Epstein Secrets

11 Case Name Rothstein Rosenfelt:II Adler, PA Case Numbers Manning Document Number:=t Docket Tear Er Pawn Motion to Appear pro lime vice by MartnCi Weinberg Filed by Interested Pay Jeffrey Efacin (Attachments. o ( I ) Proposed Order) (Nerwinh, Ronald) The following domina(t) are associated with this tran

P.A. Debtor. CASE NO. 09-34791-BKC-REIR CHAPTER 11 EX PARTE ORDER ADMITTING ATTORNEY PRO HAC VICE This matter was considered without hearing on Martin G. Weinberg's Motion to Appear Pro Hac Vice in this case pursuant to Local Rules 2090-1(B)(2) and 9013-l(C)(9). The Court having reviewed the Motion and good cau

opy of the Motion to Appear Pro Vice of Martin G. Weinberg of the firm Martin G. Weinberg, P.C., was served

ore the United States Supreme Court, First Circuit, Second Circuit, Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit, and Eleventh Circuit. 3. Movant designates RONALD G. NE1W1RT14, ESQ., of FOWLER WHITE BURNETT, P.A., who is qualified to practice in this Court and who consents to des

11 Case Name Rothstein Rosenfelt:II Adler, PA Case Numbers Manning Document Number:=t Docket Tear Er Pawn Motion to Appear pro lime vice by MartnCi Weinberg Filed by Interested Pay Jeffrey Efacin (Attachments. o ( I ) Proposed Order) (Nerwinh, Ronald) The following domina(t) are associated with this tran

opy of the Motion to Appear Pro Vice of Martin G. Weinberg of the firm Martin G. Weinberg, P.C., was served

P.A. Debtor. CASE NO. 09-34791-BKC-REIR CHAPTER 11 EX PARTE ORDER ADMITTING ATTORNEY PRO HAC VICE This matter was considered without hearing on Martin G. Weinberg's Motion to Appear Pro Hac Vice in this case pursuant to Local Rules 2090-1(B)(2) and 9013-l(C)(9). The Court having reviewed the Motion and good cau

ore the United States Supreme Court, First Circuit, Second Circuit, Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit, and Eleventh Circuit. 3. Movant designates RONALD G. NE1W1RT14, ESQ., of FOWLER WHITE BURNETT, P.A., who is qualified to practice in this Court and who consents to des

te or knowing” and the “motive underlying the lawyer’s conductis not determinative; instead the issue is whether he or she purposefully acted.”439 In Feinberg, the court concluded that the prosecutor violated FRPC 4-4.1 and 4-8.4(c) and (d) by deliberately making untruthful statements to a defense attorney,

CES GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: MAURENE R. COMEY ALISON MOE Assistant United States Attorneys MARTIN G. WEINBERG, PC Attorney for Defendant BY: MARTIN G. WEINBERG STEPTOE & JOHNSON, LLP Attorneys for Defendant BY: REID WEINGARTEN MICHAEL MILLER SOUTHERN DISTRICT

or knowing" and the "motive underlying the lawyer's conduct'is not determinative; instead the issue is whether he or she purposefully acted." 439 In Feinberg, the court concluded that the prosecutor violated FRPC 4-4.1 and 4-8.4(c) and (d) by deliberately making untruthful statements to a defense attorne

have believed that this state plea could affect the federal investigation or the rights of my clients in that federal investigation.” I In Wild, the Eleventh Circuit panel stated that the government “seemingly” deferred to Epstein’s attorneys’ requests not to notify the victims about the NPA, and that in sending t

ca, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should app

PORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of A

dings, it was reasonable for both parties to assume that their communications would remain confidential. Although the undersigned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a comp

ca, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should app

PORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of A

dings, it was reasonable for both parties to assume that their communications would remain confidential. Although the undersigned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a comp

May 2, 2011. on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. ism Martin G. Weinberg, P.C. Joseph L. Ackerman, Jr. Fowler White Burnett PA 8 EFTA00207983

ONSE TO MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ COME NOW Jane Doe #1 and Jane

s that the Government failed (for example) to confer with Jane Doe #1 and Jane Doe #2 about their rights as sexual assault victims. The controlling Eleventh Circuit case law on intervention (not cited by the defense attorneys) requires that a putative intervenor be the equivalent of a real party in interest: "In

r communications between defense lawyers and prosecutors, we wil be petitioning the court of appeals for further review,' said Boston based attorney Martin Weinberg. who represents Epstein. The U.S. Attorneys Office failed to notify victims prior to striking a non-prosecution agreement with Epstein on Sept. 24,

said Cassell, who is based in Salt Lake City. But one of Epstein's attorney's, Martin Weinberg, based in Boston, disputed those characterizations. Weinberg said Monday that the plea agreement was "reached in good faith" and that "it's not a fair conclusion" to describe the agreement as either improper o

COMPOSITE EXHIBIT 3 EFTA00605732 Eleventh Circuit rules that discovery can move forward on my Crime Victims' Rights Act... Page 1 of 3 Print Eleventh Circuit rules that discovery can move forward

cqueline Perczek, Roy Eric Black, Black Srebnick Kornspan & Stumpf, Miami, FL; Jay P. Lefkowitz, PRO HAC VICE, Kirkland & Ellis, LLP, New York, NY; Martin G. Weinberg, PRO HAC VICE, Martin G. Weinberg, P.C., Boston, MA. For Martin G. Weinberg, Jay Lefkowitz, Intervenors: Jacqueline Perczek, Black Srebnick Kornspa

, Kirkland & Ellis, LLP, New York, NY; Martin G. Weinberg, PRO HAC VICE, Martin G. Weinberg, P.C., Boston,

d because [124] the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which opinion work product is discover

her discussions. Respectfully submitted, MARTIN WEINBERG, ESQ. ROY SLACK, ESQ. By /wg cc: Jeffrey Slo

reement will provide a basis for a prompt resolution of any issue not resolved by the parties through further discussions. Respectfully submitted, MARTIN WEINBERG, ESQ. ROY SLACK, ESQ. By /wg cc: Jeffrey Sloman, Esq. Robert Senior, Esq. Black, Srebnick. Kornspan & Stumpf, P.A. EFTA00193777 ROY BLACK

false claims. 2. Rothstein and his co-conspirators abused the legal process in other cases. They forged the signature of judges, and even forged an Eleventh Circuit opinion. 3. Rothstein lawyers demanded phony protective orders. 4. In our case, they sought discovery. of Epstein's plane logs to fish for celebr

See also Florida Bar re Webster, 647 So. 2d 816 (Fla. 1994) (petition for reinstatement denied due to “misrepresentation by omission”). 442 In Feinberg, 760 So. 2d at 938, the court found that an Assistant State Attorney lacked candor and violated ethics rules when, after meeting with a defendant ou

or knowing” and the “motive underlying the lawyer’s conduct is not determinative; instead the issue is whether he or she purposefully acted.”439 In Feinberg, the court concluded that the prosecutor violated FRPC 4-4.1 and 4-8.4(c) and (d) by deliberately making untruthful statements to a defense attorne

elieved that this state plea could affect the federal investigation or the rights of my clients in that federal investigation.” In Wild, the Eleventh Circuit panel stated that the government “seemingly” deferred to Epstein’s attorneys’ requests not to notify the victims about the NPA, and that in sending