Epstein Secrets

DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL 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). 4 EFTA00205363 representing a client under federal investigation have an obligation to secure the best possible outcome

. 1992). Mr. Epstein has a Due Process right to the continued specific performance and enforcement of the non-prosecution agreement. United States I Haber, 299 < Fed. Aipx. 865, 867 (11th Cir. 2008). Rescission of the non-prosecution agreement at this juncture would, moreover, undermine Mr. Epstein's

DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL 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). 4 EFTA00205343 representing a client under federal investigation have an obligation to secure the best possible outcome

. 1992). Mr. Epstein has a Due Process right to the continued specific performance and enforcement of the non-prosecution agreement. United States I Haber, 299 < Fed. Aipx. 865, 867 (11th Cir. 2008). Rescission of the non-prosecution agreement at this juncture would, moreover, undermine Mr. Epstein's

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,

ns. Rather than invalidate the agreement, Mr. Epstein has a Due Process right to its continued specific performance and enforcement. United States. Haber, 299 Fed. Appx. 865, 867 (11th Cir. 2008). The remedy the plaintiffs seek cannot be obtained and their request for disclosure and use of the plea n

&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

1992). Mr. Epstein has a Due Process right to the continued specific performance and enforcement of the non-prosecution agreement. United States v. Haber, 299 Fed. Appx. 865, 867 (11th Cir. 2008). Rescission of the non-prosecution agreement at this juncture would, moreover, undermine Mr. Epstein's re

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

1992). Mr. Epstein has a Due Process right to the continued specific performance and enforcement of the non-prosecution agreement. United States v. Haber, 299 Fed. Appx. 865, 867 (I I th Cir. 2008). Rescission of the non-prosecution agreement at this juncture would, moreover, undermine Mr. Epstein's