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

D.Me.2001) federal courts apply federal law when ad ressing the work product doctrine, even in di- versity cases lacking any federal ques- tion); 8 Wright, Miller & Marcus, Feder- al Practice and Procedure: Civil 2d. § 2023 (2d ed. 1994) ("At least since the adoption of Rule 26(13)(3) in 1970, it has

KIRKLAND & ELLIS LLP MEMORANDUM Attorney Work Product Privileged and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric F. Leon David S. Flugman DATE: August 7, 2009 RE: Potential Claims against D.B. Zwim, Glenn Dubin, and/or Highbridge Capital You ha

E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric F. Leon David S. Flugman DATE: Aug

o impart correct information to another. The special relationship requires a closer degree of trust than that in an ordinary business relationship." Wright v. Selle, 27 A.D. 3d 1065, 1066-67 (4th Dep't 2006). Thus, Jeepers would need to establish that Dubin had a special relationship of trust that crea

ed States Attorney's Office, Miami, FL. For Roy Black, Intervenor: Jacqueline Perczek, Roy Eric Black, Black Srebnick Kornspan & Stumpf, Miami, FL; Jay P. Lefkowitz, PRO HAC VICE, Kirkland & Ellis, LLP, New York, NY; Martin G. Weinberg, PRO HAC VICE, Martin G. Weinberg, P.C., Boston, MA. For Martin G. Weinberg,

ck Srebnick Kornspan & Stumpf, Miami, FL; Jay P. Lefkowitz, PRO HAC VICE, Kirkland & Ellis, LLP, New York,

gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio

led "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28 2007 letter from Kenneth Starr to , and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010

Thru P-009125 12/6/2007 Letter from to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursua

gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio

, Esq. Company; Pax #: Direct #: United States Attorney, Southern District of Florida Company: Fax #: Direct it From: Sandra Musumeci for Jay P. Lefkowitz, P.C. Message: Date: July 29, 2011 Pages w/cover: 4 Fax #: Direct #: Please see the attached letter, in response to your letter to Martin Wei

ed similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lefkowitz at 2, 3; see also your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'ind

laim against Robson must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. Cf. Churr

ing to intervene on Epstein’s behalf. The U.S. Attorney’s Office said it wouldn’t comment on Marra's ruling. Neither Black nor New York City attorney Jay Lefkowitz, who led efforts to bury the federal indictment, responded to emails or phone calls for comment. West Palm Beach attorneyJack Goldberger, who represe

led to the impeachment of President Clinton. Marra describes an October .2007 breakfast, meeting between Acosta, who is now U.S. labor secretary, and Lefkowitz shortly after the non-prosecution agreement was. inked, After the meeting, Lefkowitz sent Acosta a note thanking him for "the commitment you made to

ral courts, but more recently, it has faced some appropriate criticism. The rule of abatement is best explained in the Second Circuit case of U.S, v. Wright. In that Wright case, two defendants had pled guilty to embezzlement and tax evasion. Both defendants appealed, but one of the defendants died while

R BEYER,LAWRENCE COHLAN,JOHN LEFKOWITZ,ELISE JAMES,JANET B HILL,MELANIE

KENT MD,SEBASTIAN PORRECA,VANESSA WRIGHT,SUZANNE FURLO,PAUL W TOWN OF PALM B

t of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 15

stitutionality or even impropriety. Incendy at 956 (citing United States' Kordel, 397 U.S. I, 11 (1970)). See also Securities and Exchange Comm'nl. Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o 'special circumstances' existed in this case warranting a stay, as there is no record evidence sug

her Florida state and federal courts. See, SCI Funeral Svs. of Fla., Inc. v. Henry, 839 So. 2d 702, n.4 (Fla. 3d DCA 2002) (“As the Levin court cited Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA, 1984), with approval, presumably the cause of action for malicious prosecution continues to exist and

pstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit “D’’) to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter r

es Attorney's Office prepared negotiated lea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit “H’), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JE