Epstein Secrets

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

s exist, counsel has a duty to initiate plea negotiations if he is to discharge his duty to faithfully represent the client's interests. Hawkman v. Parratt, 661 F.2d 1161, 1171 (8th Cir. 1981) (counsel's "failure to initiate plea negotiations concerning the duplicitous felony counts constituted ineffect

&Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 305-371-6421 Fax: 305-358-2006 Email: pleadinarqyblack com ATTORNEY TO BE NOTICED Jay P. Lefkowitz Kirkland &Ellis, LLP 601 Lexington Avenue New York, NY 10022 212-446-4970 Email: leflcowitztacirkland com PRO HAC VICE ATTORNEY TO BE NOTICED

2011. (ir) (Entered: 09/26/2011) 09/27/2011 jail RESPONSE/REPLY tom Supplement Briefing in Support of Motion to Intervene of Black, Weinberg, and Lelkowitz by United States of America. (Villafana, Ann Marie) (Entered: 09/27/2011) 09/28/2011 jaL MOTION for Extension of Time to File Response/Reply as to

s exist, counsel has a duly to initiate plea negotiations if he is to discharge his duty to faithfully represent the client's interests. Hawkman v. Parratt, 661 F.2d 1161, 1171 (8th Cir. 1981)(counsel's "failure to initiate plea negotiations concerning the duplicitous felony counts constituted ineffecti

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

s exist, counsel has a duty to initiate plea negotiations if he is to discharge his duty to faithfully represent the client's interests. Hawkman v. Parratt, 661 F.2d 1161, 1171 (8th Cir. 1981) (counsel's failure to initiate plea negotiations concerning the duplicitous felony counts constituted ineffecti

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

s exist, counsel has a duty to initiate plea negotiations if he is to discharge his duty to faithfully represent the client's interests. Hawkman v. Parratt, 661 F.2d 1161, 1171 (8th Cir. 1981) (counsel's failure to initiate plea negotiations concerning the duplicitous felony counts constituted ineffecti