Epstein Secrets

on as provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be treated with fairness end with respect for the Adler; dignity and privacy. We wit make our beat efforts to ensure you ere accorded the rights described. Most of these rights pertain to events occurrin

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- EFTA00221657 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 5 of 22 Case 9:08-cv-80736-KAM

Edwards' other client, 'f.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 Offic

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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.

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The critical nature of these documents is vividly demonstrated by Rothstein's testimony during his recent deposition that he had asked Edwards or Adler to specifically set aside a flight manifest for an Epstein private jet. (Tr. Rothstein Depo 12/21/11 at 2278). Rothstein further testified that he

(1st Cir. 1989). Only those communications made in the course of an ongoing common enterprise and intended to further the enterprise are protected. Eisenberg v. Gagnon, 766 F.2d 770, 787 (3d Cir.), cert. denied, 474 U.S. 946, 106 S. Ct. 342, 88 L. Ed. 2d 290 (1985); Matter of Bevil!, Bresier & Schulman A