Epstein Secrets

Plea Date & Method of Sending Notification Date & Method of Sending Am. Notification 3 Richard H. Willits, P.A. 2290 10th Avenue North, • Jack Scarola is co-counsel Identified late in investigation. Interviewed by agents and USAO. During interview, I asked victim how she would like case to be re

. Willits, P.A. 2290 10th Avenue North, • Jack Scarola is co-counsel Identified late in investigation.

nd right to attend was prepared. Office would not let me send it out. [NB: Letter was addressed via attorney Jim Eisenberg]. When I contacted Eisenberg to determine whether he was still representing this victim, Epstein's attorneys contacted the Office to complain that I still considered her a

S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley,

VICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail and U.S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbur

(1st Cir. 1989). Only those communications made in the course of an ongoing common enterprise and intended to further the enterprise are protected. Eisenberg v. Gagnon, 766 F.2d 770, 787 (3d Cir.), cert. denied, 474 U.S. 946, 106 S. Ct. 342, 88 L. Ed. 2d 290 (1985); Matter of Bevil!, Bresier & Schulman A

Case 9:08-cv-80736-KAM Document 56 Entered on FLSD Docket 04/07/2011 Page 9 of 19 I and Jane Doe 2. Ile and his own lawyer in a related state case, Jack Scarola, have been widely quoted by local and British press, making prejudicial and inflammatory statements about Mr. Epstein. If the correspondence betwee

nd inflammatory statements about Mr. Epstein. If the correspondence between the defense team and the government is not kept confidential, attorneys Scarola and Edwards could reasonably be expected to continue disseminating out-of-court publicity and making extrajudicial statements and commentary to the

the investigation if the facts arc known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained

ce attached to Villafafia's 12/4/08 email 12/5/2008 Willits Villafaiia Email with attached Work Release Notice B 96 12/8/2008 Spencer Kuvin, Jack Scarola, Michael Dutko, #11, #39 Villafalia Email with attached Work Release Notice p, ir 12/8/2008 Notification of Work Release Letter to Individual

ase Notice B 96 12/8/2008 Spencer Kuvin, Jack Scarola, Michael Dutko, #11, #39 Villafalia Email wit

Menchel with attached letter containing counter- proposal for plea to two years of 'supenised custody.' 9 8/24/2006- 10/24/2006 Entails betweenJim Eisenberg and Marie Villafana regarding #28 10 10/30/2006- 10/31-2006 Emails between Marie Vitt:liana and Guy Lewis regarding Lewis respresentation of Eps

. JOSEFSBERG; KATHERINE W. EZELL; Brad Edwards < >; Cc: Sent: Mon Dec 29 17:16:03 2008 Subject: Jeffrey Epstein Dear Messrs. Josefsberg, Edwards, Scarola, Herman, Kuvin, Dutko, and Willits and Ms. Ezell: Ms. Ezell contacted me to inquire whether Mr. Epstein will be told of the names or addresses of an

Brad Edwards" To: ' XUSAFLS1)" Subject: RE: Jeffrey Epstein Date: Mon, 02 Feb 2009 15:11:20 +0000 Importance: Normal Yes, I requested it from Eisenberg. He wrote back telling me that "since the case is closed, I no longer have the statement. I'm sure you can order another copy. The reporter is Conso