Epstein Secrets

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- EFTA00177302 Case 9:08-cv-; i-KAM Document 14 Entered on FLSD Docket 07/. )8 Page 4 of 21 had been tried federally and

y Edwards' other client, T.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 Office

tioner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense" 18 U.S.C. § 3553(aX2)(A). The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States I O

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.

.,' 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 ; Ex. S, ¶¶ 6-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her state

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire I. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

.,' 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.

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

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

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

pp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. a 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. FIa. June 25, 2009)). But that is precisely what Petitioners seek here. Accordingl

intentions, partial rescission would pose a significant risk of harm to certain victims, which must be considered in crafting an equitable remedy. The Eleventh Circuit has admonished courts considering equitable remedies to "bear in mind that a poorly crafted remedy may achieve justice for one by working a substan

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

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00086459 Case 9:08-cv-

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

s confidential, and accordingly they should be made part of the Court's public file. In addition, no sealing order could be justified in this case. The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States' O