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

y of the correspondence between the United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the

lorida 33131 By /S/ ROY BLACK, ESQ. Florida Bar No. JACKIE PERCZEK, ESQ. Florida Bar No. On Behalf of Intervenors Roy Black and Jay Lefkowitz MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 By /S/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 On Behalf ofIntervenor Martin We

tervenors Roy Black and Jay Lefkowitz MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 0211

ane Doe 2 to release materials that are plainly the privileged opinion work-product of the attorneys, that constitute settlement negotiations under Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11, and that contain information about matters occurring before the grand jury, which are strictly confidenti

.C. Docket No. 9:08-cv-80736-KAM JANE DOE NO. 1, JANE DOE NO. 2, Plaintiffs-Appellees, versus UNITED STATES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from the United States District Court for the Southern District of Florida (April 18, 2014) B

ES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appe

rs argued that the work-product privilege 5 EFTA00209389 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

.C. Docket No. 9:08-cv-80736-KAM JANE DOE NO. 1, JANE DOE NO. 2, Plaintiffs-Appellees, versus UNITED STATES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from the United States District Court for the Southern District of Florida (April 18, 2014) B

ES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appe

rs argued that the work-product privilege 5 EFTA00209430 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

on July 16, 2013, on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. Martin G Weinberg, P.C. /s/ Paul G. Cassell Paul G. Cassell 1 EFTA00209506

Black, Srebnick, Komspan & Stumpf, P.A. Martin G Weinberg, P.C. /s/ Paul G. Cassell Paul G. Cassell 1 E

specifically noted this evidentiary problem with Epstein's claim. The District Court gave as one reason for rejecting Epstein's contention based on Federal Rule of Evidence 410 that the rule does not even possibly protect "general discussions of leniency and statements made in the hope of avoiding a federal indictment - ar

.C. Docket No. 9:08-cv-80736-KAM JANE DOE NO. 1, JANE DOE NO. 2, Plaintiffs-Appellees, versus UNITED STATES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from the United States District Court for the Southern District of Florida (April 18, 2014) B

ES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appe

argued that the work-product privilege 5 EFTA00209636 Case: 13-12923 Date Filed: 04/18/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

.C. Docket No. 9:08-cv-80736-KAM JANE DOE NO. 1, JANE DOE NO. 2, Plaintiffs-Appellees, versus UNITED STATES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from the United States District Court for the Southern District of Florida (April 18, 2014) B

ES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appe

argued that the work-product privilege 5 EFTA00209745 Case: 13-12923 Date Filed: 04/18/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury

tes Court of Appeals, Eleventh Circuit. Jane DOE NO. 1, Jane Doe No. 2, Plaintiffs-Appellees, 1. UNITED STATES of America, Defendant. Roy Black, Martin G. Weinberg, Jeffrey Epstein, Intervenors-Appellants. No. 13-12923. April 18, 2014. Background: Alleged minor victims of federal sex crimes brought action aga

ATES of America, Defendant. Roy Black, Martin G. Weinberg, Jeffrey Epstein, Intervenors-Appellants. No. 13

P. 24(b), the intervenors moved for protective orders. The intervenors argued that the work-product priv- ilege protects their correspondence; that Federal Rule of Evidence 410 and Feder- al Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jur

r communications between defense lawyers and prosecutors, we wil be petitioning the court of appeals for further review,' said Boston based attorney Martin Weinberg. who represents Epstein. The U.S. Attorneys Office failed to notify victims prior to striking a non-prosecution agreement with Epstein on Sept. 24,

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

discovery of the correspondence between the U.S. and Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that th

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

ane Doc 2 to release materials that are plainly the privileged opinion work-product of the attorneys, that constitute settlement negotiations under Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure II, and that contain information about matters occurring before the grand jury, which arc strictly confidenti