Epstein Secrets

the Government (Bates 0001-04), court pleadings filed by the victims themselves or other victims, by Epstein, or by news media organizations (e.g., Bates 00142-88, 00229-31, 281-311, 00668-69), public court rulings on Epstein related matters (e.g., Bates 0008-10, 0012-14. 0036-86, 00190-228), public

cuments apply to which of the victims' document production requests. Instead, the Government has simply taken more than 13,000 pages of documents, Bates stamped them in no particular order (or at least no order that the victims can discern), and then asserted that they are all privileged for various

on the following using the Court's CM/ECF system: West Palm Beach, FL 33401 Fax: E-mail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black Srebnick Korns . an & Stum.f P.A. Miami, FL 33131 Email: Jay P. Lefkowitz Kirkland & Ellis, LLP New York NY 10022 Email: Martin G

the Government (Bates 0001-04), court pleadings filed by the victims themselves or other victims, by Epstein, or by news media organizations (e.g., Bates 00142-88, 00229-31, 281-311, 00668-69), public court rulings on Epstein related matters (e.g., Bates 0008-10, 0012-14. 0036-86, 00190-228), public

cuments apply to which of the victims' document production requests. Instead, the Government has simply taken more than 13,000 pages of documents, Bates stamped them in no particular order (or at least no order that the victims can discern), and then asserted that they are all privileged for various

820-8711 Fax: (561) 820-8777 E-mail: [email protected] E-mail: ann.marie.c,[email protected] Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 JIBlackaroyblack.com Attorneys for Propos

he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t

nd E-Mail Transmission: Assistant U.S. Attorneys West Palm Beach, FL 33401 Fax: E-mail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black Srebnick Koms an & Stumpf, P.A. Miami. FL 33131 Attorneys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradl

he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t

on October 3, 2011, on the following via US Mail and E-Mail Transmission: Assistant U.S. Attorneys Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. Attorneys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradley J. Edwards

he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t

est Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lee0,usdoi.gov E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 [email protected] Attorneys for Propose

e attached as Exhibit J to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp).' Because Epstein has moved to keep these documents from the public, they are at this time filed under seal with the Court. Threugh-

e foregoing reasons, the Court should GRANT this motion and enter the requested Protective Order. Respectfully submitted, /s/Roy Black Roy Black Jackie Perczek BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 So. Biscayne Blvd., Suite 1300 Miami, Florida 33131 Tele: (305) 371-6421 -12- EFTA00191301 Case