Epstein Secrets

e government's response to the motion [DE 60]; petitioners' reply to the government's response [DE 74]; intervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the motion, including moti

intervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for

ings, 616 F.3d 1172 (10° Cir. 2010). 2 "Grand jury secrecy is not unyielding" when there is no secrecy left to protect. In re Grand Jury Subpoena, Judith Miller, 438 F.3d 1138, 1140 (D.C. Cir. 2006). Rule 6(e)(6) requires that records, orders and subpoenas relating to grand jury proceedings remain sealed onl

ed similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lefkowitz at 2, 3; see gim your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'indi

ve of the $526,466 already paid by Mr. Epstein - meet the criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA language, and Mr. Critton, each strongly believe that significant amounts of the fees and costs

were identified during Grand Jury proceedings are subject to the secrecy provisions of Fed. R. Crim. P. 6(e). Sys, e.z., In re Grand Jury Subpoena, Judith Miller 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent with these purposes, we have recognized that grand jury secrecy covers 'the identities of witness

Esq. Company: Fax it: Direct #: prated States Attorney, Southern bistrict of Florida Company: Fax #: Direct it: From: Sandra Musumeci for Jay P. Lefkowitz, P.C. Message: Date: July 29, 2011 Pages w/cover: 4 Fax #; Direct #: Please see the attached letter, in response to your letter to Martin Wei

ed similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lelkowitz at 2, 3; see gla your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'indi

r were identified during Grand Jury proceedings are subject to the secrecy provisions of Fed. R. Crim. P. 6(e). age, gg„ In re Grand Jury Subpoena, Judith Miller 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent with these purposes, we have recognized that grand jury secrecy covers 'the identities of witness

&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

ings, 616 F.3d 1172 (10° Cir. 2010). 2 "Grand jury secrecy is not unyielding" when there is no secrecy left to protect. In re Grand Jury Subpoena, Judith Miller, 438 F.3d 1138, 1140 (D.C. Cir. 2006). Rule 6(eX6) requires that records, orders and subpoenas relating to grand jury proceedings remain sealed only

, Esq. Company; Pax #: Direct #: United States Attorney, Southern District of Florida Company: Fax #: Direct it From: Sandra Musumeci for Jay P. Lefkowitz, P.C. Message: Date: July 29, 2011 Pages w/cover: 4 Fax #: Direct #: Please see the attached letter, in response to your letter to Martin Wei

ed similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lefkowitz at 2, 3; see also your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'ind

were identified dining Grand Jury proceedings are subject to the secrecy provisions of Fed. R. Crim. P. 6(e). S,g, e.g., In re Grand Jury Subpoena, Judith Miller, 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent with these purposes, we have recognized that grand jury secrecy covers 'the identities of witnes