Epstein Secrets

rs" within the meaning of Rule 6(e), then it likewise violated grand jury secrecy for government attorneys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters can only be made upon court order. See Fed. R. Crim. P. 6(c)(3)(E). Everything the victims are disc

eys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters

ctionary). But the Government does not disclose that Black's Law Dictionary also clearly defines a "case" as "[a] criminal investigation" as in "the Manson case." BLACK'S LAW DICTIONARY 228 (8th ed. 2004). Accord WEBSTER'S THIRD NEW INTERNATIONAL DICTIONARY 345 (1993) (defining "case" as "a circumstan

o a mere two state prostitution-solicitation charges and agree to an 18-month sentence in the county jail. On September 16, 2007, Epstein's counsel Jay Lefkowitz sent the U.S. Attorney's Office a proposed written agreement, wherein the Office would extend immunity from federal prosecution to Epstein and cer

federal immunity. The co-conspirators did not sign the NPA and were not listed as parties to it. 7 As the NPA was being signed. Epstein's attorney Lefkowitz e-mailed AUSA Villafana, requesting: "Marie— Please do whatever you can to keep this (NPA) from becoming public." AUSA Villafana assured Lefkowitz that

civil or criminal proceeding, action, suit, or controversy at law or in equity <the parties settled the case>" and "[a] criminal investigation <the Manson case>." Case, Black's Law Dictionary 258-59 (10th ed. 2014). As shown in my factual background, everyone involved in Epstein's case— from AUSA Vill

Esq. Company: United States Attorney, Southern District of Florida Company: Fax #: Direct #: Fax #: Direct tt: From: Sandra Musumeci for Jay P. Lefkowitz, P.C. Message: Date: July 29, 2011 Pages Weaver: 4 Fax Direct Please see the attached letter, in response to your letter to Martin Weinberg o

Attorney used similar language in tying the names ', victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. to Mr. Lefkowitz at 2, 3; see aiv your email to Mr. Lcfkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'indi

i0on IDA_ H. Smuggle K Casperde M. Manlarr i e. LOMB Dave Eitype EL gartitursie N. NelUoinogen P. Paraphernalia/ U Uranown C. Cocaine 1A Manson Eoupment paVAAe P Possess T. T o E Use Pera 2 Other A Amphetamine E. Heroin 0. 9;ilurniDerie S i c i g 0.2* Charge DescadeOn Oomeelic

ice, 778 F.2d 668, 669 (I Ith Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege

nd September 9, 2009 Omnibus Order (DE 293); and Manson v. United States, 244 U.S. 362, 365 (1917). More

compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would

'the tlueat of prosecution is real, substantial and present."' See August 4, 2009 Order (DE 242) and September 9, 2009 Omnibus Order (DE 293); and Manson v. United States, 244 U.S. 362, 365 (1917). Moreover, as this court knows, the NPA only defers prosecution in the 6 Case 9:08-cv-80119-KAM Doc

rice, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privileg

and September 9, 2009 Omnibus Order (DE 293); and Manson v. United States, 244 U.S. 362,365 (1917). More

l or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (I Ith Cir. 1985), citing Lefkowitz v. Turley. 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction in favor of the right it was intended to secure," Hoffman v. Un

nto play only in those instances where the witness has "reasonable cause to apprehend danger from a direct answer." Hoffman 341 U.S. at 486 (citing Manson v. United States, 244 U.S. 362,365 (1917)). "The claimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, haza