Epstein Secrets

in light of his clear statements that he represented Jane Doe 2, I could not directly contact or "confer" with Jane Doe 2 without running afoul of the Florida Bar rules. 8. I continued to converse with Mr. Eisenberg about having Jane Doe 2 appear for a voluntary interview, which continuously delayed the inve

ents in September, 2006. Within a few days, I was contacted by attorney James Eisenberg, who informed me that he was representing Jane Doe 2. Mr. Eisenberg also informed me that Jane Doe 2 would not appear before the grand jury or at a consensual interview unless the U.S. Attorney's Office obtained cou

xs. 3 & 4). 5. A subpoena was issued to Jane Doe 2 for testimony and documents in September, 2006. Within a few days, I was contacted by attorney James Eisenberg, who informed me that he was representing Jane Doe 2. Mr. Eisenberg also informed me that Jane Doe 2 would not appear before the grand jury or at

aintiffs. Without attempting to make any connection to the asserted violation of the CVRA, Paragraphs 52 and 53 falsely allege that Movant violated Florida Bar rules and Department of Justice regulations by representing Epstein's employees in civil litigation after Movant retired from the United States Att

the VNS Internet site, you will be prompted to enter your last name (or business name) as currently contained in VNS. The nerne you should enter is Eisenberg. EFTA00229990 %029 Paw 3 of 3 r, /tar 07/09/2006 15:15 FAX 8618059846 UMW WPB COEWIRII case 9;08-cy: 80736-KAM ailment 48-7 Entered on FLSD

4Ag.j1 Ppapgpf 3 • U.S. Department of Justice Federal, &Urea of Investigation FBI - West Palm Beach • January10.200B James Bsonberg RIES Dear James Eisenberg. You have requested to fateNe nottfiCetione for Tahe This case is currenify under Investigation. This can be a lengthy process and we request your

& ASSOCIATES, LLC Attorneys for Plaintiff 2028 Harrison Street - Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: Jay Howell, Esquire Florida Bar JAY HOWEEL SSOCIATES, P.A. Co-Counsel for Plaintiff 644 Cesery Boulevard - Suite 250 Jacksonville, Florida 32211 Telephone: Facsimile: By: Bra

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

in light of his clear statements that he represented Jane Doe 2, I could not directly contact or "confer" with Jane Doe 2 without running afoul of the Florida Bar rules (e.g., R. Regulating Fla. Bar 4-4.2) and 28 U.S.0 § 530B. 9. I continued to converse with Mr. Eisenberg about having Jane Doc 2 appear for a

that he 3 EFTA00799608 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 5 of 176 was representing Jane Doe 2. Mr. Eisenberg also informed me that Jane Doe 2 would not provide testimony or appear for a consensual interview unless the U.S. Attorney's Office obtained court-

06 530 0440 fay P. Issgowitz, ESQ. DaCeectiteitt% 2007 Non 2 0P4 MECUMS Olutica glotta any past or Altura delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago/ sts° asked you to provide our Office wItht

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

l chain titled Things to do in West Palm 11/4/2008 Villafafia Senior Email thanking Villafatia for her 11/3/08 email advising she spoke with the Florida Bar 11/4/2008 Correspondence from Florida Bar Ethics Counsel regarding Florida Ethics Rules involved in distributing victim notification letters 11/1

Menchel with attached letter containing counter- proposal for plea to two years of 'supenised custody.' 9 8/24/2006- 10/24/2006 Entails betweenJim Eisenberg and Marie Villafana regarding #28 10 10/30/2006- 10/31-2006 Emails between Marie Vitt:liana and Guy Lewis regarding Lewis respresentation of Eps

ter, I received a letter from Jeffrey Herman, one of the civil attorneys who represented a number of victims, notifying me that he had complained to the Florida Bar that the Victim Notification Letters violated the Florida Bar rules against solicitation. He had filed complaints against myself and against Robert

contacted Jim Eisenberg, counsel for Individual # 28, who is Jane Doe #2 in the Jane Doe I United States suit. As noted on the attached chart, Mr. Eisenberg was paid for by Mr. Epstein. I told Mr. Eisenberg that I was preparing victim notification letters and needed to know if he was still representing