Epstein Secrets

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

mpany's disclosure of documents to the SEC during criminal investigation waived work product protections); Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question); In re Columbia

May 2, 2011. on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. ism Martin G. Weinberg, P.C. Joseph L. Ackerman, Jr. Fowler White Burnett PA 8 EFTA00207983

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

e government is no longer confidential — and therefore no longer protected by the work-product doctrine. See Grace United Methodist Church City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question). Because no con

overnment Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 i i FL 33131 ia Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 B° sto MI n MA 02116 Joseph L. Ackerman, Jr. Fowler White Burnett PA 777 S. Flagler Drive, West Tower, Suite 901

Boulevard Suite 1300 i i FL 33131 ia Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 B° sto MI n MA

government is no longer confidential — and therefore no longer protected by the work-product doctrine. See Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question). Because no con