EFTA00019570

From: Alex Conlon To: ' , "Kate L. Doniger" Cc: Roberta Kaplan Subject: RE: Transcript from yesterday's conference Date: Mon, 16 Dec 2019 15:55:47 +0000 Attachments: Epstein_November_21,_2019.pdf Hi Attached please see the transcript from the first appearance in front of Judge Freeman. On page 15 (lines 7-15), Robbie mentions that she has been told that Mark Epstein is the beneficiary of the estate. Thanks, Alex Alex Conlon I Kaplan Hecker & Fink LLP From: Sent: Friday, December 13, 2019 5:53 PM To: Kate L. Doniger Cc: Alex Conlon Roberta Kaplan Subject: RE: Transcript from yesterday's conference Received, thanks. And Alex, if you have the transcript from the prior proceeding before Judge Freeman, I'd be grateful if you could send it, though no rush at all on that — anytime early next week would be totally fine. From: Kate L. Doniger Sent: Friday, December 13, 2019 17:12 To: Cc: Alex Conlon ca Roberta Kaplan Subject: RE: Transcript from yesterday's conference Attached is the draft protocol we received from Feinberg and co. Also attached are two documents the Estate filed in the USVI today. Kate Kate L. Doniger I Kaplan Hecker & Fink LLP 1827 EFTA00019570 From: Roberta Kaplan Sent: Friday, December 13, 2019 4:53 PM To: Cc: Kate L. Doniger <la Subject: RE: Transcript from yesterday's conference >; Alex Conlon That is what Bennet Moskowitz said (I believe) at the earlier conference before M.J. Freeman Alex: can you pls check the transcript? I know they have also said it to me directly and he certainly didn't disagree with me when I said it before J Failla. Also: we got the Feinberg draft protocol today; its exactly as much of a disaster as we expected. Kate: psl send to along with their recent VI filings. Roberta ("Robbie") Kaplan, Esq. Kaplan Hecker & Fink LLP From: Sent: Friday, December 13, 2019 1:09 PM To: Alex Conlon Roberta Kaplan Subject: RE: Transcript from yesterday's conference This is helpful and interesting, thanks very much for sending. Among other things, notable that Judge Failla assumes, even were punitive damages to be excluded, a claim "for millions upon millions of dollars." Separately, Robbie, I noticed near the end of the conference you mentioned, at p. 27, that: "They [the estate and/or the trustees?] have identified the sole beneficiary as Mr. Epstein's brother." I'm wondering if you might have a recollection of what the estate has said or represented to you about that? And if you recall whether any discussion of beneficiaries was in connection with the will versus the trust versus the estate, etc. Just if you feel comfortable sharing any of that information, of course—no obligation at all. And if it's more convenient to relay in real time, rather than drafting up an email, please don't hesitate to give a call. No emergency or rush, but did want to ask. thanks, From: Alex Conlon Sent: Thursday, December 12, 2019 18:34 To: Cc: Roberta Kaplan Subject: Transcript from yesterday's conference Hi there, Attached is the transcript from yesterday's conference that Robbie described in the call today. Take care, Alex Alex Conlon I Kaplan Recker & Fink LIP EFTA00019571 This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client. work product or other applicable legal privilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure. dissemination. distribution, or copying of this communication. or any of its contents. is strictly prohibited. If you have received this communication in error, please notify the sender immediately and destroy all copies of the message from your computer system. Thank you. This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client. work product or other applicable legal privilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure. dissemination. distribution, or copying of this communication. or any of its contents. is strictly prohibited. If you have received this communication in error, please notify the sender immediately and destroy all copies of the message from your computer system. Thank you. This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client. work product or other applicable legal privilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure. dissemination. distribution, or copying of this communication. or any of its contents. is strictly prohibited. If you have received this communication in error. please notify the sender immediately and destroy all copies of the message from your computer system. Thank you. EFTA00019572