Epstein Secrets

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

nsely practical one, grounded in the realities of litigation in our adversary system." United States'. Nobles 422 U.S. 225, 238 (1975).. Relying on Sporck Peil, 759 F.2d 312 (3d Cir. 1985), and its progeny, Plaintiff contends that the compilation of non-privileged documents by attorneys is "opinion wo

n this case, should be rejected. A. The Supposedly Unassailable Sporck Plaintiff's Memorandum makes it appear as though the principle announced in Sporck has been accepted as gospel throughout the federal court system. Nothing could be further from the truth. Not only was Sporck a 2-1 decision with a

any wrongdoing, Mr. Epstein retained Roy Black, Esq., to represent him in connection with the then ongoing state investigation. Black Aff. ¶3. Mr. Black in turn hired of a a private investigation firm, to assist him in his representation of Mr. Epstein. Black Aff. 14. During the course of the stat

discovery fall within the highly-protected category of opinion work product. Shelton v. American Motors Corp., 805 F.2d 1323, 1329 (8th Cir. 1986); Sporck v. Pell, 759 F.2d 312, 315-16 (3d Cir. 1985); United States v. District Council of New York City and Vicinity of the United Bhd. of Carpenters and

ack, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Correspondence Dated July 13. 2007 Dear Mr. Black: July 16, 2007 Thank you for your letter of July 13, 2007. You and your firm are neither a subpoenaed party nor counsel to a subpoenaed party. Acc

discovery fall within the highly-protected category of opinion work product. Shelton v. American Motors Corp., 805 F.2d 1323, 1329 (8th Cir. 1986); Sporck v. Pell, 759 F.2d 312, 315-16 (3d Cir. 1985); United States v. District Council of New York City and Vicinity of the United Bhd of Carpenters and J