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

and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to

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

and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to

and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK. MARTIN WEINBERG, AND JAY LEFKOWITZ COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond in opp

PPORT OF MOTION TO INTERVENE OF ROY BLACK. MARTIN WEINBERG, AND JAY LEFKOWITZ COME NOW Jane Doe #1 and Jan

f work product materials to the government during plea bargaining waives all work product protection. The Government acknowledges, for example, that Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure o

spondence [DE 51]; the government's response to the motion [DE 60]; petitioners' reply to the government's response [DE 74]; intervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the m

above prescriptions within TWENTY (20) DAYS from the date of entry of this order. 4. The motion for protective order submitted by Intervenors Black, Weinberg and Leficowitz [160, 161] and motion for protective order submitted by limited Intervenor Jeffrey Epstein [162], seeking the continued suppression

293 F.3d 289 (6th Cir. 2002), cert. dismissed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 450 F.3d 1179 (10'" Cir. 2006); Westinghouse Electric Corp. v Republic of Philippines, 951 F.2d 1414, 1428-31 (3d Cir. 1991); In re Subpoena Duces Tecum, 738 F.2d 1367, 1372 (D.C. Cir. 1984). Finally, the c

spondence [DE 51]; the government's response to the motion [DE 60]; petitioners' reply to the government's response [DE 74]; intervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the m

above prescriptions within TWENTY (20) DAYS from the date of entry of this order. 4. The motion for protective order submitted by Intervenors Black, Weinberg and Lefkowitz [160, 161] and motion for protective order submitted by limited Intervenor Jeffrey Epstein [162], seeking the continued suppression u

293 F.3d 289 (6ih Cir. 2002), cert. dismissed, 539 U.S. 977 (2003); In re Quest Communications International, Inc., 450 F.3d 1179 (10ih Cir. 2006); Westinghouse Electric Corp. v Republic of Philippines, 951 F.2d 1414, 1428-31 (3d Cir. 1991); In re Subpoena Duces Tecum, 738 F.2d 1367, 1372 (D.C. Cir. 1984). Finally, the c