Epstein Secrets

KENT MD,SEBASTIAN PORRECA,VANESSA WRIGHT,SUZANNE FURLO,PAUL W TOWN OF PALM B

G PALM BEACH LLC KEITEL,FREDERICK J EISENBERG,KENNETH MCCARTHY,JOSEPH W PHIPPS ES

l under federal law remain confidential when filed under seal in a state criminal proceeding. See Buenoano, 707 So. 2d at 717-18; see also State v. Wright, 803 So. 2d 793, 795 (Fla. 4th DCA 2001). The non-prosecution agreement and addendum is confidential under federal 3 The Court in Buenoano constru

and jury will not be held up to public ridicule." a at 218-19; see United States v. John Doe Inc. I, 481 U.S. 102, 109 n.5 (1987); United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983); Lance v. United States Dep't of Justice (In re Grand Jury Investigation), 610 F.2d 202, 213 (5th Cir. 1980). A

gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio

rvice of the subpoena, Ms.= retained the services of James Eisenberg, Esq. to represent her. Jeffrey Epstein paid for that representation. 3. Mr. Eisenberg communicated to me orally and in writing that Ms. would assert her Fifth Amendment privilege if she were forced to appear before the grand jury, an

stitutionality or even impropriety. Incendy at 956 (citing United States' Kordel, 397 U.S. I, 11 (1970)). See also Securities and Exchange Comm'nl. Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o 'special circumstances' existed in this case warranting a stay, as there is no record evidence sug

outhern District of Florida DELIVERY BY HAND James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 Re: Dear Mr. Eisenberg: 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: February 5, 2007 I am writing to clarify the ground rules for the int