Epstein Secrets

legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have been widely publicized

s of 15 EFTA00071644 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 22 of 29 lawyers on Epstein's legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have been widely publicized. See, e.g., Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

P records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Rights Watch v. Dep't of

legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have been widely publicized

s of 15 EFTA00088721 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 22 of 29 lawyers on Epstein's legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have been widely publicized. See, e.g., Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

P records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Rights Watch v. Dep't of

33131 Tele Fax: E-Mail: E-Mail: s/Martin G. Weinberg Martin G. Weinberg, Esq. MARTIN G. WEINBERG, P.

q. (FL Bar No. 42201) BLACK SREBNICK & KORNSPAN P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, Florida 33131 Tele Fax: E-Mail: E-Mail: s/Martin G. Weinberg Martin G. Weinberg, Esq. MARTIN G. WEINBERG, P.C. (MA Bar No. 519480) 20 Park Plaza, Suite 1000 Boston, Massachusetts 02116 Tele: Fax: E-Mail

ity is "at its most limited when reviewing the Executive's exercise of discretion over charging determinations." Id. In Fokker, the question before the D.C. Circuit was whether the district court had the power to decline to enter a speedy trial waiver because it believed that the terms of the DPA were too lenie

• Jay P. Lefkowitz Kirkland & Eli P Martin G. Weinberg. P.C. Criminal Defense Counsel for Jeffrey Epste

e 400 inis ma West Palm Beach, FL 33401 Attorneys for the Government Roy Black, Esq. Jackie Perczek Es . • Jay P. Lefkowitz Kirkland & Eli P Martin G. Weinberg. P.C. Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 4 EFTA00188816 Case 9:08-cv-80736-KAM Jcument 291-2 Entered on FLSD

vice in the State of Florida. 3. Prior to assuming his teaching responsibilities, PAUL G. CASSELL clerked first for the U.S. Court of Appeals for the D.C. Circuit (1984-1985) and then from 1985 to 1986 clerked for the United States Supreme Court before serving as an Associate Deputy Attorney EFTA00188845 Ca

, /s/ Roy Black Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 /s/ Martin G. Weinberg Martin G. Weinberg 20 Park Plaza, Suite 1000 Boston, Massachusetts 02116 Intervenor/Appellants and Attorneys for Intervenor/Appellants CERTIFICA

Suite 1300 Miami, Florida 33131 /s/ Martin G. Weinberg Martin G. Weinberg 20 Park Plaza, Suite 1000 B

, in which intervenors/appellants have no other appellate remedy, as they are not parties to the underlying action. See 2 As recently as May, 2013, the D.C. Circuit affirmed the continuing validity of the Perlman doctrine in In re Sealed Case, 716 F.3d 603 (D.C. Cir. 2013)(although finding a different standard

evant to the parties claims and defenses, reasoning that the quasi-privilege for tax returns had not been expressly recognized within the Circuit); Weiner v. Bache Halsey Stuart, Inc., 76 F.R.D. 624, 627 (S.D.Fla.1977) (holding that no privilege attaches to tax returns and that their discoverability t

formation by conceding that he in fact has the documents.” In re Grand Jury Subpoena, Dated April 18, 2003, 383 F.3d 905, 910 (9th Cir. 2004). The D.C. Circuit has recently refused to extend the act of production doctrine on facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Ci

relevant to the employment relationship. Thus, as the D.C. Circuit has observed, ‘‘an employer’s right to silence is

o their future rights as employees. °3Comment of Weinberg, Roger & Rosenfeld. 947d. °5Comment of Staff Re