From:
Brendan White <
[email protected]>
Sent:
Thi
a, June 26, 2008 10:38 AM
To:
,
(USAFLS)
Subject:
Re: Grand Jury Appearance
Dear Ms.
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in
Florida state court on Monday pursuant to a deferred prosecu
ement with your office that has already been
executed. Since this would seem to obviate any need for
to testify, please let me know what is going on with
respect to this Tuesday. Do we still need to come down there an , i so, will she receive court-ordered
immunity? Thanks.
Brendan White
-
Original Messa
From:
(USAFLS)
Dear Mr. White:
.E3.
tit* ji;
L.
Please feel free to make your own travel arrangements, but if you would like Ms.
travel costs to be
reimbursed, they must be made through the government's approved agency on the approved carriers.
Regarding the immunity, at this point, without a written proffer from you regarding t e substance of her
anticipated testimony, I believe that the more prudent course will be to question Ms.
to determine the
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide me
with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to
criminal liability, then I can make the motion ahead of time. Your written statement would be treated as an
attorney statement made in the course of confidential plea discussions and related negotiations, and would be
governed by Fed. R. Crim. P. I I (f) and Fed. R. Evid. 410.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
p
(USAFLS)
Cc:
(USAFLS)
We will be there, and I will make the travel arrangements. I am assuming t
ill be done in connection with an
order of immunity. Please let me know if that is correct so I can advise Ms.
. Thanks.
Brendan White
08-80736-CV-MARRA
P-014991
99
EFTA00189017
— Original Messa e
From:
USAFLS)
White
Cc:
(USAELS)
Dear Mr. White:
Ms.
will need to appear before the grand jury on July 1g to give testimony. Please contact.
assistant,
=
M, at
to make travel arrangements. I expect that Ms.
testimony will begin either in the late morning or early afternoon, but she should be available for the whole
day.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
08-80736-CV-MARRA
P-014992
EFTA00189018
IS •
From:
Sent
To:
Subject
Dear Mr. White:
(USAFLS)
I (USARS) 4
11.
Thursday, June 26, 200810:55 AM
Brendan White
RE: Grand Jury Appearance
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be
withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I
received information confin it
i.at
the plea will be in conformance with our agreement. As such, at this time,
I still intend to present Ms.
testimony to the grand jury on Tuesday. With respect to the immunity
question, I refer you to my e-mail of June 23id, which is shown below.
If the situation changes, I will contact you.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
(USAFIS)
Dear Ms.
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in
Florida state court on Monday pursuant to a deferred prosec
ent with your office that has already been
executed. Since this would seem to obviate any need for Ms.
to testify, please let me know what is going on with
respect to this Tuesday. Do we still need to come down there a
so, will she receive court-ordered
immunity? Thanks.
Brendan White
— Ori inal Mes
e —
From:
Dear Mr. White:
Please feel free to make your own travel arrangements, but if you would like Ms.
travel costs to be
reimbursed, they must be made through the government's approved agency on the approved carriers.
08-80736-CV-MARRA
Ica
P-014993
EFTA00189019
Regarding the immunity, at this point, without a written proffer from you regarding t
ance of her
anticipated testimony, I believe that the more prudent course will be to question Ms.
to determine the
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide me
with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to
criminal liability, then I can make the motion ahead of time. Your written statement would be treated as an
attorney statement made in the course of confidential plea discussions and related negotiations, and would be
governed by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
To:
(USAFLS)
Cc: WUSAFLS)
Subject Re: Grand Jury Appearance
We will be there, and 1 will make the travel arrangements. I am assuming IO
W be done in connection with an
order of immunity. Please let me know if that is correct so I can advise Ms.
. Thanks.
Brendan White
From:
To:
n
de
Cc:
fUSAFLS1
Dear Mr. White:
Ms.
will need to appear before the grand jury on July 1st to give testimony. Please contaliim
assistant,
pi, at
o make travel arrangements. I expect that Ms.
testimony wt
gin either in the late morning or early afternoon, but she should be available for the whole
day.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
08-80736-CV-MARRA
P-014994
102
EFTA00189020
II
08-80736-CV-MARRA
P-014995
103
EFTA00189021
I. (USAFLS)
From:
Sent
To:
Subject:
Thanks.
