EFTA00808426Set 9
2018-10-2610p2,816w
ROTHSTEIN ROSENFELDT ADLER, M., CHAPTER 11
Debtor.
JEFFREY EPSTEIN'S REPLY TO THE INTERVENORS' RESPONSE TO EPSTEIN'S
MOTION TO TAKE THE INTERVENORS' DEPOSITIONS
AND TO COMPEL THEIR MENTAL EXAMINATIONS ... Jeffrey Epstein ("Epstein") replies to the Intervenors, IM and Jane Doe's
Response (D.E. 6446) to Epstein's Motion to Take the Intervenors' Depositions and to Compel
their Mental Examinations ... Epstein's "Motion") (D.E. 6440), and states:
INTRODUCTION
Inexplicably, the Intervenors' counsel insists on making the Intervenors relive (and attempt
to re-litigate) their settled sexual abuse claims against Jeffrey
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808426.pdf
EFTA01072032Set 9
2013-07-1242p9,971w
Common Law Privilege Under Rule 501 12
III. THE SEVERE AND IRREMEDIABLE PREJUDICE TO
INTERVENORS FROM DISCLOSURE OF THE
COMMUNICATIONS 15
IV. THE ABSENCE OF PREJUDICE TO THE PLAINTIFFS ... June 18, 2013 (Doc. 188), Exhibit A
hereto, ordering disclosure to plaintiffs of the intervenor attorneys' written
communications with federal prosecutors in the Southern District of Florida made
with ... Those factors are amply satisfied
in this case: there is a strong likelihood that intervenors will prevail on appeal (or at
a minimum, they have a "substantial case
https://www.justice.gov/epstein/files/DataSet%209/EFTA01072032.pdf
EFTA01180323Set 9
2014-04-2446p10,094w
Appellees,
v.
UNITED STATES OF AMERICA,
Defendant,
ROY BLACK, MARTIN G. WEINBERG,
& JEFFREY EPSTEIN,
Intervenors-Appellants.
TIME SENSITIVE MOTION FOR A STAY PENDING A
RULING ON INTERVENORS' PETITION FOR REHEARING ... TABLE OF AUTHORITIES ii
TIME SENSITIVE MOTION FOR A STAY PENDING A
RULING ON INTERVENORS' PETITION FOR REHEARING 1
Memorandum 2
I. Introduction 2
II. Background 4
III. Argument ... Sensitive Stays 6
B. The Likelihood Of Success On The Merits 7
C. The Intervenors Will Suffer Irreparable Injury
If A Stay Is Denied 18
D. Continuing the Stay Will
https://www.justice.gov/epstein/files/DataSet%209/EFTA01180323.pdf
EFTA00209806Set 9
2014-04-1816p7,014w
Appellees,
1.
UNITED STATES of America, Defendant.
Roy Black, Martin G. Weinberg, Jeffrey Epstein, Intervenors-Appellants.
No. 13-12923.
April 18, 2014.
Background: Alleged minor victims of federal sex crimes ... from disclosure by federal rule of evid-
ence barring admission of plea negotiations;
(3) intervenors waived work-product privilege; and
(4) plea negotiations were not protected from disclosure ... Preliminary proceedings; depositions and discov-
ery. Most Cited Cases
The Perlman doctrine allows an intervenor to file an interlocutory appeal of
an order denying a motion to quash a grand
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209806.pdf
EFTA00584603Set 9
2008-07-1121p5,110w
INTRODUCTION AND FACTUAL BACKGROUND
Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement
("NPA") with the government in September, 2007. Under that agreement, contrary
to the impression which the plaintiffs ... statute are those
of the government alone. Because neither Mr. Epstein nor intervenor-attorneys are
parties to the action, this Court, for the reasons addressed herein, has jurisdiction to
hear ... government also filed a response, in which it agreed with intervenors that
the correspondence was protected by the work product privilege. Doc. 100.
The district court granted the motions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584603.pdf
EFTA00209426Set 9
2014-04-1824p5,737w
Appellees,
versus
UNITED STATES OF AMERICA,
Defendant,
ROY BLACK,
MARTIN G. WEINBERG,
JEFFREY EPSTEIN,
Intervenors-Appellants.
Appeals from the United States District Court
for the Southern District of Florida
(April ... ordered the United States to
disclose the correspondence to the victims. After the intervenors filed this appeal,
the victims moved to dismiss it for lack of jurisdiction. Because we conclude ... district court
granted their permissive intervention, Fed. R. Civ. P. 24(b), the intervenors moved
for protective orders. The intervenors argued that the work-product privilege
5
EFTA00209430
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209426.pdf
EFTA00209632Set 9
2014-04-1824p5,766w
Appellees,
versus
UNITED STATES OF AMERICA,
Defendant,
ROY BLACK,
MARTIN G. WEINBERG,
JEFFREY EPSTEIN,
Intervenors-Appellants.
