Epstein Secrets

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 celebri

ve been stymied from debunking fraudulent claims brought by the Rothstein criminal enterprise because you have threatened that such action on Black Srebnick. Komspan & Stumpf, PA EFTA00014179 --- PAGE BREAK --- December 9, 2009 Page 3 our part would constitute a breach of the NPA. So the Rothstein la

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

5-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 371-06421 Fax (305) 358-2006 E-mail: [email protected]

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

5-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 371-06421 Fax (305) 358-2006 E-mail: [email protected]

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

The foregoing document was served on 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

with this portion of Boyd, the relevant portion of Boyd pertaining to an individual's private papers has not been directly overruled. Indeed, the Eleventh Circuit, in a case decided pre-Hubbell, left open the question of the continued vitality of Boyd with respect to personal documents. In re Grand Jury Inves

e held that "when the government seeks to seize the information stored on a computer, as opposed to the computer itself, that underlying 28 Black, Srebnick. Komspan & Stumpf 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 305-371-6421 • Fax 305-358-2006 • www.RoyBlack.com EFTA0171

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

e dates when you are available this month, we can schedule a short meeting in your office hopefully before the year ends. RB/wg Enclosure Black, Srebnick, Komspan & Stumpf, P.A. EFTA00193779 Epstein 1 RRA, et al. Page 2 and others. Rothstein and RRA's fraud had no boundary; Rothstein and his co- c

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 celebri

e been stymied from debunking fraudulent claims brought by the Rothstein criminal enterprise because you have threatened that such action on Black, Srebnick, Komspan & Stumpf. P.A. EFTA00223266 A. Villafafia, Esq. December 9, 2009 Page 3 our part would constitute a breach of the NPA. So the Rothste