Epstein Secrets

endant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT O

n information that the state has and will use against the defendant is not simply a matter of common sense, . . . it is the duty of the lawyer ...." Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp).2 The constitution also requires that crimi

ll the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to inte

the state has and will use against the defendant is not simply a matter of common sense, . . . it is the duty of the lawyer .. . ." EFTA00301867 Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp).' The constitution also requires that crim

l the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to inte

formation that the state has and will use against the defendant is not simply a matter of common sense, . . . it is the duty of the lawyer . . . . Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4 4.1 (2d ed. 1982 Supp).O The constitution also requires that crim

l the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to inter

the state has and will use against the defendant is not simply a matter of common sense, . . . it is the duty of the lawyer .. . ." EFTA00301890 Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp).' The constitution also requires that crim

' MOTION FOR STAY PENDING APPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epst

nment, especially information that the government intends to use against the client. Failure to do so constitutes ineffective assistance of counsel. Rompilla v. Beard, 545 U.S. 374 (2005). "The notion that defense counsel must obtain information that the state has and will use against the defendant is no