Epstein Secrets

820-8777 E-mail: [email protected] E-mail: [email protected] Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 37106421 (305) 358-2006 21 EFTA00614085

... [and] 4. The existence of unusual circumstances militating either for or against a determination that the application is timely. Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). All four of the factors suggest that the Court should deny Epstein's motion as untimely. I. The length of t

U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach FL 33401 Fax: E-mail: E-mail: Attorne Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 21 EFTA00614106

... [and] 4. The existence of unusual circumstances militating either for or against a determination that the application is timely. Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). All four of the factors suggest that the Court should deny Epstein's motion as untimely. I. The length of t

ane Doe #1 and Jane Doe #2 v. United States, Roy Black, et at, Intervenors, Eleventh Circuit No. 13-1292

. 879, 882 (11th Cir. 2006), and is "not limited to chronological considerations but is to be determined from all the circumstances." Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Among the circumstances which must be considered is "the purpose for which intervention is sought." National

14, 327 See, CL, Michael M. Mannix and David S. Black., Compliance Issues in M&A: Performing Diligence

ent to wrongfully influence the recipient. S.Rep. No. 95-114, at 10. % See 15 US.C. §§ 78dd-1(a), 78dd-2(a), 78dd-3(a). 7 See, C85 Complaint, SEC v. Monsanto Co., No. 05-cv-14 (D.D.C. Jan. 6, 2005) (among other things, the company paid a $50,000 bribe to influence an Indonesian official to repeal an unfavorabl

ane Doe #1 and Jane Doe #2 v. United States, Roy Black, et al., Intervenors, Eleventh Circuit No. 13-129

. 879, 882 (11th Cir. 2006), and is "not limited to chronological considerations but is to be determined from all the circumstances." Stal(worth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Among the circumstances which must be considered is "the purpose for which intervention is sought." National

their opposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is th

urable dimensions . . . [T]imeliness is not limited to chronological considerations but is to be determined from all the circumstances." Stallworth 'Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Those circumstances are considered in light of four factors: I. The length of time during which the would-be