Epstein Secrets

spondence [DE 51]; the government's response to the motion [DE 60]; petitioners' reply to the government's response [DE 74]; intervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the m

above prescriptions within TWENTY (20) DAYS from the date of entry of this order. 4. The motion for protective order submitted by Intervenors Black, Weinberg and Leficowitz [160, 161] and motion for protective order submitted by limited Intervenor Jeffrey Epstein [162], seeking the continued suppression

Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 8 of 11 interests to outweigh the need for probative evidence."Jaffee v. Redmond, 518 U.S. 1, 9-19,116 S. Ct.1923, 135 L.Ed. 2d 337 (1996); Trammel v. United States, 445 U.S. 40, 47,100 S. Ct. 906, 63 L.Ed.2d 186 (1980). Recogn

.C. Docket No. 9:08-cv-80736-KAM JANE DOE NO. 1, JANE DOE NO. 2, Plaintiffs-Appellees, versus UNITED STATES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from the United States District Court for the Southern District of Florida (April 18, 2014) B

ES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appe

ted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee' Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent disco

.C. Docket No. 9:08-cv-80736-KAM JANE DOE NO. 1, JANE DOE NO. 2, Plaintiffs-Appellees, versus UNITED STATES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from the United States District Court for the Southern District of Florida (April 18, 2014) B

ES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appe

ted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee' Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent disco

.C. Docket No. 9:08-cv-80736-KAM JANE DOE NO. 1, JANE DOE NO. 2, Plaintiffs-Appellees, versus UNITED STATES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from the United States District Court for the Southern District of Florida (April 18, 2014) B

ES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appe

d in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent disco

.C. Docket No. 9:08-cv-80736-KAM JANE DOE NO. 1, JANE DOE NO. 2, Plaintiffs-Appellees, versus UNITED STATES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from the United States District Court for the Southern District of Florida (April 18, 2014) B

ES OF AMERICA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appe

ed in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee'. Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent disco

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

in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee v. Redmond, 518 U.S. 1, 10 (1996), and maintaining their confidentiality advances significant public and private interests. Numerous courts have recognized a

t with the *226 defense by decid- ing after two years that it wanted a new ex- pert. Id. The court also denied as premature Fell's motion to exclude Weiner's testi- mony, holding that the nature and scope of Webees anticipated rebuttal testimony was unclear but that, even without interviewing Fell, hi

factors concerning sentencing." Id. Accordingly, the court declined to rule on admissibility prior to the government's disclosure of the scope of Weiner's projected testimony. Pursuant to the court's April 7 2005 or- der, Wetzel interviewed Fell and prepared a report explaining his findings. Fell, 2

Docket 09/02/2011 Page 10 of 23 A. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffe4. Redmond, 518 U.S. 1 (1996), is perhaps the leading case addressing Rule 501 and the common-law principles underlying the recognition of testimonial privileg

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

g the course of a mediation. Our decision whether to apply this mediation privilege .. . is governed by Federal Rule of Evidence 501 [and] Jaffee'. Redmond, 518 U.S. 1 (1996) . . . Recognizing that only those documents prepared for purposes of the confidential mediation are protected by the mediation pr