Epstein Secrets

921 F.2d 442, 447 (2d Cir. 1990) ("The government bears the burden of proving that the taint [of an illegal search] has been alleviated.")). Like a Kastigar hearing, "the government bears `the heavy burden of proving that all of the evidence it proposes to use was derived from legitimate independent sou

-AJN Document 234 Filed 04/22/21 Page 1 of 5 HADDON MORGAN FOREMAN April 22, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Haddon, Morgan and Foreman, P.0 Jeffrey S. PagRoca Denver, Colorado 80203 wv.rw.nmnaw.com Re: U

ng our last conversation, you mentioned that Ms. may want to be debriefed rather than appear before the grand jury. In that vein, I have enclosed a Kastigar letter for your review. If we proceed in that fashion and Ms. gives full and complete answers to the questions asked, then we can determine whethe

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: September 14, 2006 DELIVERY BY ELECTRONIC MAIL James L. Ei

s her testimony solely as a witness. During our last conversation regarding Ms. you indicated that she was unwilling to speak with us pursuant to a Kastigar letter. Please confer with her to confirm whether this remains her position. If Ms. is not amenable to an informal meeting, she must still appear

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 January 24, 2007 DELIVERY BY

testimony solely as a victim/witness. During our last conversation regarding El you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with the grand jury and intends to invoke the Fifth Amendment if questioned. Please confer with her

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: January 24, 2007 DELIVERY BY HAND James L. Eisenberg. Esq.

as been subpoenaed solely as a witness. During our last conversation, you stated that M. would be willing to speak with investigators ursuant to a Kastigar letter. Please let me know if that is the case and, if so, when you and M. are available. If is no longer amenable to an informal meetin , he mus

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: January 24, 2007 DELIVERY BY HAND Michael Salnick One Cle

ates seeks her testimony solely as a witness. During our last conversation regarding indicated that she was unwilling to speak with us pursuant to a Kastigar letter. Please confer with her to confirm whether this remains her position. If ib not amenable to an informal meeting, shetnust still appear purs

6 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009236 EFTA00159238 U.S. Department of Justice United States Attorney Southern District of Florida 500 Solahelusiraltan Ave., Sufis 400 West Palm Beach. FL 33401 (561) 820-8711 Facial& (561)820.8777 , January 24,2007 DELIVERY BY HA

bpoenaed solely as a witness. During our last conversation, you stated that Mr. Banasiak would be willing to speak with investigators pursuant to a Kastigar letter. Please let me know if that is the case and, if so, when you and Mr. Banasiak are available. My office would rightly question why I would as

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! Facsimile: February 2, 2007 DELIVERY BY HAND Michael Salnick One Cle

bpoenaed solely as a witness. During our last conversation, you stated that Mr. Banasiak would be willing to speak with investigators pursuant to a Kastigar letter. Please let me know if that is the case and, if so, when you and Mr. Banasiak are available. My office would rightly question why I would as

3 Newspapers $0.00 $60.27 13 2/7/2005 Publix $46.39 Groceries $0.00 $13.88 EFTA00187282 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 • February 2, 2007 DELIVERY