Text extracted via OCR from the original document. May contain errors from the scanning process.
Cc: Andrew Tomback
, '
Marc,
Received, thanks very much.
Hope you're doing well—
To:
Cc: Andrew Tomback ;
The transcripts are attached. We trust that the US Attorney's Office will keep these confidential other than to the extent
disclosure is required in any pending case.
Regards,
Marc
MarcA.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 received this e-mail by mistake and delete this e-mail from your system. E-mail
transmission cannot be guaranteed to be secure or error-free as information could be intercepted, 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 required please request a hard-copy version.
To:
Cc: Andrew Tomback
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
From:
Cc: Andrew Tomback
EFTA00023699
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
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 it intended only fig the individual named. If you am not the named addressee you should not disseminate. distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you haw: recened this email by mistake and delete this e-mail from your system. 1 nail transmission cannot be guaranteed to be secure or
enor-lice as information could be intereepted, corrupted. lost. destroyed. arose late or incomplete. or contain blIUMIS. The tender therefore does non accept liability for any atom or omissions in
the co nmnts of this message. which arise as a result of e-mail transmission. If verification is requisal please saltiest a hard-copy version.
From:
Cc: Andrew Tomback
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.
EFTA00023700
Best regards,
Marc
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is inkmded only fox the individual named. If yarn 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 e-mail from your system. li.mail transmission cannot be guaranteed to be secure or
Vier -lice ZS information could be intercepted. corrupted lost. destroyed. SIIISe late or incomplete. or contain muses. 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 ventication is required please request a hard-copy version.
From:
Cc: Andrew Tomback
c=
>
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
lawsuit.
Best,
Assistant United States Attorney
Southern District of New York
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 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 haw: received this e-mail by mistake and delete this e-mail from your system. 1 nail transmission cannot be guaranteed to be secure or
crier-lice as information could be intempled. corrupted. lost. trelrleyel.i. arrive late or incomplete. or contain drums. The sender therefore does not accept liability for any errors or omissions in
the contents of Ihn inesmage, which ans.: as a result of e-neul tran.soussion. If verification is required please request a hard-copy version.
On Sep 14, 2020, at 11:56 AM,
wrote:
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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,
EFTA00023701
To:
Cc: Andrew Tomback
M,
we have the transcript of
Regards,
Marc
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
deposition.
This message contains confidential information and is initialed only for the individual named. II you am not the named addressee you should not disseminate. distribute or copy this e-mail.
rime notify the sender immediately by e-mail if you have recessed this entail by mistake and delete this email from your system. t -mail transmission cannot be guaranteed to be secure or
error-I•ree as information could be intern:red, corrupted. lost. destroyed. Mine laic or incomplete, or contain viruses. The sender therefore does not accept liability for any l'1TCH or omissions in
the contents of this message. Much arise as a result of email transmission. If VelliiCJIIO11 is Mildred please request a hard-copy version.
From:
Cc: Andrew Tomback
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 M.
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 LIP
This message contains confidential information and is intended only for the individual named. II)131.1 are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify 11w sender immediately by e-mail a you haw received this email by mistake and delete this e-mail from your system. F.-mail transmission cannot be guaranteed to be secure or
error-free as information could Ey intervepted. corrupted. lost. deuroyoJ. arrive late or incomplete. or contain 'musts. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which uric as a result of ellen! transmission. If ValliCillO11 is required please request a hard-copy version.
From:
Cc: Andrew Tomback
CAUTION: This email was sent by someone outside of the Firm.
EFTA00023702
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
To:
Cc: Andrew Tomback
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
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only fix 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 hare received this e-mail by mistake and delete this email from your system. li-mai l transmission cannot be guaranteed to be secure or
emu-lice St information could be intern:pied. corrupted lost. destroyed. arrive late or incomplete. or contain sirens. The sender therefore does not accept liability for any errors or OTISMIXIS in
the contents of this message, which arise as a result of e.mail transmission. If verification is required please al:quest a hard-copy version.
From:
Cc: Andrew Tomback
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
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 received this e-mail by mistake and delete this email from your system. li-mail transmission cannot be guaranteed to be secure or
EFTA00023703
enor•free as information could be intercepted. corrupted. lost. deitroyed. Mine late or incomplete. or contain 'uses. The sender therefore does not accept liability for any eners or omissions in
the contents of phis message. which arise as a result of c•mml iran.smosion. If venticanon is regurn:d please mnrest a hand-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
EFTA00023704