Epstein Secrets

MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW EMAIL ADDRESSES: BOSION.

MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW EMAIL ADDRESSES: BOSION. MA IUSETTS 02116 FAX NI HT EMERGENCY July 26, 2019 Electronic Mail Assistant United States At

in relation to the government's response to the court's summary judgment order and proposed remedies in Jane Doe v. United Stales, No. 08-cv-80736 (S.D. Fl.); 7. Information provided by alleged victims (or their counsel) related to Mr. Epstein prior to the return of the above-captioned Indictment; Ple

MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW EMAII ADDRESSES BOSTON, MASSACHUSETTS 02116 FAX July 26, 2019 Electronic Mail Assistant United States Attorneys U.S. At

MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW EMAII ADDRESSES BOSTON,

in relation to the government's response to the court's summary judgment order and proposed remedies in Jane Doe v. United Stales, No. 08-cv-80736 (S.D. Fl.); 7. Information provided by alleged victims (or their counsel) related to Mr. Epstein prior to the return of the above-captioned Indictment; Ple

MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW EMAIL ADDRESSES: NI CY July 26, 2019 Electronic Mail Assistant United States Attorneys U.S. Attorney's Office for the S

MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW EMAIL ADDRESSES: NI CY

in relation to the government's response to the court's summary judgment order and proposed remedies in Jane Doe v. United Stales, No. 08-cv-80736 (S.D. Fl.); 7. Information provided by alleged victims (or their counsel) related to Mr. Epstein prior to the return of the above-captioned Indictment; Ple

West Palm Beach, FL 33401 14 ANN , ESQ. 15 Assistant U.S. Attorney 500 East Broward Boulevard 16 Fort Lauderdale, FL 33394 For U.S.A. 17 MARTIN G. WEINBERG, ESQ. 18 20 Park Plaza Boston MA 02116 19 (Via telephone) 617.227.3700 20 JAY LEFKOWITZ, ESQ. (Via telephone) 21 REPORTED BY: LARRY HERR,

3 MR. CRITTON: Your Honor, we have two members of the 14 defense team are on the phone, also. 15 THE COURT: Who do we have on the phone? 16 MR. WEINBERG: Martin Weinberg. Good morning, Your 17 Honor. 18 MR. LEFKOWITZ: Jay Lefkowitz. Good morning, Your 19 Honor. 20 THE COURT: Good morning. 21 I

elled self-incrimination in connection with civil litigation, a court can stay discovery or the entire civil case. Diaz'. Jenne, 2007 WL 624286 al (S.D. Fl. Feb. 23, 2007) (Cooke, J.). "However, 'the Constitution does not require a stay of civil proceedings pending the outcome of related criminal procee

03/28/2011 Page 3 of 3 We also certify that a copy of the foregoing was sent via separate email to all counsel of record. Respectfully submitted, MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 By r IM 1 ARTIN G. WEINBERG, ESQ. Massachusetts Bar

ntervenor attomcyJ ay Lefkowitz within the next few days, as soon as a certificate of good standing from the New York Bar arrives. Attorneys Black, Weinberg and Lcfkowitz do not seek intervention to litigate whether the Crime Victims' Rights Act was violated and if so, against whom a remedy is appropriat

and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States' Steinger, 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand iury system depends upon the secrecy of grand jury proceedings," Douglas Oil Co. Petrol Stops Northwe

n federal detention and bail law is: Hon. John L. Weinberg, Federal Bail and Detention Handbook (2003), whi

n 3142 (g). United States . King, 849 F.2d 485, 488 (11th Cir. 1988). Sciacca (unpublished opinion), Court File No. 03-80164-Cr-Hurley, at pp. 4-5 (S.D. Fl. Feb. 25, 2004). Here, the defendant's blatant disregard of the order of the Florida court regarding his contact with the victim shows his continu