Epstein Secrets

ing frames or wall frames. Request No. 14. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 15. Any and all docume

, or (3) when the patient raises and relies on the issue of his or her mental condition in litigation as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.2d 901, 903 (Fla. 3d DCA 2002). The privilege does not allow the invasion of a patient's privileged

the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administra

ing frames or wall frames. Request No. 14. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 15. Any and all docume

, or (3) when the patient raises and relies on the issue of his or her mental condition in litigation as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.2d 901, 903 (Fla. 3d DCA 2002). The privilege does not allow the invasion of a patient's privileged

the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administra

sing the State Attorney's Office to arrest Epstein. Det. had prepared series of probable cause affidavits for the arrests of Jeffrey Epstein, and Haley Robson, charging I large number of state criminal violations. Chief had asked the Palm Beach County State Attorney, Barry to authorize the arrests and h

ts for the arrests of Jeffrey Epstein, and Haley Robson, charging I large number of state criminal viola

nusz Banasiak and Mucinska. Both initially asked for immunity. After speaking with Banasiak's attorney, Mr. Banasiak was satisfied with I standard Kastigar letter, but Ms. Mucinska's attorney was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, prior to thi

for the attached Requests for Authorization to Apply for a Compulsion Order seeking Immunity pursuant to 18 U.S.C. Sections 6001- 6003 for witnesses Haley Robson and Tatum Miller in connection with the ongoing investigation named "Operation Leap Year." II. BACKGROUND Operation Leap Year involves the invest

would arrange "sexual massages" for Epstein when he would travel to Palm Beach, and many of those "sexual massages" were performed by minor females. Robson and Miller both began their relationships with Epstein as "masseuses" when they were under the age of 18.1 After performing massages for a period o

ividuals. They are, however, similarly situated, so I have joined both requests for immunity in this memorandum. -1- EFTA00190247 proffer with a "Kastigar letter" or testifying before the grand jury with a "pocket immunity" letter. Both witnesses are represented by counsel. Miller is an openly hostile