Epstein Secrets

us B. Lau, White & Case LLP, Washington, D.C., for Appellee Stolt—Nielsen S.A. and Stott- Nielsen Transportation Group Ltd. Roberta D. Liebenberg, Allen D. Black, (Argued), Gerard A. Dever, Fine, Kaplan & Black, Philadelphia, PA, James A. Back- strom, Jr., Philadelphia, PA, for Appellee Richard B. Wingfield

ation Group Ltd. Roberta D. Liebenberg, Allen D. Black, (Argued), Gerard A. Dever, Fine, Kaplan & Blac

ed States a Oregon, 718 F2d 299, 908 & n. 5 (9th Cir.1983). The district court erred in its ruling that it lacked juris- diction. See, e.g., Jett a Castaneda, 578 F.2d 842, 845 (9th Cir.1978) (felt). 1101 We have recognized, however, that as a general proposition, a district court has no "power to moni

VICE The foregoing document was served on May 2, 2011, on the following using the Court's CM/ECF system: S Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. mom Martin G. Weinberg, P.C. Joseph L. Ackerman, Jr. Fowler White Burnett PA _Pi • 29 EFTA00208012

that violation are embodied in an NPA. The mere fact that something is covered in an NPA does not block judicial review. See, e.g., United States' Castaneda, 162 F.3d 832, 834-35 (5th Cir. 1998) (reviewing issue of government's obligations under a NPA); United States' Hyles, 521 F.3d 946, 952 (8th Cir.

NITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenors/Appellants ON APPEAL FROM A

States, 445 U.S. 40 (1980) 29, 45 United States v. Al-Arian, 514 F.3d 1184 (11th Cir.), cert. denied, 555 U.S. 887(2008) 16 United States v. Castaneda, 162 F.3d 832 (5th Cir.1998) 16 vi EFTA00209665 Case: 13-12923 Date Filed: 08/05/2013 Page: 10 of 75 United States v. Cartwright, 413 F.3d

ercise that discretion. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. By: /s/ R

ct law. Under these principles, if a defendant lives up to his end of the bargain, the government is bound to perform its promises." United States Castaneda, 162 F.3d 832, 835-36 (5th Cir. 1998). Mr. Epstein has fully performed each and every one of his obligations under the nonprosecution agreement. To

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

t law. Under these principles, if a defendant lives up to his end of the bargain, the government is bound to perform its promises." United States v. Castaneda, 162 F.3d 832, 835-36 (5th Cir. 1998). The potential rescission remedy also has serious implications for Mr. Epstein's constitutional rights, as "[

500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 E-mail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 i i FL 33131 ia Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 B°

hat violation are embodied in an NPA. The mere fact that something is covered in an NPA does not block judicial review. See, e.g., United States v. Castaneda, 162 F.3d 832, 834-35 (5th Cir. 1998) (reviewing issue of government's obligations under a NPA); United States v. Myles, 521 F.3d 946, 952 (8th Cir

le, is also America's second-wealthiest majority- Black county —just recently surpassed by neighboring Ch

ty." California Woman Sentenced to Nine Years in Prison for Fraudulent Scheme to Steal California Unemployment Insurance Benefits CBS News (09/18, Castaneda) reported that a judge sentenced a Northern California woman to nine years in prison on Tuesday for fraudulently obtaining more than $1 million in u

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

t law. Under these principles, if a defendant lives up to his end of the bargain, the government is bound to perform its promises." United States v. Castaneda, 162 F.3d 832, 835-36 (5th Cir. 1998). The potential rescission remedy also has serious implications for Mr. Epstein's constitutional rights, as Id

INTRODUCTION Appellants Roy Black, Martin Weinberg, and Jeffrey Epstein hereby requ

F.3d 1184, 1190 (11th Cir. 2008)("Due process requires the government to adhere to the promises it has made in a plea agreement"); United States v. Castaneda, 162 F.3d 832, 835-36 (5th Cir. 1998)("Nonprosecution agreements, like plea bargains, are contractual in nature, and are therefore interpreted in a