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efta-efta00030439DOJ Data Set 8CorrespondenceEFTA00030439
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From: '
To: "
Cc: Alex Conlon <I
Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
Date: Fri, 13 Dec 2019 22:12:06 +0000
Attachments: Epstein_Proposed_VCP_-_DRAFT_Protocol_-_12.13.2019_-_For_Distribution.pdf;
DS_Response_to_Creditor_Doe's_Motion_for_Extension_of Time.pdf;
DS_Request_forimmediate_Hearing_or_Conference_re._Claims_Program.pdf
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 Ilecker & Fink I,LP
From: Roberta Kaplan
Sent: Friday, December 13, 2019 4:53 PM
To:
Cc:
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 cM
p.; 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
EFTA00030439
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.
C
Take care,
Alex
Alex Conlon I Kaplan Hecker & Fink LLP
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client. work product or other
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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.
EFTA00030440
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