Epstein Secrets

r filed charges against Jeffrey Epstein or any other person involved in criminal activity with Ms.M. 14. In the Jane Doe suit, U.S. District Judge Kenneth A. Marra allowed limited discovery. Exhibits 1 and 2 were listed on a privilege log and provided to Judge Marra in camera for review. The United States asse

Jane Doe suit, U.S. District Judge Kenneth A. Marra allowed limited discovery. Exhibits 1 and 2 were listed on a privilege log and provided to Judge Marra in camera for review. The United States asserted that the items should not be produced because they were governed by Fed. R. Crim. P. 6(e) and incl

2 were listed on a privilege log and provided to Judge Marra in camera for review. The United States asserted

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

Jay Lefkowitz Response to email that Jenny from Judge Marra's office spoke with the Judge and he agreed to t

and Roy Black; cc: Gerald Lefcourt, John McMillan, Karen Atkinson, and Andrew Lourie . Jay Lefkowitz Response to email that Jenny from Judge Marra's office spoke with the Judge and he agreed to take the matter off the calendar. If a plea agreement is reached, USAO will withdraw the subpoena an

ceeding conducted by the Justice Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United States, S.D. Fla. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injusti

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

of the agents and myself the matter was, in fact, "currently under investigation." The NPA was signed on September 24, 2007. The letters that Judge Marra referred to in his order were dated January 10, 2008 and May 30, 2008. During the period that the letters were sent, Epstein was asserting that: (I

as signed on September 24, 2007. The letters that Judge Marra referred to in his order were dated January 10,

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

thing. GOVERNMENT EXHIBIT Case No. 08-80736-CV-MARRA P-000146 EFTA00086499 EISENBERG & FOUTS, P.A.

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

1996); Shell Oil Co., 866 F. Supp. at 540-41. Court-Appointed Receiver of Lancer Mgt. Group LLCI. Lauer, 2009 WL 800144 (S.D. Fl. Mar. 25, 2009) (Marra, J.). Thus, before reaching the relative benefit and prejudice to each of the parties caused by staying the cases, the Court must determine whether

al., 5 Plaintiffs, I JUNE 12, 2009 6 vs. JEFFREY EPSTEIN, Defendant. 9 10 7 8 11 12 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE APPEARANCES: 13 FOR THE PLAINTIFFS: 14 15 16 ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 18205 Biscayne Bou

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

ilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parse in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, UNITED STATES ATTORNEY By: slA. Villa aft Assist

g. ! GOVERNMENT EXHIBIT A Case No. 08-80736-CV-MARRA P-000146 EFTA00185325 U.S. Department of Just

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

')007, at West Palm Beach. Florida. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE cc: William L. Ri

Jury Subpoenas and Cross Motion to Compel is deemed timely filed. DONE AND ORDERED in chambers this day of , ')007, at West Palm Beach. Florida. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE cc: William L. Richey. Esquire Roy Black. Esquire EFTA00178973 (Rev. 06/2005)Sealcd Document Tracking Form Corr

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

UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY

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

THERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Nlatthewman JANE DOE 1 AND JANE DOE 2, Petition

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,

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE 1 AND JANE DOE 2, Petitione

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