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

ed by Judge on 9/26/2011. (ir) (Entered: 09/26/2011) 09/27/2011 jail RESPONSE/REPLY tom Supplement Briefing in Support of Motion to Intervene of Black, Weinberg, and Lelkowitz by United States of America. (Villafana, Ann Marie) (Entered: 09/27/2011) 09/28/2011 jaL MOTION for Extension of Time to File Respo

uite1300 Miami, FL 33131 305-371-6421 represented by Jacqueline Perczek Black Srebnick Komspan & Stumpf Jay P. Lefkowitz Kirkland & Ellis, LLP Martin G. Weinberg Martin G. Weinberg, P.C. Roy Eric Black Black Srebnick Komspan & Stumpf https://ecf flsd.circltdcn/cgi-bin/DktRpt.pl?818316027212123-L_1_0-1 6/2

n https://ecf.flsd.circ 1 1 .dcri/cgi-bin/DktRpt.p17818316027212123-L_1_0-1 6/27/2013 EFTA00209223 CM/ECF - Live Database - flsd Page 14 of 24 Weinberg, and Jay Lejkowitz by Roy Black (Perczek, Jacqueline) (Entered: 09/02/2011) 09/16/2011 21 Unopposed MOTION for Extension of Time to File Response/

eth A. Marra on 9/26/2011. (ir) (Entered: 09/26/2011) 09/27/2011 100 RESPONSE/REPLY to 94 Supplement Briefing in Support of Motion to Intervene of Black, Weinberg, and Lefkowitz by United States of America. ( Ann Marie) (Entered: 09/27/2011) 09/28/2011 i (Court only) ***Motions terminated: 41 Plaintiffs MO

/S/ ROY BLACK, ESQ. Florida Bar No. 126088 JACKIE PERCZEK, ESQ. Florida Bar No. 0042201 On Behalf of Intervenors Roy Black and Jay Lefkowitz MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 By /S/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar

of the investigation properly protected by Rule 6(e)). Jane Doe 1 and Jane Doe 2 also oppose intervention because they claim that attorneys Black, Weinberg, and Lefkowitz do not have an interest "in" the underlying action against the U.S. Attorney's Office. They claim that to intervene to assert a claim

ENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ Jane Doe I and Jane Doe 2 oppose intervention because according to them, proposed intervenors Black, Weinberg and Lefkowitz do not have a claim of privilege or confidentiality. Jane Doe I and Jane Doe 2 contend that all the correspondence at issue was alread

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

9:08-cv-80736-KAM Document 93 Entered on FLSD Docket 09/02/2011 Page 3 of 9 First, they argued in their opposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is the real party in interest" and that "harm from the release of the materials (if any) could be only to Jeffrey

E I and JANE DOE 2, 1. Plaintiffs, UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that wa

RICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed during the litigation on intervention. We only

, ESQ. Florida Bar No. 126088 JACKIE PERCZEK, ESQ. Florida Bar No. 0042201 On Behalf of Limited Intervenors Jeffrey Epstein And Attorneys Black, Weinberg, and Lefkowitz 4 EFTA00208184

TES OF AMERICA, Defendant. MOTION TO STRIKE NOTICE OF SUPPLEMENTAL AUTHORITY This is a motion by limited intervenors Jeffrey Epstein and attorneys Black, Weinberg, and Lefkowitz, to strike the plaintiffs' notice of supplemental authority [DE 173] because the "authority" cited by the plaintiffs — a comment by

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

s and emails that Jane Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56), as well as during the August 12, 2011 hearing.

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

s and emails that Jane Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56], as well as during the August 12, 2011 hearing.