Epstein Secrets

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

x: (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] Attorneys for Int

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

x: (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] Attorneys for Int

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

ents. The Court in In re Grand Jury Subpoena, 454 F.3d 511 (6th Cir. 2006), was called upon to "determine who has the right to 36 Black. Srebnick. Kornspan & Stumpf 2015. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 305-371-6421. Fax: 305-358-2006 • www.RoyBlack.com EFTA01713202 conduct a re

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

einberg, PRO HAC VICE, Martin G. Weinberg, P.C., Boston, MA. For Martin G. Weinberg, Jay Lefkowitz, Intervenors: Jacqueline Perczek, 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,

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

available this month, we can schedule a short meeting in your office hopefully before the year ends. Roy Black RB/wg Enclosure Black. Srebnick. Kornspan & Stumpf. P.A. EFTA00014180