Epstein Secrets

ca, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should app

PORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of A

n attorney's work is for his client's advantage, opposing counsel or adverse parties should not gain the use of that work through discovery." In re John Doe, 662 F.2d 1073, 1081 (4i° Cir. 1981). As is required by the Sixth Amendment, a criminal defense attorney must exert his best efforts to convince the

ca, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should app

PORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of A

n attorney's work is for his client's advantage, opposing counsel or adverse parties should not gain the use of that work through discovery." In re John Doe, 662 F.2d 1073, 1081 (4i° Cir. 1981). As is required by the Sixth Amendment, a criminal defense attorney must exert his best efforts to convince the

[email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 Boston. MA 0211

1 (305) 358-2006 Jay P. Leflcowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 Boston. MA 02116 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 9 EFTA00208681

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Motor Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E. Rule 6(e) —

has an interest in the validity of the non-prosecution agreement . . . ." Jane Doe I and Jane Doe 2's Response To Motion To Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz [DE 78] at 4. And third, in their "Motion to Use Correspondence To Prove Violations of The Crime Victim 's Rights Act And To Hav

pposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is the real par

(4th Cir.1992) (opinion work product "absolutely immune" from discovery); In re Martin Marietta Corp., 856 F.2d 619, 625 (4th Cir.1988); In re John Doe, 662 F. 2d 1073, 1080 ( 4th Cir. 1981), cert. denied 455 U.S. 1000, 102 *463 S.Ct. 1632, 71 L.Ed.2d 867 (1982) (opinion O 2011 Thomson Reuters. N

m (305) 37106421 Jay P. Leflcowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 Email: [email protected] (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley

[email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 0211

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Moto• Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E Rule 6(c) —

n), NBC News (12/15, Caputo), ABC News (12/15, Hutzler, Gomez), CBS News (12/15, Becket), Fox News (12/15, Hagstrom, Sabes), The Independent (12/15, Feinberg, Marcus), The Hill (12/15, Schonfeld), HuffPost (12/15, Golgowski), The Daily Beast (12/15, McDougall), Newsweek (12/15, Reynolds), Politico (12/15

nt Shore. According to the article, consumer genetic data provided by users hoping to locate their own relatives enabled investigators to identify "John Doe 1978" as Kenneth Nevada Williams, 15. The article noted that the FBI, which conducted the investigative genealogy, had no comment on the case. The a

at profound empathy for victims, deep commitment to fairness of process, fairness of outcome. And also Camille Viras (Ph.) who has worked with Mr. Feinberg over many years and is also a leading expert. I selected those three people to design, and then Ms. Feldman to administer the program. However, wha

ng to be organized and have a nice presentation. I appreciate it. I'm not trying to be critical. I'm just saying it's really not necessary. On the John Doe -- John Doe? Jane Doe, Jane Doe issues, I have no problem signing an order. The only question is what form of order. And because there are several

the existence of cancer, the personal testimony of the lay sufferer is entitled to no weight...... 4I Furthermore, as the Supreme Court found in Weinberger v. Hynson, Westeott and Dunning, Ine.,43: (FDA's] strict and demanding standards, barring anecdotal evidence indicating that doctors "believe" in

D STATES of America, John N. Mitchell, Attorney General of the V. S., Frederick II. InceY, United States AtFy for the District of New Jersey, and John Doe, any Federal Law Enforce- ment Officer Joseph Caruano, Appellant In No. 18903 Charles Majurf, Appellant in No. 15904. Nos. 18003, 18904. United S