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barred from delving further into the confidential plea negotiations. At the hearing on August 12, 2011, the Court heard oral argument from Attorney Black, who 'The United States uses the term "confidential" plea negotiations as a term of art. By definition, all plea negotiations are confidential and,
orney's Office during pre-indictment presentations and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit
barred from delving further into the confidential plea negotiations. At the hearing on August 12, 2011, the Court heard oral argument from Attorney Black, who 'The United States uses the term "confidential" plea negotiations as a term of art. By definition, all plea negotiations are confidential and,
orney's Office during pre-indictment presentations and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit
RIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK. MARTIN WEINBERG, AND JAY LEFKOWITZ COME NOW Ja
pre-indictment presentations and ongoing plea negotiations." Gov't Resp. at 8 (citing In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (1st Cir. 2003)). But the case the Government cites stands for no such broad proposition. Rather, that case involved a situati
NITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenors/Appellants ON APPEAL FROM A
34, 40 In re Sealed Case, 716 F.3d 603 (D.C.Cir. 2013) 54 In re Six Grand Jury Witnesses, 979 F.2d 939 (2d Cir. 1992), cert. denied sub nom. XYZ Corp. v. United States, 509 U.S. 905 (1993) 22 Jasper v. State, 871 So.2d 729 (Miss. 2004) 43 *Jaffee v. Redmond, 518 U.S. 1 (1996) passim Keen
team of attorneys began approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew o
purpose of securing legal advice or assistance. United States v. Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege protects only those communications that are confidential and are made for the pu
by extremely competent counsel. In addition to Mt Black and his partners, Epstein has retained at least
purpose of securing legal advice or assistance. United States I Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. I United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege protects only those communications that are confidential and are made for the pur
team of attorneys began approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew o
purpose of securing legal advice or assistance. United States I Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. I United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege protects only those communications that are confidential and are made for the pur
was excused from appearing before the grand jury and that Mr. Riley did not flout the subpoena by failing to appear. AUSA agreed with Attorney Mr. Black that Mr. Riley would not have to appear and produce the disputed items if a motion to quash all aspects of the subpoenas was filed. Neither party's
purpose of securing legal advice or assistance. United States v. Sehaltenbrand, 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States, 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege protects only those communications that are confidential and are made for the purp
sing the CM/ECF system. Respectfully submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 South Bi
istrict court should consider it in the first instance. Reversed. C.A.1 (Mass.),2003. In re Keeper of Records (Grand Jury Sub- poena Addressed to XYZ Corp.) 348 F.3d 16, 62 Fed. R. Evid. Serv. 1032 END OF DOCUMENT O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. Page 17 https://web2.westlaw.
Entities connected to both Leon Black and XYZ Corp.

Jeffrey Epstein
PERSONRoy Black
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
George W. Bush
PERSON
Michael Cohen
PERSONJack Goldberger
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Alexander Acosta
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSON
Jay Lefkowitz
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Samantha Power
PERSON
Scarlett Johansson
PERSON
Virginia Giuffre
PERSON
A. Marie Villafana
PERSONSouthern District
LOCATION