Epstein Secrets

6/06/2017 Page 26 of 32 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010). In their state court tort actions against Epstein, both petitioners invoked the provisi

on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S. 1 14. In seeking summary judgment, 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 her statements would

/02/2017 Page 27 of 33 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010). In their state court tort actions against Epstein, both petitioners invoked the provisi

on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S,1 14. In seeking summary judgment, Jane Doe N

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 her statements would

telephone. computer or any other facility of interstate commerce, hut rather in a nate-to-face discussion with a third party who was her friend (Ms. Robson) and who told her to lie to Mr. Epstein about her age. As such, it is simply impassible to shoehorn this conduct into any of the above-discussed fe

and federal attorneys or agents. We have no objection to sending the letters through the mail' but we will not remove the language about contacting AUSA Villafafia or Special Agent Kuyrkendall with questions or concerns. Again, federal law requires that victims have the "reasonable right to confer with the att

ng suit. A violation of this provision, by contesting jurisdiction or otherwise, will be considered a material breach. It had been my suggestion to AUSA Villafafia that we simply quote the terms of the Agreement directly into the Notification Letter or include a photocopy of the relevant sections. If you would

States v. St. Amour, 886 F.3d 1009, 1013 (11th Cir. 2018) (quoting United States v. Fisher, 289 F.3d 1329, 1337-38 (11th Cir. 2002)); see also ? Robinson g Shell Oil Co., 519 U.S. 337, 341, 117 S.Ct. 843, 136 L.Ed.2d 808 (1997) ("The plainness or ambiguity of WESTLAW @ 2021 Thomson Reuters. No claim

efkowitz e-mailed AUSA Villafana, requesting: "Marie - Please do whatever you can to keep this [Agreement] from becoming public." (emphasis added). AUSA Villafafia assured Lefkowitz that the Agreement would be kept confidential. 7 For example, in a December 6, 2007 letter, AUSA Villafana informed Lefkowitz tha