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TES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of America, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplementa
INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of America, by and thro
gned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a company may maintain even its attorney-client privilege and work-product privilege in materials that it discloses to the U.S. Attor
TES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of America, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplementa
INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of America, by and thro
gned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a company may maintain even its attorney-client privilege and work-product privilege in materials that it discloses to the U.S. Attor
t of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 15
obtain the "extraordinary" remedy of a stay is inevitably much reduced. Sterling Nat'l Bank, 175 F. Supp. 2d at 577 (internal citations omitted). The First Circuit has noted that the decision whether to grant a stay "is highly nuanced ... [and] involves competing interests. Balancing these interests is a situat
Entities connected to both Jay Lefkowitz and The First Circuit

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONKirkland & Ellis LLP
ORGANIZATIONLeon Black
PERSONRoy Black
PERSON
A. Marie Villafana
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Ken Starr
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSON
George W. Bush
PERSONGerald Lefcourt
PERSON
Prince Andrew
PERSONSouthern District
LOCATION