Epstein Secrets

te 400 West Palm Beach, FL 33401 (561) 820-8711 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 Email: [email protected] (305) 37106421 (305) 358

rative process is at issue) that have not been proven by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle v. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown v. City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert pri

CM/ECF system: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Jay P. Leflcowitz M

Government has not provided factual material identifying who is the attornex, who is the client, and how the communications were confidential. See Bogle I McClure, 332 F.3d 1347, 1358 (11th Cir. 2003) (noting privilege holders not As the Court is aware, the victims have alleged that U.S. Attorney's

NITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenors-Appellants MOTION TO DISMIS

create the necessary factual support from which this Court could find that he will be injured if the correspondence is provided to the victims. See Bogle v. McClure, 332 F.3d 1347, 1358 (1 1 th Cir. 2003) (noting privilege holder not "excused from meeting their burden of proving the communication con

was served on July 2, 2013, on the following using the Court's CMJECF system: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. /s/ Paul G. Cassell Paul G. Cassell 22 EFTA00209594

create the necessary factual support from which this Court could find that he will be injured if the correspondence is provided to the victims. See Bogle. McClure, 332 F.3d 1347, 1358 (1 1 th Cir. 2003) (noting privilege holder not "excused from meeting their burden of proving the communication confi

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

e Government has not provided factual material identifying who is the attorney, who is the client, and how the communications were confidential. See Bogle v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003). 13. Deliberative Process Privilege Privilege Not Properly Invoked - Any deliberative process pri

820-8777 E-mail: [email protected] E-mail: ann.marie.c,[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 JIBlackaroyblack.com Attorneys for Proposed Intervenor

rative process is at issue) that have not been proven by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown' City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert privile

01/20/2006 Color: Year: Description: Plate: BLACK 1995 FORD F150 PICKUP FORD F150 PICKUP - 4.9L

an I in so much pain? 'he answer Is uncettain and en still unsure. Guys are suds a waste of time, atWast i thought they were. 'For now Fir Mt a Bogle gishrm Burma stay this fl y, Linn the perfect guy comes Moog and knows gust what to say. •1:'s better to have loved and lost then to have never