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on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S. 1 14. In seeking summary judgment, Jane Doe
No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Ltr. from Eisenberg to AUSA Villafafia; Ex. S, 6-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her statements would
s of subordinate employees in the DOJ were considered judicial admissions, a party's judicial admissions on questions of law have no legal effect.6 Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. Ill. 1999). Plainly, at the time the NPA was negotiated in 2007, the then-current version of
on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S,1 14. In seeking summary judgment, Jane Doe N
No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Is. from Eisenberg to AUSA Villafafia; Ex. S, ¶16-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her statements would
s of subordinate employees in the DOJ were considered judicial admissions, a party's judicial admissions on questions of law have no legal effect.6 Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. Ill. 1999). Plainly, at the time the NPA was negotiated in 2007, the then-current version of
tters in approximately June 2007 [Jane Doe #1] and August 2006 [Jane Doe #2] wherein they were advised of this right and given the phone numbers of AUSA Villafafia, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners
bserved that, "[f]actual admissions can be binding as judicial admissions; admissions of legal conclusions cannot." Id.(citations omitted). See also Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. Ill. 1999)("It is well established that judicial admissions on questions of law have no legal
Entities connected to both AUSA Villafafia and Dabertin

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
A. Marie Villafana
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Alexander Acosta
PERSON
Jay Lefkowitz
PERSONJane Doe
PERSONLeon Black
PERSON
Paul Cassell
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
George W. Bush
PERSONMaria Farmer
PERSON
Dexter Lee
PERSON
Ken Starr
PERSON
Scarlett Johansson
PERSONKuyrkendall
PERSONFISTOS & LEHRMAN
ORGANIZATION