Epstein Secrets

NE DOE 2, 1. Plaintiffs, UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previousl

REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed during the litigation on intervention. We only add that,

e elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality." DeBartolo Corp.. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988). One final matter must be addressed concerning Mr. Epstein's state court plea: During a hearing in this case, the Court a

&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

elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality." DeBartolo Corp. v. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988). B. Recognition of a Privilege Under Rule 501. The Court rejected intervenors' contention that the Court should recogniz

NE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENORS' MOTION FOR STAY PENDING APPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court stay its order of June 18, 2013 (Doc. 188), denying their Motion for a Protective Ord

ntal Authority of the United States Supreme Court (Doc. 163); and Reply in Support of Supplemental Briefing By Limited Intervenors Black, Weinberg, Lefkowitz, and Epstein (Doc. 169). 3 EFTA00583391 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must beg

elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality." DeBartolo Corp. v. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988). B. Recognition of a Privilege Under Rule 501. The Court rejected intervenors' contention that the Court should recogniz

NE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENORS' MOTION FOR STAY PENDING APPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court stay its order of June 18, 2013 (Doc. 188), denying their Motion for a Protective Ord

ntal Authority of the United States Supreme Court (Doc. 163); and Reply in Support of Supplemental Briefing By Limited Intervenors Black, Weinberg, Lefkowitz, and Epstein (Doc. 169). 2 EFTA00584592 Ninety-four percent of state convictions are the result of guilty pleas. The reality is that plea bargai

elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality." DeBartolo Corp. v. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988). B. Recognition of a Privilege Under Rule 501. The Court rejected intervenors' contention that the Court should recogniz