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From: ' To: Roy BLACK Subject: RE: Jeffrey Epstein Date: Tue, 12 Aug 2008 16:06:41 +0000 Importance: Normal Hi Roy -- Can you give me a call? We need to discuss something. ----Original Message---From: Roy BLACK [ Sent: Monday, August 11, 2008 11:40 PM To: IISAFLS) Subject: Jeffrey Epstein I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9124/07 agreement. We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners. We are particularly concerned because civil lawyers are more apt to publicize something like this than those of us who litigate on the criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his misconceptions of the case. This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were disclosed in the state court. As part of counsels obligation to fully disclose any promises or inducements which led to the plea agreement, the 9/24107 agreement was filed with the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein and his counsel intend to stand by their agreements. If you or anyone in the USAO have any concern about a possible breach please call or email me again so we can discuss any dispute or misunderstanding and allay any concerns. Thanks again. Roy EFTA00211877