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zier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock v. United Slates, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside the grand jury ro
he Court's earlier finding. The Government also candidly admits that since then "the delay from October 28, 2010 through early March 2011 was due to the United States' efforts to reach [an] amicable resolution of the case . . . .. Gov't Resp. at 46 n.22. 9 The CVRA does not appear to impose specific timelines for v
ring before Epstein and Groff that had nothing to do with the inner workings of the grand jury. There is abundant caselaw to that effect. See, e.g., United States v. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blal
The defense attorneys have no interest in that "transaction" — it concerns only the crime victims, the Government, and Jeffrey Epstein. Simply put, Roy Black et al. have no recognized "interest" in whether or not the Court finds that the Government failed (for example) to confer with Jane Doc #1 and Jane Doe #
port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[Tjhe United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE
ernment which may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and United States v. Agurs, 427 U.S. 97 (1976)." The Court should adopt that language to the case at hand here. Interesting, the Standing Discovery Order — and asso
Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 JIBlackaroyblack.com Attorneys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. EFTA00179736 Case
ing crime victims informed. Just as the Government cannot illegally agree to run a sentence on a new crime concurrently with a probation revocation, United States v. Walker, 98 F.3d 944 (7th Cir. 1996), so too here it cannot illegally agree not to prosecute a sex offender without first conferring with his vict
sing with those that it does not. 9 Epstein, however, has sent in his surrogates to litigate in this case, including his criminal defense attorneys Roy Black et al. and an attorney who has represented persons close to him, Bruce Reinhart. 20 EFTA00304761 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD D
ing crime victims informed. Just as the Government cannot illegally agree to run a sentence on a new crime concurrently with a probation revocation, United States I Walker, 98 F.3d 944 (7th Cir. 1996), so too here it cannot illegally agree not to prosecute a sex offender without first conferring with his victi
sing with those that it does not. 9 Epstein, however, has sent in his surrogates to litigate in this case, including his criminal defense attorneys Roy Black et al. and an attorney who has represented persons close to him, qtr 20 EFTA00204911 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/
lies. In any event, it is obvious that grand jury secrecy only extends to matters that occurred in secret before the grand jury. See, e.g., Blalock. United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside the grand jury roo
The defense attorneys have no interest in that "transaction" — it concerns only the crime victims, the Government, and Jeffrey Epstein. Simply put, Roy Black et al. have no recognized "interest" in whether or not the Court finds that the Government failed (for example) to confer with Jane Doe #1 and Jane Doe #
port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE
for the Government Roy Black, Esq. Jackie Perczek, Esq. Black Srebnick Koms an & Stumpf, P.A. Miami. FL 33131 Attorneys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. EFTA00208645 Case
port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search foi that information." DE
ys Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. Attorneys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, EFTA00615906 Case 9:00-
port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE
Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 [email protected] Attorneys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradley J Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. EFTA00081153 Case 9
Entities connected to both United States and Roy Black et al

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSON
Scarlett Johansson
PERSON
Bill Clinton
PERSONJack Goldberger
PERSON
Julie K. Brown
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Samantha Power
PERSON