From: Robert Lewis <I

From: Robert Lewis <I To: ' " ' Subject: Epstein -- Date: Thu, 25 Jul 2019 18:11:08 +0000 Dear Alexander and Alison: I represent a potential witness in our E stein case. As you will recall, we spoke about back in March, when you reached out to see if would speak to you and we agreed that you could. Although you have not contacted I thought you should know about some recent developments. For the last week or so the New York Times (Mike McIntire) has been aggressively reaching out to- Jesse Rose (his .m I m lawyer) and me (who represented him in the Maxwell case) by email and phone, as well comin to ome twice. He is seeking our comments and information concerning the Dubins an testimony in the Maxwell case. According to McIntire, the Times is planning to run story on th • aL m and their ties to Epstein. It also appears that the Times has a copy of all or a portion of the deposition gave in the Maxwell case, which is troubling because it was subject to confidentiality in that case and, although the Second Circuit has ordered the unsealing of the summary judgment papers (which likely include references to=EM:leposition testimony), no mandate has issued or documents been unsealed. ji= In addition, the Times tells us that a "representative" of the Dubins has told it that "lied" in his deposition. If a representative did that, it is both defamatory and breaches a non isparagement provision in the settlement agreement with The Times also informs that flight documents purportedly do not corroborate certain portions o eposition. We do not have access to those flight documents, but we understand that Epstein's flight documentation is inco t materially inaccurate. Also pursuant to his settlement of his employment dispute with the Dubins estroyed all of the documents he possessed pertaining to the Dubins, which might corroborate some o Is testimony, We have rebuffed the Times' entreaties because of confidentiality obligatiotas pursuant to a settlement agreement in the employment case and the confidentiality order in the Maxwell case, as well as his desire to avoid doing anything that would undermine your criminal prosecution. Should you need or want a copy of deposition transcript in the Maxwell case, we would provide it to you pursuant to subpoena. If you wish to discuss these matters, please do not hesitate to call. Best regards, Bob Lewis ROBERT Y. LEWIS wwwireemanlewis.com EFTA00095361 lithttps://www.lawyers.com/ new-york/new-york/robert- y-lewis-379752-a/? CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential and may be subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law. Any disclosure, distribution, copying, or use of the information contained in this message or any attachment by anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not the intended recipient, please telephone or email the sender and delete this message and any attachment from your system. EFTA00095362