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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
rstatement. '''N) Whether to negotiate a plea or contest a criminal charge "is ordinarily the most important single decision in any criminal case." Boria v. Keane, 99 F.3d 492 (2d Cir. 1996). In the age of the Sentencing Guidelines, with the severe sentences called for in federal criminal cases, minimum manda
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
tation of Counsel Whether to negotiate a plea or contest a criminal charge "is ordinarily the most important single decision in any criminal case." Boria v. Keane, 99 F.3d 492 (2d Cir. 1996). In the age of the Sentencing Guidelines, with the draconian sentences called for in federal criminal cases, minimum ma
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
l understatement. Whether to negotiate a plea or contest a criminal charge "is ordinarily the most important single decision in any criminal case." Boria v. Keane, 99 F.3d 492 (2d Cir. 1996). In the age of the Sentencing Guidelines, with the severe sentences called for in federal criminal cases, minimum manda
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
TAY PENDING APPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby reque
l understatement. Whether to negotiate a plea or contest a criminal charge "is ordinarily the most important single decision in any criminal case." Boria v. Keane, 99 F.3d 492 (2d Cir. 1996). In the age of the Sentencing Guidelines, with the draconian sentences called for in federal criminal cases, minimum ma
rguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and i
EL EFTA00301866 Whether to negotiate a plea or contest a criminal charge "is ordinarily the most important single decision in any criminal case." Boria v. Keane, 99 F.3d 492 (DATE). In the age of the Sentencing Guidelines, with the draconian sentences called for in federal criminal cases, minimum mandatorie
rguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and
of counsel includes counsel s informed opinion as to what pleas should be entered. United States v. Villar, 416 F.Supp. 887, 889 (S.D.N.Y. 1976); Boria v. Keane, 99 F.3d 492, PAGE (DATE), citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992). Counsel also has a constitutiona
rguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and i
EL EFTA00301889 Whether to negotiate a plea or contest a criminal charge "is ordinarily the most important single decision in any criminal case." Boria v. Keane, 99 F.3d 492 (DATE). In the age of the Sentencing Guidelines, with the draconian sentences called for in federal criminal cases, minimum mandatorie
Entities connected to both Martin Weinberg and Boria v. Keane

Jeffrey Epstein
PERSONLeon Black
PERSON
United States
LOCATIONRoy Black
PERSONJane Doe
PERSON
Jay Lefkowitz
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Michael Cohen
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSON
Supreme Court
ORGANIZATIONEmmy Taylor
PERSON
Bradley Cooper
PERSONthe Eleventh Circuit
ORGANIZATIONHerman
PERSON
Chris Christie
PERSON
Columbia University
LOCATIONSantobello
PERSONthe Northern District
LOCATION