Epstein Secrets

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

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

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

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

S OF AMERICA, Respondent. UNITED STATES' RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ ]DE94] The United States of America, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplement

TERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ ]DE94] The United States of America, by and thr

and information should be privileged under a common law plea negotiations privilege. In addition, in its initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the P

al mseimien-ef-that-investigatienr Edwards-Deelaratien-at--11-147 33. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay Leflcowitz„ a copy of which is attached hereto as Exhibit _.Bpsteinls—eriminal—defense eeunselr explaining that the Justice Department's Child Exploitation Obsc

ter Relantionulso-is-felling-Chief Reiier-not4O-diselose the-eufeente-fe-anyene 4-2, On about September 25, 2007, AUSA Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit stating.-11And-ean-we-itaye-a-eenferenee-edi-te-disesss what-I-may-diselese-to,the-gek-regarding-th

ed on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E