Brendan White
TtiLla, June 26, 2008 11:26 AM
,
(USAFLS)
Re: Grand July Appearance
-F76:11111a1Mil
Iv,1
Dear Mr. White:
•
t
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be
withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I
received information confirming at the lea will be in conformance with our agreement. As such, at this
time, I still intend to present Ms.
testimony to the grand jury on Tuesday. With respect to the
immunity question, I refer you to my e-mail of June 23rd, which is shown below.
If the situation changes, I will contact you.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
June 26,_2008 10:38 AM
To:
(USAFLS)
Dear Ms.
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in
Florida state court on Monday pursuant to a deferred prosecu •
ment with your office that has already been
executed. Since this would seem to obviate any need for Ms.
to testify, please let me know what is going on
with respect to this Tuesday. Do we still need to come down t ere and, if so, will she receive court-ordered
immunity? Thanks.
Brendan White
— 0 • •
ssa e —
From
08-80736-CV-MARRA
104
P-014996
EFTA00189022
Dear Mr. White:
Please feel free to make your own travel arrangements, but if you would like Ms.
travel costs to be
reimbursed, they must be made through the government's approved agency on the approved carriers.
Regarding the immunity, at this point, without a written proffer from you regarding
substance of her
anticipated testimony,) believe that the more prudent course will be to question Ms.
to determine the
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide
me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to
criminal liability, then I can make the motion ahead of time. Your written statement would be treated as an
attorney statement made in the course of confidential plea discussions and related negotiations, and would be
governed by Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410.
i ssistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
To:
(USAFLS)
Cc: n(USAFLS)
We will be there, and I will make the travel arrangements. I am assuming tbigill
be done in connection with an
order of immunity. Please let me know if that is correct so I can advise Ms.
. Thanks.
Brendan White
-F70:1101
hite
Cc:
(USAFLSI
Dear Mr. White:
Ms.
III, at
to make travel arrangements. I expect that Ms.
testimony will begin either in the late morning or early afternoon, but she should be available for the whole
day.
Thank you.
assistant,
will need to appear before the grand jury on July I a1 to give testimony. Please contact
Assistant U.S. Attorney
08-80736-CV-MARRA
P-014997
los
EFTA00189023
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
08-80736-CV-MARRA
P-014998
106
EFTA00189024
n
il I (USAFLS)
From:
Brendan White •:
e
Sent:
ThLsc if
la, June 26, 2008 3:00 PM
To:
• .
I. (USAFLS)
Subject
Re: Grand Jury Appearance
I've learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning. In understand, of
course, that you need confirmation of this before withdrawing the subpoena, but it might make logistical sense to consider
putting the contingent appearance off for another week at this point, to avoid our having to make an unnecessary trip to
Florida. Although I am confident that things will proceed as scheduled, should there be a problem, we would then be able
to appear at a later date.
Brendan White
Ori inal Mes
From:
Dear Mr. White:
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be
withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I
received information confirming Seta
will be in conformance with our agreement. As such, at this
time, I still intend to present Ms.
testimony to the grand jury on Tuesday. With respect to the
immunity question, I refer you to my e-mail of June 23rd, which is shown below.
If the situation changes, I will contact you.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
(USAFLS)
Dear Ms.
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in
Florida state court on Monday pursuant to a deferred prosecut
ment with your office that has already been
e
executed. Since this would seem to obviate any need for Ms.
to testify, please let me know what is going on
with respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered
immunity? Thanks.
08-80736-CV-MARRA
P-014999
109
EFTA00189025
Brendan White
Ori inal M
From:
'
Sent Monday, June 23, 2008 2:09 PM
Dear Mr. White:
Please feel free to make your own travel arrangements, but if you would like Ms.
travel costs to be
reimbursed, they must be made through the government's approved agency on the approved carriers.
