Epstein Secrets

led "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28 2007 letter from Kenneth Starr to , and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010

Thru P-009125 12/6/2007 Letter from to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursua

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

to October 24, 2006 N O approval of 18 U.S.C. § 6001 Immunity for TM i sNAbril 24, 2007 TM Interview Transcript N i31 cember 21, 2007 letter from Lefkowitz to Acosta N gust 11, 2006 victim letter to TM gust 11, 2006 victim letter to CW Epstein appeal letters to CEOS • May 15, 2008 letter from Oosterb

led "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28, 2007 letter from Kenneth Starr to Alice S. Fisher; and a November 29, 2007 letter from Jay Lefkowitz to R. Alexande

06 victim letter to CW Epstein appeal letters to CEOS • May 15, 2008 letter from Oosterbaan to Leflcowtiz • June 23, 2008 letter from John Roth to Lefkowitz \limuary 2008 FBI victim letters ' November 28, 2007 letter, Ken Starr to Alice Fisher Nlilecember 11, 2007 letter, Lefkowitz to Acosta Attorney Ge

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

acy to commit an assault on a plane. I just want to make sure that we have something that is factually accurate. Just trying to plan ahead" (id). At Jay Lefkowitz's request, MAUSA Lourie and I scheduled a conference call with him for early on the morning of September 14, 2007 (id. at 25). Mr. Lourie did not att

Villafana letter to Lclkowitz, Black, and Goldberger regarding history of Epstein's performance under the NPA 89 6/17(2009 Villafaila letter to Lelkowitz regarding monitoring future performance under the NPA 90 9/1/2009 Black letter to Montan seeking approval for Epstein to transfer community contr

draft Plea Agreement 9/18/2007 1:37pm draft Information 9/18/2007 Garcia, Villafaiia Lourie Email stating new terms that Louric negotiated with Lefkowitz 9/19/2007 A. Laurie, R. Garcia, K. A. Marie Villafana Email re negotiating strategy with attached correspondence l6 9/19/2007 A. A. Marie Vi

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

cy to commit an assault on I plane. I just want to make sure that we have something that is factually accurate. Just trying to plan ahead" (id.). At Jay Lefkowitz's request, MAUSA and I scheduled conference call with him for early on the morning of September 14, 2007 (id. at 25). Mr. did not attend the confere

After correspondence with Roy Black and I telephone conference with Mr. Black and Jay Leflcowitz, we were advised that USA Acosta had informed Mr. Lefkowitz31 that Epstein could be considered for any Erogram that was available to other prisoners. At that point, I was unable to press forward with I breach,

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

ee, e.g., Ex. L.) In response to Mr. Leflcowitz's ruinous allegations against Jane Doe 2 and myself, on December 13, 2007, I sent a response to Mr. Lefkowitz defending myself and Jane Doe 2. (Ex. 7.) 16. During the course of the suit filed by Jane Doe 1 and Jane Doe 2, the Petitioners have alleged that

LED Docket 06/02/2017 Page 48 of 176 U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: SOO S. Australia

ee Ex. A. I had several oral and written communications with Mr. Eisenberg asking him if Jane Doe 2 would appear under the protection of a standard Kastigar letter, but he told me that Jane Doe 2 would only appear if statutory immunity pursuant to 18 U.S.C. § 6001 was received. For example, in my letter

l or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11 th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege

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

or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11 th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege i

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

al or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citing Lefkowitz v. Turlev 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is

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

's attorneys used my efforts to provide a victim notification to Jane Doe 2 as evidence of that misconduct. (See, e.g., Ex. 13.) In response to Mr. Lefkowitz's ruinous allegations against Jane Doe 2 and myself, on December 13, 2007, I sent a response to Mr. Lefkowitz defending myself and Jane Doe 2. (Ex.

et seq. I had several oral and written communications with Mr. Eisenberg asking him if Jane Doe 2 would appear under the protection of a standard Kastigar letter, but he told me that Jane Doe 2 would 2 EFTA00235272 only appear if 6001 immunity was received. For example, in my letter of January 24,

t of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 15

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