Epstein Secrets

12/2011 fa REPLY to Response to Motion rein MOTION to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz filed by Roy Black, Jay Lefkowitz, Martin G. Weinberg. (Perczek, Jacqueline) (Entered: 05/12/2011) 05/16/2011 El RESPONSE in Opposition rel2 MOTION to Intervene MOTION for Sanctions Jane Doe #1 and Ja

f Supplemental Authority of the United States Supreme Court (Doc. 163); and Reply in Support of Supplemental Briefing By Limited Intervenors Black, Weinberg, Leticowitz, and Epstein (Doc. 169). 4 EFTA00177814 already addressed the issue in Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410 and did not see fi

EDT 2 of 16 Roy Black Black, Srebnick, Komspan &Stumpf, P.A. 201 South Biscayne Boulevard Suite1300 Miami, FL 33131 305-371-6421 intervenor Martin G. Weinberg J ntervenor Jay Lefkowitz represented by Jacqueline Perczek Black Srebnick Komspan &Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 3

e admitted in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee v. Redmond, 518 U.S. 1, 10 (1996), and maintaining their confidentiality advances significant public and private ends. Discovery and use of plea negotiations

V-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the he

MENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FO

on FLSD Docket 04/17/2012 Page 10 of 23 A. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffee v. Redmond, 518 U.S. 1 (1996), is perhaps the leading case addressing Rule 501 and the common-law principles underlying the recognition of testimonial privileg

llants ON APPEAL FROM AN ORDER OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA BRIEF OF INTERVENORS/APPELLANTS ROY BLACK, MARTIN G. WEINBERG, AND JEFFREY EPSTEIN Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131

, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923 Date Filed: 08/05/2013 Page: 3 of 75 16. Weinberg, Martin 17. Doe No. 1, Jane 18. Doe No. 2, Jane /s/ Martin G. Weinberg Attorney for Intervenor/Appellants Page C-2 of 2 EFTA00209659 Case: 13

dentiality on which defense counsel have reasonably relied for many decades in negotiating with government attorneys on behalf of their clients. In Jaffee v. Redmond, 518 U.S. 1 (1996), the Supreme Court focused on four primary considerations governing the recognition of privileges under Rule 501: the needs of t

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

ge is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiat

TAY PENDING APPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby reque

JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENORS' MOTION FOR STAY PENDING APPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court stay its order of June 18, 2013 (Doc. 188), denying their Motion for a

e admitted in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee v. Redmond, 518 U.S. 1, 10 (1996), and maintaining their confidentiality advances significant public and private ends. Discovery and use of plea negotiations

has an interest in the validity of the non-prosecution agreement . . . ." Jane Doe I and Jane Doe 2's Response To Motion To Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz [DE 78] at 4. And third, in their "Motion to Use Correspondence To Prove Violations of The Crime Victim 's Rights Act And To Hav

pposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is the real par

n FLSD Docket 09/02/2011 Page 10 of 24 A. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffee v. Redmond, 518 U.S. 1 (1996), is perhaps the leading case addressing Rule 501 and the common-law principles underlying the recognition of testimonial privileg

rguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and i

oof of guilt." Herman, 544 F.2d at 797. D. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffee v. Redmond, 518 U.S. 1, 5-6 (1996), is perhaps the leading case addressing Federal Rule of Evidence 501 and the common-law principles underlying the recognitio

rguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and i

oof of guilt." Herman, 544 F.2d at 797. D. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffee v. Redmond, 518 U.S. 1, 5-6 (1996), is perhaps the leading case addressing Federal Rule of Evidence 501 and the common-law principles underlying the recognitio