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would 25 EFTA00799849 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 26 of 32 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010).
.,' 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 he
ners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' 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.
ld 25 EFTA00591486 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 27 of 33 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010).
q.,' 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 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 h
ners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' 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 Is. f
o covers this story. Two Florida Men Charged In Ohio "Grandparent Scam." The Warren (OH) Tribune Chronicle (12/7, 72K) reports from Cleveland, "Two Tampa, Fla. men are charged in a nine-count federal indictment involving the scamming of elderly people throughout the Northern Ohio district." John Tyle
if its hospitals become overwhelmed, though he said the current situation was not dire enough to warrant such a step." According to Politico (12/7, Eisenberg, 4.29M), "The new plan is based on hospitalization rates rather than infection rates and will take a regional approach to reducing Covid-19 cases.
(OH) Tribune Chronicle <https://www.tribtoday.cominews/local-news/2020/12/two-charged-in- grandparent-scam/> (1217, 72K) reports from Cleveland, "Two Tampa, Fla. men are charged in a nine-count federal indictment involving the scamming of elderly people throughout the Northern Ohio district." John Tyler
/www.politico.com/states/new- yorlc/albany/story/2020/12/07/cuomo-outlines-fauci-approved-shutdown-plans-amid-hospitalization-uptick- 1342956> (12/7, Eisenberg, 4.29M), "The new plan is based on hospitalization rates rather than infection rates and will take a regional approach to reducing Covid-19 cases. T
o covers this story. Two Florida Men Charged In Ohio "Grandparent Scam." The Warren (OH) Tribune Chronicle (12/7, 72K) reports from Cleveland, "Two Tampa, Fla. men are charged in a nine-count federal indictment involving the scamming of elderly people throughout the Northern Ohio district." John Tyle
if its hospitals become overwhelmed, though he said the current situation was not dire enough to warrant such a step." According to Politico (12/7, Eisenberg, 4.29M), "The new plan is based on hospitalization rates rather than infection rates and will take a regional approach to reducing Covid-19 cases.
ch delayed what had been a June surrender date." CYBER DIVISION Florida Teen Charged In Twitter Hack Pleads Not Guilty. The AP (8/4) reports from Tampa, Florida, "A Florida teen identified as the mastermind of a scheme that gained control of Twitter accounts of prominent politicians, celebrities and
ic health effort." The Wall Street Journal (8/4, West, Subscription Publication, 7.57M), The Hill (8/4, Wilson, 2.98M), and Politico New York (8/4, Eisenberg) also cover the story. NYTimes Urges Cuomo, De Blasio To Work Together. The New York Times (8/4, 18.61M) editorializes that de Blasio and New York
-West Palm Beach 401 North Dixie Highway West Palm Beach, FL 33401 DEANNA K. SHULLMAN 400 North Ashley Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post Page41 CONFIDENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331804 EFTA_00204530 EFTA02729515 SPE
and jury will not be held up to public ridicule." a at 218-19; see United States v. John Doe Inc. I, 481 U.S. 102, 109 n.5 (1987); United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983); Lance v. United States Dep't of Justice (In re Grand Jury Investigation), 610 F.2d 202, 213 (5th Cir. 1980). A
Entities connected to both Tampa and James Eisenberg

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Joe Biden
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Kenneth Marra
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSON
Scarlett Johansson
PERSONJane Doe
PERSON
Ghislaine Maxwell
PERSON
Michael Jackson
PERSON
John F. Kennedy
PERSON
Prince Andrew
PERSON
Marc Rich
PERSON
Atlanta
LOCATIONFBI
ORGANIZATION
Alan Dershowitz
PERSONMaria Farmer
PERSON