Regarding the immunity, at this point, without a written proffer from you regarding t
ance of her
anticipated testimony, I believe that the more prudent course will be to question Ms.
to determine the
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide
me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to
criminal liability, then I can make the motion ahead of time. Your written statement would be treated as an
attorney statement made in the course of confidential plea discussions and related negotiations, and would be
governed by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
n
o
To:
=I.
(USAFLS)
Cc:
(USAFLS)
We will be there, and I will make the travel arrangements. I am assuming t
ill be done in connection with an
order of immunity. Please let me knoW if that is correct so I can advise Ms.
Thanks.
Brendan White
Ori inal Mes
e
From:
ite
Cc:
.
fUSAFLSI
Dear Mr. White:
Ms.
assistant,
will need to appear before the grand jury on July I g to give testimony. Please contaciiim
M, at
to make travel arrangements. I expect that Ms.
testimony will begin either in the late morning or early afternoon, but she should be available for the whole
day.
Thank you.
08-80736-CV-MARRA
P-015000
EFTA00189026
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
08-80736-CV-MARRA
P-015001
111
EFTA00189027
USAFLS)
From:
■
(USAFLS)
Sent:
Thursday, June 26, 2008 6:41 PM
To:
Brendan White
Subject
RE: Grand Jury Appearance
Dear Mr. White:
I have not received any such confirmation. At this time, we are still on for July
I recommend that you make
your travel plans for Monday afternoon or evening and if things change, I will call you right away.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
June 264.2008 3:00 PM
To:
g (USAFLS)
I've learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning. In understand, of
course, that you need confirmation of this before withdrawing the subpoena, but it might make logistical sense to consider
putting the contingent appearance off for another week at this point, to avoid our having to make an unnecessary trip to
Florida. Although I am confident that things will proceed as scheduled, should there be a problem, we would then be able
to appear at a later date.
Brendan White
— Ori in IM
From:
Dear Mr. White:
CH 11 `11
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be
withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I
received information confirming that the lea will be in conformance with our agreement. As such, at this
time, I still intend to present Ms.
testimony to the grand jury on Tuesday. With respect to the
immunity question, I refer you to my e-mail of June 23s, which is shown below.
if the situation changes, I will contact you.
Thank you.
08-80736-CV-MARRA
P-015002
112
EFTA00189028
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
To:
=1.
(USAFLS)
Sen : Th
m216,2008 10:38 AM
Dear Ms.
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in
Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been
executed. Since this would seem to obviate any need for Ms.
to testify, please let me know what is going on
with respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered
immunity? Thanks.
Brendan White
Frew
ve
Sent Monday, June 23, 2008 2:09 PM
Dear Mr. White:
s
M
Please feel free to make your own travel arrangements, but if you would like Ms.
travel costs to be
reimbursed, they must be made through the government's approved agency on the approved carriers.
Regarding the immunity, at this point, without a written proffer from you regarding the substance of her
anticipated testimony, I believe that the more prudent course will be to question Ms.
to determine the
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide
me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to
criminal liability, then I can make tte motion ahead of time. Your written statement would be treated as an
attorney statement made in the course of confidential plea discussions and related negotiations, and would be
governed by Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Sent Monday June 23 ■2008 1:45 PM
Cc:
(USAFLS)
08-80736-CV-MARRA
P-015003
113
EFTA00189029
We will be there, and I will make the travel arrangements. I am assuming t
will be done in connection with an
.
order of immunity. Please let me know if that is correct so I can advise Ms.
Thanks.
Brendan White
F.roni ;
To:
fl
tp,
Cc:M. NI= (USAFLS)
Dear Mr. White:
Ms.
will need to a car before the
nd jury on July In to give testimony. Please contacti
assistant,
im
M
,
at
to make travel arrangements. I expect that Ms.
testimony will begin either in the late morning or early Afternoon, but she should be available for the whole
day.
Thank you.
U
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
08-80736-CV-MARRA
P-015004
114
EFTA00189030