Epstein Secrets

rey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 6(e) Box #3 P-012056 Thru P-012088 Affidavit of Roy Black, F-sq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United State

ith handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Ro Black to and m Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upo

investigation, and Ms. likely testimony. Exhibit 1 at P-003732 thru P-003733. 7. On February 5, 2007, I provided Mr. Eisenberg with two proposed Kastigar letters that, again, discuss the grand jury's investigation. Exhibit 1 at P-003739 thru P-003743, P-003745. 8. In response to a complaint from Mr.

timony solely as a victim/winless. During our last conversation regarding Ms. , 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

and had been told that Epstein would not be eligible for work release. Accordingly, I provided my Notice of Breach, but was told by defense attorney Roy Black that, despite those specific conversations, USA Acosta himself agreed that Epstein would be eligible for any program 3 "Unwinding" was USA Acosta's

ire Epstein to elect either the 12/19/07 letter or not, but to make it clear in writing (Exhibits B-73 through B-82). On August 15, 2008, I wrote to Roy Black and Jay Lefkowitz confirming their position that the final agreement consisted only of the NPA and Addendum (Exhibit B-83). By discarding USA Acosta

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

es. Epstein's motion to quash was filed on July 17, 2007 before the close of business. See Gov't Resp. at 1. Riley was informed of these matters by Roy Black, Esquire. and did not appear in reliance on the Government's agreement with Roy Black. I Undersigned counsel has been out of the country and just

in its entirety. Respectfully submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, PA. 201 South Biscayne Boulevard, Suite 1300 Miam 1prida 33131 By ROY BLA K, Florida Bar No. Counsel for Jeffrey Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 17, 2007, a true and correct copy of the forgi

521-23. Interestingly, in that case, the government conceded that "the leaking of privileged materials to investigators would raise the specter of Kastigar-like evidentiary hearings". Id. at 517. This case presents the same specter should Mr. Epstein be indicted. The recognized importance of the attorn

ation of possible compelled disclosure of the Non-Prosecution Agreement B-74 8/6/2008 Email response from Bob Senior to Marie Villafaila regarding Roy Black's response to email B-75 8/12/2008 Email response from Bob Senior to Marie Villafana to request for conference call prior to call with Roy Black

8/2008 Villafaiia Slornan Email response to Villafafia's 10/8/08 email advising to send a copy of pleading to Roy and Jay 10/8/2008 Villafaiia, Roy Black, cc: Atkinson, Lee Lefkowitz Email thanking Villafaiia for fowarding United States' Response to Petitioners' Motion to Unseal the Non-Prosecution

in employees — Janusz Banasiak Both initially asked for immunity. After speaking with Banasiak's attorney, r. anasi was satisfied with a 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

ned between her and Epstein. Miller is represented by Jim Eisenberg, who is being paid by Epstein. Eisenberg has admitted to speaking regularly with Roy Black, who is Epstein's "behind the scenes" attorney, but Eisenberg insists that he is exercising independent judgment on behalf of Miller. Eisenberg has

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

cording to information obtained by the local police, one or more of the women so engaged was under the age of 18 at the relevant time. Affidavit of Roy Black, Esq., sworn to July 17, 2007, annexed ("Black Aft") ¶3. Following a 16 month investigation, on July 17, 2006, Mr. Epstein was charged under Florid

521-23. Interestingly, in that case, the government conceded that "the leaking of privileged materials to investigators would raise the specter of Kastigar-like evidentiary hearings". Id. at 517. This case presents the same specter should Mr. Epstein be indicted. The recognized importance of the attorn

ith handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Ro Black to A. and re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel

imony solely as, a victim/witness. During our last conversation regarding Ms. , 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