Appeals from the United States District Court
for the Southern District of Florida
(April ... ordered the United States to
disclose the correspondence to the victims. After the intervenors filed this appeal,
the victims moved to dismiss it for lack of jurisdiction. Because we conclude ... district court
granted their permissive intervention, Fed. R. Civ. P. 24(b), the intervenors moved
for protective orders. The intervenors argued that the work-product privilege
5
EFTA00209636
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209632.pdf
EFTA01197325Set 9
2014-04-1824p5,755w
Appellees,
versus
UNITED STATES OF AMERICA,
Defendant,
ROY BLACK,
MARTIN G. WEINBERG,
JEFFREY EPSTEIN,
Intervenors-Appellants.
Appeals from the United States District Court
for the Southern District of Florida
(April ... ordered the United States to
disclose the correspondence to the victims. After the intervenors filed this appeal,
the victims moved to dismiss it for lack of jurisdiction. Because we conclude ... district court
granted their permissive intervention, Fed. R. Civ. P. 24(b), the intervenors moved
for protective orders. The intervenors argued that the work-product privilege
5
EFTA01197329
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA01197325.pdf
EFTA00209741Set 9
2014-04-1823p5,318w
Appellees,
versus
UNITED STATES OF AMERICA,
Defendant,
ROY BLACK,
MARTIN G. WEINBERG,
JEFFREY EPSTEIN,
Intervenors-Appellants.
Appeals from the United States District Court
for the Southern District of Florida
(April ... ordered the United States to
disclose the correspondence to the victims. After the intervenors filed this appeal,
the victims moved to dismiss it for lack of jurisdiction. Because we conclude ... district court
granted their permissive intervention, Fed. R. Civ. P. 24(b), the intervenors moved
for protective orders. The intervenors argued that the work-product privilege
5
EFTA00209745
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209741.pdf
EFTA00209385Set 9
2014-04-1824p5,738w
Appellees,
versus
UNITED STATES OF AMERICA,
Defendant,
ROY BLACK,
MARTIN G. WEINBERG,
JEFFREY EPSTEIN,
Intervenors-Appellants.
Appeals from the United States District Court
for the Southern District of Florida
(April ... ordered the United States to
disclose the correspondence to the victims. After the intervenors filed this appeal,
the victims moved to dismiss it for lack of jurisdiction. Because we conclude ... district court
granted their permissive intervention, Fed. R. Civ. P. 24(b), the intervenors moved
for protective orders. The intervenors argued that the work-product privilege
5
EFTA00209389
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209385.pdf
EFTA00583760Set 9
2008-07-1120p5,068w
INTRODUCTION AND FACTUAL BACKGROUND
Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement
("NPA") with the government in September, 2007. Under that agreement, contrary
to the impression which the plaintiffs ... statute are those
of the government alone. Because neither Mr. Epstein nor intervenor-attorneys are
parties to the action, this Court, for the reasons addressed herein, has jurisdiction to
hear ... government also filed a response, in which it agreed with intervenors that
the correspondence was protected by the work product privilege. Doc. 100.
The district court granted the motions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583760.pdf
EFTA00583454Set 9
13p3,972w
JANE DOE I AND JANE DOE 2,
Plaintiffs
v.
UNITED STATES OF AMERICA,
Defendant
INTERVENORS' REPLY TO JANE DOE #1 AND JANE DOES #2'S RESPONSE IN
OPPOSITION TO INTERVENORS ... MOTION TO STAY
Intervenors' Motion for Stay Pending Appeal should be granted. Contrary to plaintiffs'
contentions, the Eleventh Circuit will have jurisdiction over their appeal from the Court's
disclosure ... amply satisfied in this
case.
I. THE ELEVENTH CIRCUIT WILL HAVE JURISDICTION OVER THE
INTERVENORS' APPEAL UNDER THE PERLMAN DOCTRINE.
A. Mohawk Does Not Affect the Operation of the Perlman
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583454.pdf
EFTA00800218Set 9
2019-02-2535p19,674w
Street
Fax: 510-7119
Email:
LEAD A7 fORNLY
ATTORNEY TO BE NOTICED
Intervenor
Roy Black represented by Jacqueline Perczek
Black, Srebnick, Kornspan & Stumpf, P.A. Black Srebnick Kornspan & Stumpf
201 South ... Biscayne Boulevard
Suite 1300
1
ax: 1:50.113T.
Email:
ATTORNEY TO BE NOTICED
Intervenor
Martin G. Weinberg represented by Jacqueline Perczek
(See above for address)
ATTORNEY TO BE NOTICED ... Martin G. Weinberg
(See above for address)
PRO HAC VICE
ATTORNEY TO BE NOTICED
Intervenor
Jay Lefkowitz represented by Jacqueline Perczek
(See above for address)
ATTORNEY TO BE NOTICED
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800218.pdf