Epstein Secrets

ification letter, and draft correspondence to Jay Lefkowitz." Here again, the materials at issue go to the h

. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard, Suite 1300 Miami, FL 33131 Email: [email protected] (305) 37106421 Jay P. Lefkowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Pl

entry reads: "File folder entitled '12/05/07 Stan• to Acosta' containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafla." Again, these materials are central to the dispute i

). Communications Facilitating Crime-Fraud-Misconduct Not Covered - Any privilege would be subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985) (applying exception to attorney-client privilege); Cox v. Administrator U.S. Steel & Carnie, 17 F.3d 1386, 1422

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

inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document

resolve the ongoing criminal investigation of him. Both Mr. Epstein and his criminal defense attorneys — appellants Roy Black, Martin Weinberg, and Jay Lefkowitz — filed motions to intervene for the limited purpose of challenging the use and disclosure of the settlement/plea negotiation correspondence (Doc.

— appellants Roy Black, Martin Weinberg, and Jay Lefkowitz — filed motions to intervene for the limited pur

ognized under Rule 501 is not a bar to Perlman jurisdiction. The controlling factor is whether the appellants assert a right or privilege, see In re Sealed Case, F.3d , 2013 WL 2120157 at *4 (D.C.Cir. March 5, 2013)("The Perlman doctrine permits appeals from some decisions that are not final but allow the