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

them, the cat is out of the bag, and there will be no effective means by which TRPB can vindicate its asserted rights after final judgment"); In re Perrigo Co., 128 F.3d 430, 437 (6th Cir.1997)("We find . . . that forced disclosure of privileged material may bring about irreparable harm"); In re Grand Jury

E DOE 1 AND JANE DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL 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

f Supplemental Authority of the United States Supreme Court (Doc. 163); and Reply in Support of Supplemental Briefing By Limited Intervenors Black, Weinberg, Lefkowitz, and Epstein (Doc. 169). 4 EFTA00205363 representing a client under federal investigation have an obligation to secure the best possib

them, the cat is out of the bag, and there will be no effective means by which TRPB can vindicate its asserted rights after final judgment"); In re Perrigo Co., 128 F.3d 430, 437 (6th Cir.1997)("We find . . . that forced disclosure of privileged material may bring about irreparab e harm"); In re Grand Jury

E DOE 1 AND JANE DOE 2, Plaintiffs 1. UNITED STATES OF AMERICA, Defendant tc INTERVENORS' MOTION FOR STAY PENDINWCPPEAL 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

f Supplemental Authority of the United States Supreme Court (Doc. 163); and Reply in Support of Supplemental Briefing By Limited Intervenors Black, Weinberg, Lefkowitz, and Epstein (Doc. 169). 4 EFTA00205343 representing a client under federal investigation have an obligation to secure the best possib

them, the cat is out of the bag, and there will be no effective means by which TRPB can vindicate its asserted rights after final judgment"); In re Perrigo Co., 128 F.3d 430, 437 (6th Cir.1997)("We find . . . that forced disclosure of privileged material may bring about irreparab e harm"); In re Grand Jury

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

them, the cat is out of the bag, and there will be no effective means by which TRPB can vindicate its asserted rights after final judgment"); In re Perrigo Co., 128 F.3d 430, 437 (6th Cir.1997)("We find . . . that forced disclosure of privileged material may bring about irreparable harm"); In re Grand Jwy

e itself. CONCLUSION For all the foregoing reasons, the Court should deny plaintiffs' motion to dismiss. Respectfully submitted, hi Roy Black hi Martin G. Weinberg Roy Black Martin G. Weinberg Black, Srebnick, Kornspan & 20 Park Plaza, Suite 1000 Stumpf Boston, Massachusetts 02116 201 South Biscayne Boule

fense attorneys — appellants Roy Black and Martin Weinberg — filed motions to intervene for the limited pur

them, the cat is out of the bag, and there will be no effective means by which TRPB can vindicate its asserted rights after final judgment"); In re Perrigo Co., 128 F.3d 430, 437 (6th Cir.1997X"We find . . . that forced disclosure of privileged material may bring about irreparable harm"); In re Grand Jury

ssue in this matter. CONCLUSION For all the foregoing reasons, the requested stay pending appeal should be granted. Respectfully submitted, /s/ Martin G. Weinberg Martin G. Weinberg 20 Park Plaza, Suite 1000 Boston Massachusetts 02116 /s/ Roy Black Roy Black Black, Srebnick, Kornspan & Stumpf 201 South

INTRODUCTION Appellants Roy Black, Martin Weinberg, and Jeffrey Epstein hereby request that this Co

them, the cat is out of the bag, and there will be no effective means by which TRPB can vindicate its asserted rights after final judgment"); In re Perrigo Co., 128 F.3d 430, 437 (6th Cir.1997)("We find . . . that forced disclosure of privileged material may bring about irreparable harm"); In re Grand Jury