Epstein Secrets

1961). Foremost among the prerogatives of sovereignty is the power to create and enforce a criminal code.") (citing Alfred L. Snapp & Son. Inc. v. Puerto Rico ex rel. Barez, 458 U.S. 592, 601 (1982); McCulloch v. Maryland, 4 Wheat. 316, 418, 4 L. Ed. 579 (1819)). 15 EFTA00799839 Case 9:08-cv-80736-KAM

.,' Jane Doe No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Ltr. from Eisenberg to AUSA Villafafia; Ex. S, 6-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured he

ners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' Jane Doe No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Ltr.

1961). Foremost among the prerogatives of sovereignty is the power to create and enforce a criminal code.") (citing Alfred L. Snapp & Son. Inc. v. Puerto Rico ex rel. Barez, 458 U.S. 592, 601 (1982); McCulloch v. Maryland, 4 Wheat. 316, 418, 4 L. Ed. 579 (1819))- 15 EFTA00591476 Case 9:08-cv-80736-KAM D

q.,' Jane Doe No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Is. from Eisenberg to AUSA Villafafia; Ex. S, ¶16-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured h

ners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' Jane Doe No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Is. f

grand jury secrecy. This attorney could neither confirm nor deny the information presented by the `external party.'" Senate of the Commonwealth of Puerto Rico v. United States Dep't of Justice, 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barmy v. United States, 740 F. Supp. 888, 891 (D.D.C. 1990) ("

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained

n grand jury secrecy. This attorney could neither confirm nor deny the information presented by the `external party!" Senate of the Commonwealth of Puerto Rico I United States Dep't of Justice , 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry I United States , 740 F. Supp. 888, 891 (D.D.C. 1990) ("

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States I Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States I Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained

n grand jury secrecy. This attorney could neither confirm nor deny the information presented by the 'external party.' Senate of the Commonwealth of Puerto Rico v. United States Dep ' of Justice , 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry v. United States , 740 F. Supp. 888, 891 (D.D.C. 1990)

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" containe

grand jury secrecy. This attorney could neither confirm nor deny the information presented by the `external party.'" Senate of the Commonwealth of Puerto Rico I United States Dep't of Justice , 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry I United States , 740 F. Supp. 888, 891 (D.D.C. 1990) ("

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States I Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States I Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). EFTA00208547 Several of the "f

n grand jury secrecy. This attorney could neither confirm nor deny the information presented by the `external party.' Senate of the Commonwealth of Puerto Rico v. United States Dep't of Justice , 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry v. United States , 740 F. Supp. 888, 891 (D.D.C. 1990)

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). EFTA00208554 Several of the "

n grand jury secrecy. This attorney could neither confirm nor deny the information presented by the 'external party.' Senate of the Commonwealth of Puerto Rico I United States Dep't of Justice , 1992 WI- 119127 at *3 (D.D.C. May 13, 1992) (citing Bany I United States , 740 F. Supp. 888, 891 (D.D.C. 1990) ("

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States I Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States I Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained

n grand jury secrecy. This attorney could neither confirm nor deny the information presented by the 'external party.' Senate of the Commonwealth of Puerto Rico I United States Dep ' of Justice , 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry I United States , 740 F. Supp. 888, 891 (D.D.C. 1990) ("

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States I Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States I Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained

to enjoin prosecutors to conduct their investigation in a particular manner, we can only assume it would have expressed itself more clearly. See, Puerto Rico v. Franklin Cat Tax-Free Trust, — U.S. —, 136 S. Ct. 1938, 1947, 195 L.Ed.2d 298 (2016) ("Congress 'does not, one might say, hide elephants in mou

stigative and prosecutorial arm of the executive branch of government." (quotation marks omitted)). Further, as we explained in ?a United States v. Eisenberg, "[u]ntil an indictment is returned and a case presented to the United States District Court, the responsibility for the functioning of the grand