Epstein Secrets

t 247 Entered on FLSD Docket 05/02/2014 Page 13 of 13 Fax: (305) 358-2006 rblackQrovblack.com joerczekQrovblack.com Attorneys for Intervenors /s/Martin G. Weinberg Martin G. Weinberg 20 Park Plaza, Suite 1000 Boston, Massachusetts 02116 Tele: (617) 227-3700 Fax: (617) 338-9538 owlmgw(aatt.net Attorney for

said Cassell, who is based in Salt Lake City. But one of Epstein's attorney's, Martin Weinberg, based in Boston, disputed those characterizations. Weinberg said Monday that the plea agreement was "reached in good faith" and that "it's not a fair conclusion" to describe the agreement as either improper o

923 D.0 Docket No.9 OS•cv.80736-KASI JANE DOE NO. I. JANE DOE NO 2. Plasottifs•AppcIlett setup UNITED STATES OF Al 'MC Dtforbeti. ROY BLACK. MARTIN 0 WEINBERG. SEEFRE1 EPSTEIN. Intentoon•Appelloote Appeals eons the Weed States Amite Coon fo the &Mika) APma of Fkuidn tAptil IS 2014) Berme PRYOR Intl MA

ed on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E

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

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use 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

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

ers, v. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ ]DE94] The United States of America, by and through the undersigned Assistant United States Attorney, hereby files this Respon

ORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ ]DE94] The United States of

and information should be privileged under a common law plea negotiations privilege. In addition, in its initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the P

MEMORANDUM OF LAW Intervenors Roy Black, Martin Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c) of

ully submitted, /s/Rov Black Roy Black Jackie Perczek BLACK, SREBNICK, KORNSPAN & STUMPF P A. -12- EFTA00605762 Attorneys for Intervenors Is/Martin G. Weinberg Martin G. Weinber Attorney for Intervenors CERTIFICATE OF SERVICE I HERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this 2"

d on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E

3131 Telephone (305) 371-6421 Fax (305) 358-2006 By: _/s/ ROY BLACK, ESQ. Florida Bar No. 126088 JACKIE PERCZEK, ESQ. Florida Bar No. 042201 MARTIN G. WEINBERG, ■. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 By: _/s/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar

PERCZEK, ESQ. Florida Bar No. 042201 MARTIN G. WEINBERG, ■. 20 Park Plaza Suite 1000 Boston, MA 02116

harm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et at, Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecution agreement which wo