Epstein Secrets

y 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10. 11. 12. 13. 14. 15. l• 16. Weinberg, Martin C-1 of 2 EFTA00209356 17. Doe No. 1, Jane 18. Doe No. 2, Jane Note: As they have in the court below, as well as in parallel civil court

00209366 Procedural History Regarding Releasing the Correspondence On April 7, 2011, Epstein's criminal defense attorneys — appellants Roy Black, Martin Weinberg, and Jay Lefkowitz — filed a motion for limited intervention in the case, arguing that their right to confidentiality in the correspondence would b

ION 20 EFTA00209358 TABLE OF AUTHORITIES Cases Bogle v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003) 22 Florida Wildlife Federation, Inc. v. South Florida Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011) 21 Holt-Orsted v. City of Dickson, 641 F.3d 230, 236-40 (6th Cir. 2011) 14, 15, 19 In re Sealed Case, ---

ay 9. IMPIIPIS 10. Lefkowitz, Jay 11. Perczek, Jackie 12. libuilm.1 13. ra.c....1.„ , ‘,1„ 1. 14. Sloman, Jeffrey 15. 101010MRNI,PIIIIMP 16. Weinberg, Martin C-1 of 2 EFTA00209568 17. Doe No. 1, Jane 18. Doe No. 2, Jane Note: As they have in the court below, as well as in parallel civil court

00209578 Procedural History Regarding Releasing the Correspondence On April 7, 2011, Epstein's criminal defense attorneys — appellants Roy Black, Martin Weinberg, and Jay Lefkowitz — filed a motion for limited intervention in the case, arguing that their right to confidentiality in the correspondence would b

ate jurisdiction. His appeal must accordingly be dismissed for lack of subject matter jurisdiction. See, e.g., Florida Wildlife Federation, Inc.'. South Florida Water Management Dist, 647 F.3d 6 It is instructive to note that, even though the correspondence at issue is between Epstein's attorneys and the Government's attorneys,

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

intiffs rely for the proposition that this appeal should be dismissed for lack of subject matter jurisdiction, Florida Wildlife Federation, Inc. v. South Florida Water Management Dist, 647 F.3d 1296 (11th Cir. 2011), is wholly inapposite. The issue in that case was whether intervenors had standing to appeal a consent decree, and

f of their client to resolve the ongoing criminal investigation of him. Both Mr. Epstein and his criminal defense attorneys — appellants Roy Black, Martin Weinberg, and Jay Lefkowitz — filed motions to intervene for the limited purpose of challenging the use and disclosure of the settlement/plea negotiation co

defense attorneys — appellants Roy Black, Martin Weinberg, and Jay Lefkowitz — filed motions to intervene

intiffs rely for the proposition that this appeal should be dismissed for lack of subject matter jurisdiction, Florida Wildlife Federation, Inc. v. South Florida Water Management Dist, 647 F.3d 1296 (11th Cir. 2011), is wholly inapposite. The issue in that case was whether intervenors had standing to 19 EFTA00584621 Plaintiffs