Epstein Secrets

DIATELY AT: (312) 862-2000, To: CC: Martin G. Weinberg, Esq. Company: Fax it: Direct #: prated Stat

CTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY AT: (312) 862-2000, To: CC: Martin G. Weinberg, Esq. Company: Fax it: Direct #: prated States Attorney, Southern bistrict of Florida Company: Fax #: Direct it: From: Sandra Musumeci for

well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing In.m Dow Jones & Co., Inc.„, 142 F.3d 496, 500 (D.C. Cir. 1998)); see SEC v Dresser Indust'. Inc., 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't v

OSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NO IMMEDIATELY AT: To: CC: Martin G. Weinberg, Esq. Company: Fax #: Direct #: United States Attorney, Southern District of Florida Company: Fax #: Direct Si: From: Sandra Musumeci for

, PLEASE NO IMMEDIATELY AT: To: CC: Martin G. Weinberg, Esq. Company: Fax #: Direct #: United State

well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing JaLe Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); Les also SEC Dresser Indust', Ms , 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't a

CTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY AT: (312) 862-2000, To: CC: Martin G. Weinberg, Esq. Company: United States Attorney, Southern District of Florida Company: Fax #: Direct S: Fax #: Direct N: From: Sandra Musumeci for

DIATELY AT: (312) 862-2000, To: CC: Martin G. Weinberg, Esq. Company: United States Attorney, Souther

as well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and t like.") (citing Dug Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); see also SEC Dresser Indust. la, 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't Nat'

igation. Accordingly, we request that you reconsider and decline the request of the New York District Attorney. Sincerely, Jay P. Lefkowitz, P.C. Martin G. Weinberg JPL/kla Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981, are binding as precedent in

r letter of July 27, 2011 to my co-counsel Martin Weinberg concerning the request by the New York District

s that either testified or were identified during Grand Jury proceedings are subject to the secrecy provisions of F.R.Crim.P 6(e). Ste, tg,,, In re Dow Jones & Co., Inc., 142 F.3d 496, 500 (D.C. Cir. 1998) ("Consistent with these purposes, we have recognized that grand jury secrecy covers `the identities of wit

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

cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Page 4 of 10 of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co., Inc., 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[E]ven if material concerning the grand jury

CTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY AT: (312) 862-2000, To: CC: Martin G. Weinberg, Esq. Company: United States Attorney, Southern District of Florida Company: Fax #: Direct #: Fax #: Direct tt: From: Sandra Musumeci for

DIATELY AT: (312) 862-2000, To: CC: Martin G. Weinberg, Esq. Company: United States Attorney, Souther

well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing in re Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); sce alsq SEC v Dresser hglustr, inc„ 628 F.2d 1368, 1382 (D.C. Cir. 1980); fund for Constitutional Gov't