Epstein Secrets

6/30/08 BSI 6/27/2008 AUSA Villafafia notifies Attorney Edwards of upcoming change of plea and urges his clients

#33, #37 (via Michael E. Dutko), #38, #44 biaJeffni Herman) 8-90 9/W2008 Victim notification letters to #36, #35 (via Brad Edwards), #42, #43 (via Brad Edwards) B-9I 9/12/2008 Notification of Identified Victim letter #39 B-92 9/15/2008 Mailed victim notification letters for #I8 and #32 15-93 9/17/2008-

77 6/27/2008 Counsel for Epstein advise USAO of Epstein state court change of plea on 6/30/08 BSI 6/27/2008 AUSA Villafafia notifies Attorney Edwards of upcoming change of plea and urges his clients to attend 6/27/2008 USAO notifies Palm Beach Police Chief Reiter of upcoming change of plea. He

9 Villafafia Roy Black Letter in response to 11/02/09 letter re Epstein's place of employment with attached Complaint against Scott Rothstein and Bradley J. Edwards 1/4/2010 Villafafia Spencer Kuvin Letter re computer seized by FBI 1/20/2010 Villafalia Roy Black Letter re attorney's fees 1/21/2010 Villaf

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

have counsel state their appearances? MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. : Good morning, Your Honor. Sid for Jane Doe II. THE COURT: Good

sel state their appearances? MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. : Good morning, Your Honor. Sid for Jane Doe II. THE COURT: Good morning. MR.

ard Miami, FL 33160 305.931.2200 For Jane Doe BRADLEY J. EDWARDS, ESQ. 17 Rothstein Rosenfeldt Adler 401 East Las Ola

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

United States litigation, asserting that his clients wanted to 4 1 few days after Jeffrey Epstein entered his guilty plea in state court, attorney Brad Edwards filed suit on behalf of one of the victims identified in the federal investigation (later expanded to include I second victim who had been identifie

ng aside the NPA would not benefit his clients, and he sued Epstein on behalf of I number of victims under the NPA. I did what I could to assist Mr. Edwards, other attorneys, including Mr. Josefsberg, the attorney selected by the Special Master, and the Court, to locate victims, provide signed copies of

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

to paragraph 29 of DE361, copies of emails sent to and from my personal email address were produced in discovery. Pursuant to my agreement with Mr. Edwards (counsel for Petitioners), personal email addresses were redacted. Some of those emails are included in the exhibits attached to Petitioners' motio

6/02/2017 Page 21 of 176 37. In mid-June 2008, Attorney Edwards contacted your Affiant to inform me that he repr

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

ten and adopted to guarantee Americans greater freedom than had been enjoyed by their ancestors who had been driven from Europe by per- secution." Edwards, 430 A.2d at 13 (Mack, J., dissenting) (quoting Carlson i Landon, 342 U.S. 524, 556, 72 S.Ct. 52 , 542, 96 L.Ed. 547reh. denied,343 U.S. 988, 72

alto Shapiro United States, 335 U.S. 1, 19, 68 S.Ct. 6, 1385, 92 L.Ed. 1787 (1948) (following rule of construction of Mike). More recently, in Kastigar, the Court up- held the constitutionality of 18 U.S.C. 6002 on the ground that use immunity "is coextensive with the scope of the privi- lege again

certain charges pending in Alabama. Be cause it disputed the very existence of a grant of immunity, the government object- ed to the holding of a Kastigar hearing as unwarranted. Faced with this disputed claim of an un- written grant of immunity, the magistrate did not hold a traditional Kastigar hea

er counsel on the phone for permitting us to appear 19 by phone. 20 THE COURT: All right. Anyone else have anything they 21 want to add? 22 MR. EDWARDS: Brad Edwards on behalf of Jane Doe. 23 I only had one issue here, and when I read your motion 24 that you wanted to hear on the narrow issue of j

l on the phone for permitting us to appear 19 by phone. 20 THE COURT: All right. Anyone else have anything they 21 want to add? 22 MR. EDWARDS: Brad Edwards on behalf of Jane Doe. 23 I only had one issue here, and when I read your motion 24 that you wanted to hear on the narrow issue of just defense in

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

onstitutional basis for precluding trial of criminal case by injunction. Melvin L. Klafter, Leonard R. Harten- feld, Chicago, Ill., for appellant. Edward,. Hanrahan, U. S. Atty., John Peter Lulinski, Thomas W. James, Asst. U. S. Attys., Chicago, Ill., William W. Goodrich, Asst. Gen. Counsel, Joanne

itness' invocation of the Fifth Amendment, the Supreme Court has held that the scope of the immu- nity granted must be as broad as the privi- lege. Kastigar, 406 U.S. at 460, 92 S.Ct. at 1859. Due to the cumbersome requirements of obtaining properly authorized statutory im- munity, U.S. Attorneys often