Epstein Secrets

g the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached i

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

tion between the intervenor and the adverse party." Alvarado v. J.C. Penney Co., Inc., 997 F.2d 803, 805 (10th Cir. 1993) (quoting United States v. Oregon, 657 F.2d 1009, 1014 (9th Cir. 1981)). One illustration of the way in which Epstein is seeking to avoid ordinary litigation obligations comes from

820-8711 Fax: (561) 820-8777 E-mail: [email protected] E-mail: [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 (305) 37106421 (305) 358-2006 21 EFTA00

tion between the intervenor and the adverse party." Alvarado v. J.C. Penney Co., Inc., 997 F.2d 803, 805 (10th Cir. 1993) (quoting United States v. Oregon, 657 F.2d 1009, 1014 (9th Cir. 1981)). One illustration of the way in which Epstein is seeking to avoid ordinary litigation obligations comes from

ECF system: Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach FL 33401 Fax: E-mail: E-mail: Attorne Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 21 EFTA00614106

oiding the improper deposition. secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached i

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

oper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached i

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

oper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached i

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

oper deposition. AUSA Villafaila secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached.

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