UNITED STATES DISTRICT COURT
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING In accordance with Local Rule 4(b) of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned Roy Black, of Black, Srebnick, Kornspan & Stumpf, P.A., respectfully moves for the admission pro hac vice of attorney Martin Weinberg of Martin G. Weinberg P.C., 20 Park Plaza, Suite 1000, Boston, MA 02116, Telephone: (617) 227-3700, for purposes appearing as counsel on behalf of proposed intervenors in this case. Pursuant to Rule 28 of the CM/ECF Administrative Procedures, undersigned also requests that the Court permit attorney Weinberg to receive electronic filings in this case. In s
Persons Referenced (7)
“...berg, Esq. at [email protected]• DONE AND ORDERED in West Palm Beach, Florida on KENNETH MARRA UNITED STATES DISTRICT JUDGE Copies furnished to all counsel of record EFTA0...”
United States of AmericaUnited StatesJane Doe #1Roy BlackJane Doe #2“...THERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. CERTIFICATION OF MARTIN WEINBERG Pursuant to Rule...”
Martin Weinberg“... & Stumpf, P.A., respectfully moves for the admission pro hac vice of attorney Martin Weinberg of Martin G. Weinberg P.C., 20 Park Plaza, Suite 1000, Boston, MA 02116, Telephone: (617) 227-3700, for...”
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UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true: 1. Between about 2001 and 2006, defendant Jeffrey Epstein (a—billienaire—with—signifteant politieal-eenneetiens)-sexually-abusedinere-than-40 enticed into prostitution minor girls at his mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually sed so enticed were Jane Doe #1 and Jane Doe #2. Because Epstein, through others, used a means of interstate commerce and knowingly traveled in interstate commerce to engage in this conduct, te-abuse-Jane-Dee-#4-en43ane-Dee-#2-(and-the-ether-vietims), he committed violations of federal law, specifically repeated violations of 18 U.S.C. § 2422. 2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Inves
Case 9:08-cv-80736-KAM Document 160 Entered on FLSD Docket 04/17/2012 Page 1 of 13
Case 9:08-cv-80736-KAM Document 160 Entered on FLSD Docket 04/17/2012 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. INTERVENORS' MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE 1 AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF SETTLEMENT NEGOTIATIONS Jane Doe 1 and Jane Doe 2 complain that the government treated them unfairly by not keeping them involved in the government's settlement negotiations with Jeffrey Epstein. They seek to invalidate the Non-Prosecution Agreement between Mr. Epstein and the government, claiming that the agreement violates the Crime Victims's Rights Act. Jane Doe I and Jane Doe 2 seek disclosure of all the letters between the lawyers defending Mr. Epstein and federal prosecutors during the criminal investigation. They claim that the letters are relevant and admissible to show that
CWECF - Live Database - flsd
CWECF - Live Database - flsd Page I of 24 WM U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80736-KAM Internal Use Only Doe . United States of America Assigned to: Judge Kenneth A. Marra Cause: no cause specified Date Filed: 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant Petitioner Jane Doe represented by Bradley James Edwards Fanner Jaffe Weissing Edwards Fistos & Lehrman PL I. Respondent United States of America Fax: 954-524-2822 Email: brad®pathtojustice.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Jay C. Howell Jay Howell & Associates PA Paul G. Cassell En e represented by https://ecf.fisd.circll.den/cgi-bin/DktRpt.p17818316027212123-L_1_0-1 6/27/2013 EFTA00209211 CM/ECF - Live Database - flsd Page 2 of 24 561-820-8711 Fax: 820-8777 LEAD ATTORNEY ATTORNEY TO BE NOTICED Intervenor Roy Black Black, Srebnick, Komspan & Stumpf, P.A. 2
Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23
Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the hearing on August 12, 2011, the Court directed the proposed intervenors to file additional briefing on their argument that plea negotiations are privileged and not subject to discovery or use as evidence in these proceedings. Proposed intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective order and his opposition to the motions of the plaintiffs for production, use,
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-MarratIVIatthewman JANE DOE #1 AND JANE DOE #2, Petitioners, UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING THIRD SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Third Supplemental Privilege Log. The index has been marked with Bates Numbers P-014924 thru P-015267. The documents referenced in the Third Supplemental Privilege Log will be delivered tomorrow to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafafia A. MARIE VILLAFAFIA Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Ave, Suite 40
Nos. 13-12923, 13-12926, 13-12928
Nos. 13-12923, 13-12926, 13-12928 IN THE Einiteb ibtateo Court of appeato FOR THE ELEVENTH CIRCUIT JANE DOE NO. 1 AND JANE DOE NO. 2, 1. UNITED STATES OF AMERICA, ROY BLACK ET AL., Plaintiffs-Appellees Defendant-Appellee Intervenors-Appellants OPPOSITION TO MOTION FOR STAY OF DISTRICT COURT DISCOVERY ORDER PENDING APPEAL AND REQUEST FOR AN EXPEDITED RULING Bradley J. Edwards Paul G. Cassell FARMER, JAFFEE, WEISSING S. J. Quinney College of Law at EDWARDS, FISTOS & LEHRMAN, P.L. the University of Utah Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209507 OPPOSITION TO MOTION FOR STAY OF DISTRICT COURT DISCOVERY ORDER PENDING APPEAL AND REQUEST FOR AN EXPEDITED RULING INTRODUCTION Appellees Jane Doe No. 1 and Jane Doe No. 2 ("the victims") respectfully file this opposition to the motion for a stay pending appeal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referred to as "Epstein"). A
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