Epstein Secrets

he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t

would have had, if Mr. Epstein 'The undersigned does not know when Mr. Edwards began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. -3- EFTA00184768 Calits0:9808AD*360313flICOM DOcurnauenBa31-61EntEradrod 6bSIDIIIDeetl091/02/24/02011E3aTmtef52df 8 had been tr

y Edwards' other client. T.M., was represented by counsel and, accordingly. all contact with T.M. was made through that attorney. That attorney was James Eisenberg. and his fees were paid by Jeffrey Epstein, the target of the investigation! 5. In the summer of 2007. Mr. Epstein and the U.S. Attorney's Office

e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The F131 soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were mi

the VNS Internet site, you will be prompted to enter your last name (or business name) as currently contained in VNS. The nerne you should enter is Eisenberg. EFTA00229990 %029 Paw 3 of 3 r, /tar 07/09/2006 15:15 FAX 8618059846 UMW WPB COEWIRII case 9;08-cy: 80736-KAM ailment 48-7 Entered on FLSD

4Ag.j1 Ppapgpf 3 • U.S. Department of Justice Federal, &Urea of Investigation FBI - West Palm Beach • January10.200B James Bsonberg RIES Dear James Eisenberg. You have requested to fateNe nottfiCetione for Tahe This case is currenify under Investigation. This can be a lengthy process and we request your

e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min

FBI - West Palm Beach State 500 505 South Flintier Drive West Par Beach. FL. 33901 Phone' (501) 833-7517 Fax: (581) 833•7970 .lanualy 10, 2008 James Eisenberg Ons Cieaaake Carter Ste 7C4 Australian South West Pam Beach FL 32901 Re aleallillr Dear James Eisenberg. You have requested to MONS notification

ss the VNS Internet sate, you war be prompted to enter your last name (or business name) as currently contained in VNS. The name you should enter is Eisenberg 08-80736-CV-MARRA 000744 EFTA00230568 07/09/2006 15:15 FAX 8618059846 LIMO IFB COMM %029 case 9;08-cy: 80736-KAM _Moment 48-7 Entered on FLSD

face of Edwards' privilege log, Epstein has no way to determine whether the work product privileges claimed are fact or opinion work product. (See Bates . (Ex. F). It is essential that sufficient information be provided by Edwards to distinguish between fact and opinion work product because Epstein

(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