Epstein Secrets

8033 Fax: (954) 924-1530 Attorney for Plaintiffs [Service via CM/ECF] Jay C. Howell Jay Howell & Associates PA 644 Cesery Boulevard Suite 250 Jacksonville , FL 32211 Email: [email protected] PRO HAC VICE [Service via CM/ECF] Paul G. Cassell Email: [email protected] [Service via CM/ECF] EFTA00

would have had, if Mr. Epstein 'The undersigned does not know when Mr. Edwards began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. -3- EFTA00184199 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 4 of 21 had been tried federally an

y Edwards' other client, T.M., was represented by counsel and, accordingly, all contact with T.M. was made through that attorney. That attorney was James Eisenberg, and his fees were paid by Jeffrey Epstein, the target of the investigation.' 5. In the summer of 2007, Mr. Epstein and the U.S. Attorney's Office

that the Motion to Close Trial be denied. DONE AND ORDERED. Fla.Cir.Ct.,1994. John Doc-1 Through John Doe-41. Museum of Sci- ence and History of Jacksonville, Inc. Not Reported in So.2d, 1994 WC. 741009 (Fla.Cir.Ct.), 22 Media L. Rcp. 2497 END OF DOCUMENT Page 7 O 2009 Thomson Reuters/West. No Claim

t with. mai Decl., ¶ 4. Earlier in the investigation. was represented by James Eisenberg, E:sq. Consequently, all contact with. was made through Mr. Eisenberg. In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an effort to resolve the federal investigation. al 5. At that time, Mr.

nvestigation, AUSAIIIIII and the FBI's Victim-Witness Specialist had contact with. mai Decl., ¶ 4. Earlier in the investigation. was represented by James Eisenberg, E:sq. Consequently, all contact with. was made through Mr. Eisenberg. In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an

nth Judicial Circuit 2 Administrative Order no. 2.032-10/06 Of the Fifteenth Judicial Circuit 3 John Doe I. Museum of Science and History of Jacksonville, Case No. 92-32567, 1994 WL 741009 (Fla. 7th Jud. Cir. June 8, 1994) 4 Government's Response to Victim's Emergency Petition for Enforcement of C

the investigation, AUSAInauld the FBI's Victim-Witness Specialist had contact with C.W. ¶ 4. Earlier in the investigation, T.M. was represented by James Eisenberg, E:sq. Consequently, all contact with T.M. was made through Mr. Eisenberg. In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in

ith C.W. ¶ 4. Earlier in the investigation, T.M. was represented by James Eisenberg, E:sq. Consequently, all contact with T.M. was made through Mr. Eisenberg. In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an effort to resolve the federal investigation. a,j 5. At that time, Mr.

, 1332 (1 1 th Cir. 2011); Reahard v. Lee County, 30 F.3d 1412, 1415 (11th Cir. 1994); see also Jacksonville Property Rights Ass'n, Inc. v. City of Jacksonville, 635 F.3d 1266, 1276 (11th Cir. 2011), reh'g & reh'g en banc denied, Case No. 09-15629, 435 F. App'x 914 (11th Cir. Jun. 29, 2011) (Table). I/I I/

p. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09- 80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). Additionally, declaratory judgment is inappropriate to adjud

23, 1332 (11th Cir. 2011); Reahard v. Lee County, 30 F.3d 1412, 1415 (11th Cir. 1994); see also Jacksonville Property Rights Ass'n, Inc. v. City of Jacksonville, 635 F.3d 1266, 1276 (11th Cir. 2011), reh'g & reh'g en banc denied, Case No. 09-15629, 435 F. App's 914 (11th Cir. Jun. 29, 2011) (Table). I/I //

p. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09- 80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). Additionally, declaratory judgment is inappropriate to adjud

, 1332 (1 1 th Cir. 2011); Reahard v. Lee County, 30 F.3d 1412, 1415 (11th Cir. 1994); see also Jacksonville Property Rights Ass'n, Inc. v. City of Jacksonville, 635 F.3d 1266, 1276 (11th Cir. 2011), reh'g & reh'g en banc denied, Case No. 09-15629, 435 F. App'x 914 (11th Cir. Jun. 29, 2011) (Table). I/I I/

p. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09- 80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). Additionally, declaratory judgment is inappropriate to adjud

, 1332 (1 1 th Cir. 2011); Reahard v. Lee County, 30 F.3d 1412, 1415 (11th Cir. 1994); see also Jacksonville Property Rights Ass'n, Inc. v. City of Jacksonville, 635 F.3d 1266, 1276 (11th Cir. 2011), reh'g & reh'g en banc denied, Case No. 09-15629, 435 F. App'x 914 (11th Cir. Jun. 29, 2011) (Table). 111 2i

p. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09- 80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). Additionally, declaratory judgment is inappropriate to adjud

1 U.S. 352, 355 (1983) (holding due process bars unduly vague offense definitions to reduce opportunities for selective enforcement); Papachristou v. Jacksonville, 405 U.S. 156, 162 (1972) (same). 26 See Duncan v. Louisiana, 391 U.S. 145, 156 (1968) (regarding trial by jury as a "safeguard against the corrupt

lack Jacket): A Critique on the Lack of Prosecution of Hunting "Accidents," 56.S.C. L. Rev. 135, 166-73 (2004). © See id.; Duane, supra note 48. 5! Eisenberg, supra note 45, at 893-96 (discussing data from prosecutor interviews). In the contexts Eisenberg describes, prosecutors typically forgo hate-crime o