Text extracted via OCR from the original document. May contain errors from the scanning process.
Cc: Andrew Tomback
, '
rr
I connected with Jack Scarola last week. I just sent him an email to confirm that we can provide you with the
transcript. Once we receive confirmation from him, we will send you the transcript.
Best regards,
Marc
MarcA.Weinstein Partner
t.2 Collar Defense
Hughes Hubbard & Reed LLP
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destroyed. arrive 'ate a• Eneoraale!a. or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message. ...
-lad transmission. If verification is required please request a hard-copy version.
From:
Cc: Andrew Tomback ;
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Hope you're doing well. I wanted to check in on the status of this issue — have you been able to connect with Mr. Scarola?
Thanks,
To:
Cc: Andrew Tomback
<S>
Thanks
. I will give him a call.
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
this message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate. distribute or copy this e-mail.
News: notify the sender immediately by e-mail if you haw received this e-mail by mistake and delete this c.mail from your system. E-mail transmission cannot be guaranteed to be secure or
elan-lice ao infonnation could be intereepted. corrupted. lust. destroyed. arrive late or incomplete, or contain viruses. The tender therefore does not accept liability, for any enure or omissions in
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EFTA00020865
From:
Cc: Andrew Tomback ica
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Thanks for following up on this. If it's okay with you, I think it makes sense to connect you with the plaintiff's attorney,
Jack Scarola, so that he can convey this to you directly. I have spoken with him and explained the context here, and he has
told me that he would be happy to speak with you. He is also seeking a copy of the transcript, as he has informed me that
he no longer has his case files for matters this old. Here is his contact information:
Jack Scarola
Thank you,
To:
Cc: Andrew Tomback
We haven't found a governing protective order, but to be safe, would you be able to get a letter or email from
attorney stating that they are not aware of a protective order/agreement governing the disclosure of the transcript, and
to the extent one existed, they are waiving any provisions in order to permit the Estate to provide the transcript to the US
Attorney's Office, and that they will not claim, in any forum, that the Co-Executors, the Estate, or any representatives of
either, breached any such order/agreement in that case by providing the transcript to the US Attorney's Office.
Let us know if that works on your end.
Best regards,
Marc
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. I lye° are not the named addressee you should not disseminate. distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email from your system. li-mail transmission cannot be guaranteed to be secure or
eiropiree as information could he Int.:to:pied. corrupted. lost. destroyed. SIIISe late or incomplete. or contain VilUSCS. The sender therefore does not accept liability, for any errors or omissions in
the contents of this me says. ‘‘ Inch
as a result of e-mail transim‘ston. If %voile-limn is required pkase nmuest a hard-copy version.
From:
Cc: Andrew Tomback
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Thanks — we have conferred with plaintiff's counsel, who has informed us that he is unaware of any protective order
relating to the
awsuit.
Best,
EFTA00020866
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
To:
Cc: Andrew Tomback
M,
we are still looking to see what confidentiality restrictions might apply. If her lawyer has any such confidentiality or
protective order that governed the case, it might be helpful if you could obtain and share that.
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LIP
This message contains confidential information and is intended only for the individual mimed. If you are not the named addressee you should not disseminate. distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you hal: received this c-Mall by illiSiake and delete this e-mail from your system. 1 nail transmission cannot be guaranteed to be secure or
ems-lice as information could be intennted. corrupted. lost. deitroyed. muse late or incomplete. or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the cut ants of this message. which 311U: as a result oft-mail ifilISITIISSIOCI. If venfication is required please richest a hard-copy version.
On Sep 14, 2020, at 11:56 AM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Thanks very much. Are you able to provide it to us? If there are any issues with providing it to us, or if a call would be
useful to discuss, please let us know.
Thanks,
To:
cas
Cc: Andrew Tomback
M,
we have the transcript of Ms.
Regards,
Marc
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
deposition.
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Please notify the sender immediately by e-mail if you have receised this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-lice as information could be interwpted. corrupted lost. destroyed. Mine late or incomplete, or contain VillIftS. The sender therefore does not accept liability for any errors or omissions in
the contents of this message. which an
as a result of e-mail iran.smusion. If verification is required please request a hard-copy version.
From:
Cc: Andrew Tomback
EFTA00020867
CAUTION: This email was sent by someone outside of the Firm.
Thanks, Marc. We'll look forward to hearing from you, and thanks for your assistance with this.
To:
Cc: Andrew Tomback
>
Thanks
. It wasn't clear to me from the call that it was the plaintiff's deposition that you were after, as opposed to
another witness in the case. Now that it's clear, we will see if we can track it down.
Regards,
Marc
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate. distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have rrvened INS c-Illad by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be SWIM or
CHM-rite as information could be nmena•plcd. corrupted lust. destroyed. Mine law or incomplete. or contain cruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which 311SC as a result of e-mail transmission. If %untie-mon is namind pkase request a hard-copy version.
From:
Cc: Andrew Tomback
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Thanks for speaking earlier. The plaintiff's name is
who is represented by Jack Scarola. The deposition
took place in 2009, and Jeffrey Epstein was represented by Mark Luttier and Bob Critton of Critton, Luttier, and Coleman
LLP in West Palm Beach.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
To:
Cc: Andrew Tomback
MI,
I just realized that you didn't share with us the deponent's name for the transcript you are looking for. Let us know
so that we can make the appropriate inquiries.
Best regards,
Marc
EFTA00020868
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
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Please notify the sender immediately by e-mail if you have receised this e-mail by mistake and delete this e-mail from your system.
transmission cannot be guaranteed to be secure or
error-lice as information could be intercepted. corrupted. lost. destroyed. arrive late or incomplete. or contain vilUSC3. The sender therefore do..-s not accept liability for any errors or omissions in
the contents of this message. which arise as a result of e-nuul transmission. If verification i% ieutiin:d please request a hard-copy version.
From:
Cc: Andrew Tomback
;I
CAUTION: This email was sent by someone outside of the Firm.
That works well, thanks very much. Talk to you then.
To:
Cc: Andrew Tomback
if 11:00 works, I can send a dial-in.
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
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Please notify the sender immediately by e-mail if you have received this equal' by mistake and delete this e-mail from your system. E•mai I transmission cannot be guaranteed to be secure or
error-free as information could be inten:epted, corrupted, lost. destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message. which arise as a result of e-mail transmission. If verification is natuin:d please request a hard-copy version.
On Sep 10, 2020, at 10:46 AM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Andy and Marc,
Are you available for a brief call tomorrow? I'm available before 1 p.m., if there's a time that works for you in that window.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020869