Epstein Secrets

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

of liberty, he has an even greater "need for confidentiality and trust between participants in a [plea negotiation]." Folb v. Motion Picture Indus. Pension & Health Plans, 161 F.Supp.2d 1164, 1175 (M. Cal. 1998).Discovery and use of plea negotiations will cause "a meaningful and irreparable chill" to the "frank and c

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

s counsel to discuss matters in an uninhibited fashion often leading to settlement . ." Id. at 930. Ten years later, in Folb'. Motion Picture hid. Pension & Health Plans, 16 F. Supp. 2d 1164, (C.D.Ca. 1998), the district court in California became the first federal court to adopt the mediation privilege as federal c

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

counsel to discuss matters in an uninhibited fashion often leading to settlement ...." Id. at 930. Ten years later, in Folb v. Motion Picture hid. Pension & Health Plans, 16 F.Supp.2d 1164, 1998), the district court in California became the first federal court to adopt the mediation privilege as federal common law

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

counsel to discuss matters in an uninhibited fashion often leading to settlement ...." Id. at 930. Ten years later, in Folb v. Motion Picture hid. Pension & Health Plans, 16 F.Supp.2d 1164, 1998), the district court in California became the first federal court to adopt the mediation privilege as federal common law