Epstein Secrets

P-003745 EFTA00086415 EISENBERG & FOUTS, P.A. ATTORNEYS AT LAW JAMES L. EISENBERG Suitt 704. Oat Cleartake Centre 250 Australian Avenue So. Wen Palm Beach. FL 33401 BOARD CERTIFIED CRIMINAL TRIAL LAW5'ER 561-659-2009 Fax Case No. 08-80736-CV-MARRA P-003746 EFTA00086416 EISENBERG & FOUTS, P.A. A

ry Material and the Order granting same shall be provided to counsel for the United States. DONE AND ORDERED in chambers this day of May, 2017, at West Palm Beach, Florida. DANIEL T. K. HURLEY SENIOR UNITED STATES DISTRICT JUDGE cc: AUSA EFTA00086376 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLO

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

V-MARRA P-003740 EFTA00086508 U.S. Department of Justice United States Attorney Southern District orlorida SOO South Australian Avo,'Suite400 West Palm Bleach, AL 33401 fracsItnt February 5, 2007 PELIVERY BY HAND James L. Eisenberg, Esq. 250.8 Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 Re

r &Sakai Board Of Trial Advocacy Corilltrd Criminal Trial Advocate KAI LI ALOE POUTS OneClearlako Cenfro,Suito 704, 250 Australian Avenue So u lb, Wesi Palm Beach, FL 3340i Fax: February 12, 2007 Asst. U.S. Attorney 500 South Australian Avenue, Suite 400 West Palm Reach, FL 33401 Re: Dear for As always

me, I can only say that my client does not want to do ei q of your suggestions. She does not want to give a statement under the irnmuni ed with its Kastigar exception and she does not want to test 5'h Amendment grounds. With this client, I am sorry, but I must have a formal grant of m it y f.re she wi

testimony solely as a vie 'm/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 Mftand intends to invoke the Fifth Amendment if questioned. Please confer with her to con

Miami Center Miami, ;bride 33131.4325 *Igeepl.n: :Fa. ziroi e: July 9, 2007 As 3i stant US Attorney S00 South Australian Avenue, Suite 400 WI !st Palm Beach, Florida 33401 RE: Grand Jury Subpoena CASE NO. FGJ 07-103(WPB)/No. OLY-64 5501 SW Sunshine Farms Way Palm City, Florida 34990.5696 Telephona

09:28 PM M RS 30' 90189 P.02 U.S. Department of Justice United States Attorney Southern District of Florida 500 g Australian Ave, Suite 400 Ware Palm Beach, FL 11401.6235 APPEARANCE NOTICE The attached subpoena requires the production of the records specified to a Federal Grand Jury/Trial in the South

re the Grand Jury of the United States District t the place, date and time specified below, United States District Courthouse 701 Clematis Street West Palm Bench, Florida 33401 ROOM: Grand Jury Room DATE AND TIME: March 13, 2007 1:00 pm• YOU ARE ALSO COMMANDED to bring with you the following document(s)

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

yer National Board Of Trial Advocacy Certified Criminal Trial Advocate KM LI ALOE POUTS One Cleariake Centre,Suite 704,250 Australian Avenue Soutb,WestPalm Beach,FL33401 February 12, 2007 Asst. U.S. Attorney 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Re: Grand Jury Subpoena for Dea

red on FLSD Docket 07/15/2008 U.S. Department of Justice United Stales Attorney Southern Distract of Florida SOO South eltatahan Arc., Suite 400 West Palm Ocach FL 33401 acsimtle: August I I, 2006 DELIVERY BY HAND Mis Re: Crime Victims' and Witnesses' RighA Dear Miss I fifirS t r ite- GOVERNIRENT EXH

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

possible public corruption or, at the least] miscarriage of justice. With regard to the logistics of opening the case file, the opening of files in West Palm Beach is relatively informal. In instances where an agent approaches line directly (either because it is duty matter or because the investigation is with

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

& Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: SOO S. Australian Ave, Ste 400 West Palos Beach, FL 33401 December 13, 2007 I am writing not to respond to your asserted "policy concerns" regarding Mr. Epstein's Non- Prosecution Agreement, whic

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

ssible public corruption or, at the least, a miscarriage of justice. With regard to the logistics of opening the case file, the opening of files in West Palm Beach is relatively informal. In instances where an agent approaches a line AUSA directly (either because it is a duty matter or because the investigation

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