (N.D. Ind. 2010), a case that the Government cites as supporting its position. Gov't Resp. at 21-22. But Peterson squarely rejects

atts-that4ane-Dee-1-ancl4ane-Dee-2-alrea ma . confidemiel,Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56], as well as during the August 12, 2011 hearing. EFTA00301857

rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (M. Ind. Dec. 8, 2010), the district court denied relief under the CVRA before any charges were filed. The court

e Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56), as well as during the August 12, 2011 hearing. In further sup

rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), the district court denied relief under the CVRA before any charges were filed. The cour

e Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56], as well as during the August 12, 2011 hearing. EFTA00301881

rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (M. Ind. Dec. 8, 2010), the district court denied relief under the CVRA before any charges were filed. The court