Epstein Secrets

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-

15 EFTA00799620 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 17 of 176 1264, 1307 (11th Cir. 2012). Likewise, Federal Rule of Criminal Procedure 6(e) requires confidentiality for persons subject to a grand jury investigation. My recommendations to opposing counsel to limit any ple

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

r, and subject to any other conditions that it directs — of a grand-jury matter: (i) preliminarily to or in connection with a judicial proceeding." Federal Rule of Criminal Procedure 6(e) provides that the traditional rule of grand jury secrecy may be placed aside under certain circumstances to allow for disclosure. S

the investigation if the facts arc 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

ssemination of these letters because they contain information from the grand jury's investigation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstei