ri ay, eptember 6, 20082:05M

From: Sent: ri ay, eptember 6, 20082:05M To: bertpattonepodhurst.com; MERCEDES C. ESTRADA Subject: Civil Cases Involving Jeffrey Epstein Hi all — I just received Bert's voicemail message. 1 do not know all of the case numbers of cases involving Jeffrey Epstein. If you go to the District Court's PACER site, and search for the party name of Jeffrey Epstein, they will all come up. The press also has reported that some cases were recently filed in Palm Beach County state court. You can do a similar search on the Clerk of Court's website to find all of the state court cases. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 22 08-80736-CV_MARRA 002111 EFTA00227225 From: Jay Lefkowitz pLefkowitz@kirldand corn] Sent: r 08, 2008 2:40 PM To: Cc: Subject: e: ane aoes e• tates Thank you for sending this. Jay From: Sent: 10/08/2008 02:37 PM AST To: <RBlackt Ro Blaelc.com>• Jay Letkowitz Cc: Subject: Jane Does United States Dear Roy and Jay: I am attaching the United States' Response to the Petitioners' Motion to Unseal the Non-Prosecution Agreement, which was filed in the victims' rights suit filed against the United States by Attorney Brad Edwards on behalf of two of the victims. In his motion to unseal, Attorney Edwards stated that he would provide notice of his motion to counsel for Mr. Epstein. I do not know if he actually did so. In our response, we oppose the Petitioners' motion, and point out that Mr. Edwards has filed a civil suit against Mr. Epstein and that litigation regarding the Non-Prosecution Agreement is more appropriate in that forum where the real party in interest (Mr. Epstein) is a party to the suit. «DE29_081008_Resp to Motel Unseal.pdf>> Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this 6 08-80736-CV_MARRA 002112 EFTA00227226 communication in error, please notify us immediately by return e-mail or by e-mail to postmastergkirkland.com, and destroy this communication and all copies thereof, including all attachments. 7 08-80736-CV_MARRA 002113 EFTA00227227 From: Sent: To: Cc: Subject: Dear Roy and Jay: Wednesday, October 08. 2008 2 38 PM I am attaching the United States' Response to the Petitioners' Motion to Unseal the Non-Prosecution Agreement, which was filed in the victims' rights suit filed against the United States by Attorney Brad Edwards on behalf of two of the victims. In his motion to unseal, Attorney Edwards stated that he would provide notice of his motion to counsel for Mr. Epstein. I do not know if he actually did so. In our response, we oppose the Petitioners' motion, and point out that Mr. Edwards has filed a civil suit against Mr. Epstein and that litigation regarding the Non-Prosecution Agreement is more appropriate in that forum where the real party in interest (Mr. Epstein) is a party to the suit. DE29 _081008_R p to Mom Unsea Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 Tracking: 8 08-80736-CV_MARRA 002114 EFTA00227228 From: Sent: To: Subject: Lilly Sanchez [LAS@FOWLER-WHITE.COMJ I hope that the two weeks you will be out of the district is for a well-deserved vacation. I have been so busy lately that I am also looking forward to taking some time off closer to the end of the year. I am planning to be out of the office the weeks of Dec. 18 and Dec. 25 to spend much quality time with my son who is now 8 years old and growing up too fast. Since it looks like we will miss each other before the New Year, I will be in touch at that time and hopefully we will be able to meet shortly thereafter. In the interim, I will check on the document requests you made and get back to you. Regards. Lilly III Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 lsanchez0fowler-white.com >>> ' c > 11/17/2006 9:22 AM >>> Hi Lilly -- This is the correct e-mail address. I hope that you received the letter that I faxed yesterday. I will be out of the office today, but I will be back on Monday. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, Florida Phone 561 209-1047 Fax 561 820-8777 243 08-80736-CV MARRA 002115 EFTA00227229 From: Sent: To: Subject: fyi FW: Jeffrey Epstein From il Sent: Tuesday, May 22, 2007 6:32 PM To: 'Gerald Lefcourt' Subject: RE: Jeffrey Epstein have your letter. I think we are on the same page, but to be sure I do want to clarify that we spoke the other week and I did say that if you want to meet with me again, I am ready to do so. The wording of your letter, however, suggests implicitly that I agreed to contact you before a decision is made to seek an indictment of Mr. Epstein. If that was your understanding, then please allow me to clarify. Our investigation is ongoing and if we decide to seek an indictment, we don't intend to call Mr. Epstein's representatives to let him know that. Of course, in the interim, if you would like to make a presentation to us, we are willing to listen. Along those lines, iven the fact that we have already met once, with schedules being what they are, it makes sense for our criminal chief, to be included when you make another presentation, rather than working up the chain incrementally. I realize you were being respectful in not attempting to leapfrog over me, which I appreciate. I will pass on your request to meet with the U.S. Attorney as well, but can't commit for him one way or another. When you have some dates in mind, let me know and I will try to set up a meeting in Miami. From: Gerald Lefcourt [mailto:GBL@Iercourtlaw.com] Sent: Tuesday, May 22 2007 2:05 PM To: Cc: ; Ully ■ Sanchez Subject: Jeffrey Epstein MI. attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your attention. Could you email back so that I know you have received this letter? Gerald B. Lefcourt Gerald B. Lefcoun, P.C. 148 E. 78th Street New York New York 10021 Tel Fax obialefcourtlaw corn 152 08-80736-CV MARRA 002116 EFTA00227230 From: Sent: Mon February 12. 2007 3A3 PM To: Lilly MI Sanchez Subject: RE Epstein Matter Thank you, Lilly. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 From: Lilly Ann Sanchez [mailto:LAS@FOWLER-WHITE.COM] Sent: Monday Februa 12, 2007 1:45 PM Subject: Re: Epstein Matter i received your email. i will speak to gerry and get back to you shortly on both items. hope you are well. regards Lilly Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 BrIckell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 Isanchez(throwler-white.cona Hi Lilly — Please let Gerry know that I took his comments to heart and I am re-reviewing all of the tapes. I noticed that he had transcripts of at least some of the tapes. Any chance you would be willing to share those with me? It would make the review oh so much quicker. And, could you send me the list of the lawyers who represent current or former employees? Before you ask, Rule 6(e) requires that I keep mattcrs before the grand jury secret, so I cannot tell you who or what 1 am subpoenaing. lithe subpoenaed party (or his/her attorney) decides to disclose that information to you, that is his/her prerogative, but 1 can't do it. Thank you very much. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 227 08-80736-CV_MARRA 002117 EFTA00227231 West Palm Beach, Ft 33401 561 820-8711 Fax 561 820-8777 **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 228 08-80736-CV_MARRA 002118 EFTA00227232 From: Sent: To: Subject: IMF I received your email. I will speak to gerry and get back to you shortly on both items. hope you are well. regards Lilly Ann Sanchez [LAS@FOWLER-WHITE COMI 213W1:45 PM Re: Epstein Matter Ully Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 isanchez@fowler-white.com Iii Lilly -- Please let Gerry know that I took his comments to heart and 1 am re-reviewing all of the tapes. I noticed that he had transcripts of at least some of the tapes. Any chance you would be willing to share those with me? It would make the review oh so much quicker. And, could you send me the list of the lawyers who represent current or former employees? Before you ask, Rule 6(e)requires that I keep matters before the grand jury secret, so I cannot tell you who or what I am subpoenaing. If the subpoenaed party (or his/her attorney) decides to disclose that information to you, that is his/her prerogative, but I can't do it. Thank you very much. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 nalAudo'.o **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this 229 08-80736-CV_MARRA 002119 EFTA00227233 message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 230 08-80736-CV MARRA 002120 EFTA00227234 From: Sent: Monday, February 12, 2007 12:25 PM To: Sanchez, Lilly Ann (Isanchez©fowler-white com) Subject: Epstein Matter Contacts: Lilly Ann Sanchez Hi Lilly -- Please let Gerry know that 1 took his comments to heart and I am re-reviewing all of the tapes. I noticed that he had transcripts of at least some of the tapes. Any chance you would be willing to share those with me? It would make the review oh so much quicker. And, could you send me the list of the lawyers who represent current or former employees? Before you ask, Rule 6(e) requires that I keep matters before the grand jury secret, so I cannot tell you who or what lam subpoenaing. If the subpoenaed party (or his/her attorney) decides to disclose that information to you, that is his/her prerogative, but 1 can't do it. Thank you very much. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 231 08-80736-CV_MARRA 002121 EFTA00227235 From: , C. (USAFLS) Sent: Friday, February 02, 2007 3:29 PM To: Big, tom Subject: RE: Hi Jim -- I just received your letter. It, of course, contains a number of topics, but I will ss only the first. I have conferred with our victim-witness coordinator, who tells me that we can reimburse Ms. for childcare expenses. I need an estimate to prepare the request and then, after the testimony, if Ms provides me with the amount of money that she actually paid, we can reimburse that amount. As for the remainder of the letter, I am a big believer in actions speaking louder than words, so the only way to prove that I am exercising independent judgment is to do so. I intend to do a thorough independent investigation so that I can make a reasoned decision about the matter. I cannot do that if witnesses who are not targets refuse to speak to me, even with assurances that their statements will not be used against them. As soon as I know the grand jury's schedule, I will call you with the time. Thank you. A. Assistant C.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 _stagt In ,ijL(I! From: BlgJImLaw@aoLcom [mallto:Big.limlaw@aol.com) Sent: February 02, 2007 9:36 AM To: C. (USAFLS) Subject: Re. I just wrote you a letter confirming that Ms. will be at the grand jury room with me. Please keep me informed as to the time. I must ou, my letter is critical o your office, although not at all critical of you. If you change your mind about forcing Ms to appear, please e-mail or call at once so she does not have to make arrangements for child care to be in court. Thanks, Jim Eisenberg 232 08-80736-CV MARRA 002122 EFTA00227236 • C. (USAFLS) From: BigJimLaw@aol corn Sent: 2007 9:36 AM To: C (USAFLS) Subject: I just wrote you a letter confirming that Ms. will be at the grand jury room with me. Please keep me informed as to the time. I must ou, my letter is critical iyour office, although not at all critical of you. If you change your mind about forcing Ms to appear, please e-mail or call at once so she does not have to make arrangements for child care to be in court. Thanks, Jim Eisenberg 233 08-80736-CV MARRA 002123 EFTA00227237 , • C. (USAFLS) From: C. (USAFLS) Sent: Friday, ebruary 02, 2007 9'02 AM To: enberg (bigpmlaw@aol com) Subject: Contacts: James I. Eisenberg Hi Jim -- Will Ms. appear at the grand jury on Tuesday? I believe that we will start at 1:00, but I won't know for certain until later today or Monday. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 234 08-80736-CV_MARRA 002124 EFTA00227238 C. (USAFLS) From: Lilly Ann Sanchez RASe4FC0)5WPLMER-WHITE COM] Sent: 007 To: a C.(USAFLS) Cc: Gerald Lefcourt Subject: Jeffrey Epstein hope you had a great holiday season. Gerald Lefcourt and I would like to speak with you early next week on the Epstein matter. if you provide me with some convenient dates and times for us to call you, i will coordinate with Gerry and confirm same. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131.3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 lsanchez(afowler-white.com **TAX MATTERS- IRS Circular 23C Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 240 08-80736-CV MARRA 002125 EFTA00227239 C. (USAFLS) From: C (USAFLS) Sent: •tt lisdaytruary , 15, 2007 3 51 PM To: Lilly Ann Sanchez Subject: RE: JE Great. We will see you then. A. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 - 77 Vid From: Lilly Ann Sanchez [maitto:LAS@FOWLER-WHITE.COM) Sent: Thu February 15, 2007 3:41 PM To: O, C. (USAFLS) Subject: RE: JE absolutely not in that case, gerry and I may come in jeans. Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 Isanchez@fowler-whlte.com >>> C. (USAFLS)" < 8)usdoi.aoy> 2/15/2007 3:20 PM >>> Hi Lilly -- This is a silly question but I know some people from an earlier generation get upset. The agents and I had set aside next week to go through all the tapes, so we are setting up a warroom and I was planning to just wear jeans. Do you think Gerry would be offended? A. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820.8711 Fax 561 820-8777 219 08-80736-CV_MARRA 002126 EFTA00227240 From: Lilly Ann Sanchez [mailto:LAS@FOWLER-WHITE.COM] Sent: Thursdaytebruary 15, 2007 3:18 PM To: MIN IIIII C. (USAFLS) Subject: JE confirmed meeting on Tuesday at 10am with gerry lefcourt. see you then. safe trip. Ully Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 isanchezPfowler-white.com **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 220 08-80736-CV MARRA 002127 EFTA00227241 C. (USAFLS) From: , El C. (USAFLS) Sent: Thursday. February 15, 2007 3:21 PM To: Lilly Ann Sanchez Subject: RE: JE Hi Ully -- This is a silly question but I know some people from an earlier generation get upset. The agents and I had set aside next week to go through all the tapes, so we are setting up a warroom and I was planning to just wear jeans. Do you think Gerry would be offended? A. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820.8711 its 824 . 37 77 Adjs._ au e. ov From: Lilly Ann Sanchez Imailto:LAS@FOWLER-WHITE.COM] Sent: Thursday, February 15, 2007 3:18 PM To: a Ann III C. (USAFLS) Subject: JE confirmed meeting on Tuesday at 10am with gerry lefcourt. see you then. safe trip. Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 Isanchez(afowler-white,com **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please 221 08-80736-CV MARRA 002128 EFTA00227242 contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 22.2 08-80736-CV_MARRA 002129 EFTA00227243 C. (USAFLS) From: Lilly Ann Sanchez [LAS@FOWLER-WHITE.COMJ Sent: i. 15. 2007 3:18 PM To: = C. (USAFLS) Subject: JE confirmed meeting on Tuesday at 10am with gerry lefcourt. see you then. safe trip. Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131.3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 Isanchezcafowler-white.com **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message.. Thank you. 223 08-80736-CV MARRA 002130 EFTA00227244 S, • C. (USAFLS) From: C. (USAFLS) Sent: Tuesday, Rruary 13, 2007 4:41 PM To: Bruce M. Lyons (brucelyons@aol com) Subject: Adronna Ross Contacts: Bruce M. Lyons Hi Bruce -- I was hoping I could get that factual proffer from you so I can see what the Office wants to do regarding immunity. On a totally unrelated note, are you related to Dennis Lyons from the Chicago area? Thank you. A. 561 209-1047 Fax 561 820-8777 a Lg Isdo.. ov 224 08-80736-CV MARRA 002131 EFTA00227245 , • C. (USAFLS) From: . IMI C. (USAFLS) Sent: Tuesd%, February 13, 2007 1:28 PM To: James I Eisenberg (bigjimlaw©aol.00m) Subject: Writter Proffer Contacts: James'. Eisenberg Hi Jim -- I haven't received your written proffer of likely testimony. Have you sent it already? Thank you. A. Assistant U.S, Attorney 561 209-1047 Fax 561 820-8777 226 08-80736-CV_MARRA 002132 EFTA00227246 Villatanalli Marie C. (USAFLS) • From: Mae C. (USAFLS) Sent: Friday, February 23, 2007 1:37 PM To: Sanchez, Lilly Ann (Isancheggfowler-white.corn) Subject: . Transcripts Hi Lilly — I talked to Nesbitt, and we would like to get the transcripts and a you very much for interceding on our behalf. Have a very good weekend. Assistant U.S. Attorney 561 209-1047 Fax 561 820.8777 218 Rif possible. Thank 08-80736-CV_MARRA 002133 EFTA00227247 C. (USAFLS) From: Ell C. (USAFLS) Sent: Wednesday, April 25, 2007 5:39 PM To: BruoeLyons@aol.com Subject: RE: Epstein Corporations Attachments: Hyperion Subpoena001.pdf: JEGE Subpoena001.pdf Hi Bruce -- I tried faxing these a couple of times but your fax machine wasn't picking up, so I just scanned them in. These are the JEGE and Hyperion Subpoenas. I will wait to hear from you about the other items. Thank you. A. Assistant U.S. Attorney 561 209-1047 Fax 820-8777 anicadisa From: BruceLyons@aol.com [mailtoltruceLyons@aol.com] Sent: Wednesda,S125, 2007 4:49 PM To: C (USAFLS) SublM Epstein Corporations I will get you the information on his NY counsel and find out the other info you request. See what's free at AOL corn. 194 08-80736-CV_MARRA 002134 EFTA00227248 C. (USAFLS) From: C. (USAFLS) Sent: M& ay, Apra 25, 2007 12:45 PM To: Bruce M. Lyons (brucelyons@aol.com) Subject: Epstein Corporations Contacts: Bruce M. Lyons Hi Bruce -- Sorry to bother you. I couldn't remember whether you represented JEGE and Hyperion or if you only represented the pilots. Could you let me know? I need a few more business records. And, do you represent any other corporate entities owned/operated by Mr. Epstein? If not, do you know who his general corporate counsel is? Thank you! A. Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 195 08-80736-CV_MARRA 002135 EFTA00227249 MI • C. (USAFLS) From: C. (USAFLS) Sent: ReWasda.pnl 25, 2007 11 49 AM To: info@ctadvantage.com Subject: Service on a Delaware Corporation Dear Sir or Madam: I have a federal grand jury subpoena that needs to be served on a Delaware corporation for which CT Corporation is listed as the registered agent. Do you accept service via facsilime and/or via e-mail? Thank you for your kind assistance. A. Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 196 08-80736-CV_MARRA 002136 EFTA00227250 C. (USAFLS) From: El C (USAFLS) Sent Wednesday, A 11, 2007 8 43 AM To: Sanchez. Lilly M (Isanchez@fowler-while corn), Gerald Letcourt Esq. (gb@lefcourtlaw.com) Subject: Jeffrey Epstein Contacts: Lilly Ann Sanchez Hi Lilly and Gerry -- I have been out sick and have a 2255 due by the end of the week. I will give you a call next week. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 206 08-80736-CV_MARRA 002137 EFTA00227251 , • C. (USAFLS) From: C (USAFLS) Sent: Wednesday. February 28, 2007 11.28 AM To: m w aol corn Subject: Hi Jim -- Your favorite AUSA contacting you about your favorite client. I hope all is well. I reviewed the proffer and I will make the request to Washington. I will be out of town next week, but hopefully will have an answer by the time I return. Thank you. A. Assistant U.S. Attorney. 561 209-1047 Fax 561 820-8777 IlafanatZusdoi.gov 217 08-80736-CV MARRA 002138 EFTA00227252 C. (USAFLS) From: Gerald Lefcourt [GBL@lefcourtlaw.com) Sent: , 2007 5:19 PM To: C. (USAFLS) Cc: r y nn a z; oy BLACK Subject: RE: Jeffrey Attachments: 2007-07-18 re NES subpoena.pdf please consider this letter in response to the subpoena to NES. Gerald B. Lefcourt Gerald B. Lefcourt, P.C. 148 E. 78th Street New York, New York 10021 Tel. Fax gb1011efcourtlaw.com Original Messa e From: C. (USAFLS) [mailto Sent: ‘11111!!, Ju y 04, 2007 4:07 PM To: Lilly Ann Sanchez Cc: Gerald Lefcourt Subject: RE: Jeffrey Epstein Dear Lilly and Gerry: Thank you for your e-mail and your message. This e-mail was supposed to have gone out yesterday while I was in trial. I have no objection to the two-week extension with respect to NES, New York Strategy Group, and Epstein Virgin Islands Foundation. With respect to the subpoena to the investigator, I would like to get the computer equipment as soon as possible. If you prefer to simply turn over the equipment without anyone appearing before the grand jury that is fine. If we proceed that way, we can defer litigating the issue of the applicability of the attorney-client and/or work product privilege to information related to how and why the equipment was removed. I will be in trial this week, so please contact Jason Richards at the FBI directly at 561 833-7517. I look forward to your July 11th submission. If you would like to discuss the possibility of a federal resolution of Mr. Epstein's case that could run concurrently with any state resolution, please leave a message on my voicemail at the office the day. (561 209-1047) and I will get back to you after trial has ended for Thank you. A. Assistant U.S. Attorney 51 08-80736-CV MARRA 002139 EFTA00227253 561 209-1047 Original Message From: Lilly Ann Sanchez [mailto:LAS@FOWLER-WHITE.COM] Sent: Friday, June 29, 2007 4:05 PM To: ) III C. (USAFLS) Cc: Gerald Lefcourt Subject: Jeffrey Epstein As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of the following outstanding subpoenas: 1. NES 2. NY Strategy 3. Investigator Riley 4. Certification for St. Thomas entity We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based resolution shortly thereafter. as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would like to extend the return date two weeks-- to July 24. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 728-7579 lsanchezQfowler-white.com 52 08-80736-CV MARRA 002140 EFTA00227254 C. (USAFLS) From: , IM C. (USAFLS) Sent: Friday, July 06, 2007 9:25 AM To: 'Sanchez, Lilly Ann (Isanchez@fowler-white.com); Gerald Letourt Subject: Extension of Time re Computer Subpoena Hi Lilly and Gerry — I hope you are enjoying your time off. Your request to extend the time to respond to the Riley and Riley-Kiraly subpoenas is fine. 1 will schedule time with the grand jury on July 17th, so if you intend to move to quash the subpoenas, please file your papers not later than July 16 FYI--United States District Judge Middlebrooks is assigned to handle matters related to the relevant grand jury. As I am sure you know, pursuant to Fed. R. Crim. P. 6(eX6), any such motion must be filed under seal. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 as 08-80736-CV_MARRA 002141 EFTA00227255 C. (USAFLS) From: Ell C. (USAFLS) Sent: le .ir lay. July I, 2007 4:07 PM To: 'Lilly Ann Sanchez Cc: Gerald Lefcourt Subject: RE: Jeffrey Epstein Dear Lilly and Gerry: Thank you for your e-mail and your message. This e-mail was supposed to have gone out yesterday while I was in trial. I have no objection to the two-week extension with respect to NES, New York Strategy Group, and Epstein Virgin Islands Foundation. With respect to the subpoena to the investigator, I would like to get the computer equipment as soon as possible. If you prefer to simply turn over the equipment without anyone appearing before the grand jury that is fine. If we proceed that way, we can defer litigating the issue of the applicability of the attorney-client and/or work product privilege to information related to how and why the equipment was removed. I will be in trial this week, so please contact Jason Richards at the FBI directly at 561 833-7517. I look forward to your July 11th submission. If you would like to discuss the possibility of a federal resolution of Mr. Epstein's case that could run concurrently with any state resolution, please leave a message on my voicemail at the office (561 209-1047) and I will get back to you after trial has ended for the day. Thank you. A. Assistant U.S. Attorney 561 209-1047 Original Message From: Lilly Ann Sanchez [mailto:LAS@FOWLER-WHITE.COM] Sent: Frida June 29 2007 (USA LS) To: III C. (USAFLS) Cc: Gerald Lefcourt Subject: Jeffrey Epstein As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of the following outstanding subpoenas: 1. NES 2. NY Strategy 3. Investigator Riley 4. Certification for St. Thomas entity We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based resolution shortly thereafter. 99 08-80736-CV MARRA 002142 EFTA00227256 as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would like to extend the return date two weeks-- to July 24. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 728-7579 lsanchez0fowler-white.com Tracking: 100 08-80736-CV MARRA 002143 EFTA00227257 C. (USAFLS) From: Lilly Ann Sanchez [LAS@FOWLER-WHITE.COM] Sent: LaUr 4:05 PM To: IIMI C. (USAFLS) Cc: era a court Subject: Jeffrey Epstein As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of the following outstanding subpoenas: 1. NES 2. NY Strategy 3. Investigator Riley 4. Certification for St. Thomas entity We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based resolution shortly thereafter. as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would like to extend the return date two weeks-- to July 24. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 728-7579 lsanchezefowler-white.com 110 08-80736-CV MARRA 002144 EFTA00227258 • C. (USAFLS) From: C. (USAFLS) Sent: Monday, June 25, 2007 4:54 PM To: Sanchez, Lilly Ann (Isanchez@fowler-white.com) Subject: Your letter Hi Lilly — I did get a copy of your letter, thanks. I will see you tomorrow morning. Regards, 113 08-80736-CV MARRA 002145 EFTA00227259 C. (USAFLS) From: , IN C. (USAFLS) Sent: Wsday, June 13, 2007 5:48 PM To: G8L©lefcourtlave.cont, Sanchez, Lilly Ann (Isanchez(gfowler-white.com) Subject: Another Corporation Dear Gerry and Lilly: Sony to trouble you yet again, but are you authorized to accept service of a subpoena for NES, LLC? Thank you again. A. Assistant U.S. Attorney 561 209-1047 135 08-80736-CV_MARRA 002146 EFTA00227260 C. (USAFLS) From: Faith A. Friedman [FFriedman lefcourttaw.com) Sent: esa007 5:45 PM To: = C. (USAFLS) Cc: erald Le court Subject: Subpoenas dated May 31, 2007, to J. Epstein Virgin Islands Foundation. Inca, J. Epstein & Co., Inc.; Epst sts: and Financial Trust Company. Inc Attachments: 2007-06-12 to w subpoena material.pdf Dear Ms. At Mr. Lefcourt's request, I hereby provide you with responses to the subpoenas served on the above entities all of which were dated May 31, 200 7. I note that the original, along with the documents referenced therein, was sent to your office this afternoon by Federal Express. If you do not receive these items or have any questions please do not hesitate to contact Mr. Lefcourt. Very truly yours, Faith A. Friedman, Esq. Law Offices of Gerald B. Lefcourt, P.C. 148 East 78th Street York 10021 x327 email. ffriedman@lefcourtlaw.com 136 08-80736-CV_MARRA 002147 EFTA00227261 1•11 • C. (USAFLS) From: , C. (USAFLS) Sent: il,y,Ty , 31, 2007 8:26 PM To: Gerald Lefcourt Cc: Ball, Shawn (USAFLS) Subject: RE: Representation of Financial Trust Company, Inc.. J. Epstein & Company. Inc., and other corporate entities Hi Gerry — Sorry. I was out and then I had to start trial. You will receive them tomorrow. Thank you again. A. Assistant U.S. Attorney 561 209-1047 From: Gerald Lefcourt [mailto:GBL@Iefcourtlaw.com] Sent: ThursdasMath, 2007 11:56 AM To: S C. (USAFLS) Cc: Lilly Ann Sanchez Subject: RE: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities when we spoke last Thursday I agreed to accept service of a subpoena (without promising I would represent Financial Trust depending on what was being requested) that I think you said you would fax. This is just to let you know that I never received any fax to that end --just in case it was sent somewhere else in error. Gerald B. Lefcourt Gerald B. Letcourt, P.C. 148 E. 78th Street New York. York 10021 Tel. Fax oblalefcourtlaw.com From: M. . 07 7:14 PM C. (USAFLS) [mailto Sent: To: Gerald Lefcourt Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities Dear Gerry: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc., J. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or all of those entities, are you willing to accept service of subpoenas via fax? Thank you for your assistance. 137 08-80736-CV_MARRA 002148 EFTA00227262 A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 138 08-80736-CV_MARRA 002149 EFTA00227263 MIS C. (USAFLS) From: Gerald Lefcourt [GBL@Iercourtlaw.com] Sent: 007 11:56AM To: C. (USAFLS) Cc: Lilly anchez Subject: RE: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities , when we spoke last Thursday I agreed to accept service of a subpoena (without promising I would represent Financial Trust depending on what was being requested) that I think you said you would fax. This is just to let you know that I never received any fax to that end -- just in case it was sent somewhere else in error. Gerald B. Lefcourt Gerald B. Lefcourt, P.C. 148 E. 78th Street New York New York 10021 Tel. Fax pblalercourtlaw.corq From: S (USAFLS) [mailto:Ann Sent Tuesday, May 22, 2007 7:14 PM To: Gerald Lefcourt Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities Dear Gerry: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc., .1. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or all of those entities, are you willing to accept service of subpoenas via fax? Thank you for your assistance. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 139 08-80736-CV_MARRA 002150 EFTA00227264 MN • C. (USAF LS) From: ) Sent: 007 9:25 AM To: C. (USAFIS) Subject: FW: Jeffrey Epstein Please put in your file. thx From: Gerald Lefcourt [mailto:GBL@lefcourtlaw.com] Sent: Wednesda Ma 23 2007 5:00 PM To: Subject: RE: Jeffrey Epstein Thanks for the email. I will get back to you as to timing of the meeting. Gerald B. Lefcourt Gerald B. Lefcourt, P.C. 148 E. 78th Street New York New York 10021 Tel. Fax obleletcourtlaw.com From: [mailto:Andrew.Lourie@usdoj.gov] Sent: Tues ay, May 22, 2007 6:32 PM To: Gerald Lefcourt Subject: RE: Jeffrey Epstein I have your letter. I think we are on the same page, but to be sure I do want to clarify that we spoke the other week and I did say that if you want to meet with me again, I am ready to do so. The wording of your letter, however, suggests implicitly that I agreed to contact you before a decision is made to seek an indictment of Mr. Epstein. If that was your understanding, then please allow me to clarify. Our investigation is ongoing and if we decide to seek an indictment, we don't intend to call Mr. Epstein's representatives to let him know that. Of course, in the interim, if you would like to make a presentation to us, we are willing to listen. Along those lines, iven the fact that we have already met once, with schedules being what they are, it makes sense for our criminal chief, MIt11, to be included when you make another presentation, rather than working up the chain incrementally. I realize you were being respectful in not attempting to leapfrog over me, which I appreciate. I will pass on your request to meet with the U.S. Attorney as well, but can't commit for him one way or another. When you have some dates in mind, let me know and I will try to set up a meeting in Miami. From: Gerald Lefcourt [mailto:GBL@Iefcourtlaw.com] Sent: Tuesday May 22 2007 2:05 PM To: Cc: C. (USAFLS); Lilly ■ Sanchez Subject: Jeffrey Epstein 141 08-80736-CV MARRA 002151 EFTA00227265 , attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved Thanks for your a ention. Could you email back so that I know you have received this letter? Gerald B. Letcourt Gerald B. Letcourt, P.C. 148 E. 78th Street New York. rk 10021 Tel. Fax 142 08-80736-CV_MARRA 002152 EFTA00227266 C. (USAFLS) From: C. (USAFLS) Sent: I,•., • Ng 7:14 PM To: Gi3L©lefcourtlaw.com Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company. Inc., and other corporate entities Dear Gerry: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc., J. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or all of those entities, are you willing to accept service of subpoenas via fax? Thank you for your assistance. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 116 08-80736-CV_MARRA 002153 EFTA00227267 C. (USAFLS) From: , C. (USAFLS) Sent: 1,, tl l.007 7:12 PM To: GBL@lefcourtlaw.com Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company. Inc., and other corporate entities Dear Gerry: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc., J. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or all of those entities, are you willing to accept service of subpoenas via fax? Thank you for your assistance. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 147 08-80736-CV_MARRA 002154 EFTA00227268 C. (USAFLS) From: Sent: gust 02, 2011.1 Fag. To: (USAFLS); . C (USAFLS): Subject: Attachments: FYI Original Message From: Lilly III Sanchez [mailto:las@FOWLER-WHITE.COM] Sent: Thursday, August 02, 2007 12:38 PM To: Cc: Jacqueline Borrero Subject: JE -- letter - please see attached and confirm receipt. i am also having letter hand-delivered to you and alex. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 lsanchez0fowler-white.com **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 41 08-80736-CV MARRA 002155 EFTA00227269 C. USAFLS From: Roy BLACK (RBLACK©royblack.comj Sent: 06, 20081.49 PM To: C (USAFLS) Subject: Re: ollow-up on last week's call Ok. Will do. Ori inal Messa e From: " , III C. (USAFLS)" < To: o r tiotr Ro BLACK<RBLACI <.cow Cc: Sent: 8/6/2008 1:38:23 PM Subject: RE: Follow-up on last week's call Hi Roy -- Hope your trip is going well. Are you available today at 4:30 Eastern (1:30 Pacific)? If so, please call my office at the number below, and Karen and I can both be reached there. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Roy BLACK [mailto:RBLACK@royblack.com] Sent: Tuesda , Au ust 05, 2008 11:40 PM To: C. (USAFLS) Cc: Subject: Re: Follow-up on last week's call I just got back to my computer. Sorry it took awhile to respond. I am available tomorrow to call you. Let me know what time to call. Remember I am 3 hours behind you so email me the time in the am and I will call. Thanks Roy >>> ' 08/05/08 1:01 PM >>> Hi Roy - Are you available late this afternoon to do a follow-up on last week's call? If today does not work, can you let us know about your availability tomorrow, as well? • C. (USAFLS)" < Thank you. 308 08-80736-CV MARRA 002156 EFTA00227270 A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 309 08-80736-CV MARRA 002157 EFTA00227271 From: Sent: To: Cc: Subject: C. (USAFLS) C. (USAFLS) Wednesday, August 06, 2008 1:38 PM RE: Follow-up on last week's call Hi Roy -- Hope your trip is going well. Are you available today at 4:30 Eastern (1:30 Pacific)? If so, please call my office at the number below, and Karen and I can both be reached there. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Roy BLACK Cmailto:RBLACK@royblack.com] Sent: Tuesday, August 05, 2008 11:40 PM To: Mla (USAFLS) Cc: ) Subject: Re: Follow-up on last week's call I just got back to my computer. Sorry it took awhile to respond. I am available tomorrow to call you. Let me know what time to call. Remember I am 3 hours behind you so email me the time in the am and I will call. Thanks Roy >>> " , III C. (USAFLS)" < 08/05/08 1:01 PM >>> Hi Roy - Are you available late this afternoon to do a follow-up on last week's call? If today does not work, can you let us know about your availability tomorrow, as well? Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 310 08-80736-CV MARRA 002158 EFTA00227272 Tracking: 311 08-80736-CV_MARRA 002159 EFTA00227273 C. (USAFLS) From: . C (USAFLS) Sent: Friday, August 15, 2008 2 12 PM To: O' MMSRoy BLACK' Cc: Subject: Response to your e-mail Dear Jay and Roy: Please see the attached. Thank you. 380815 Ltr to Lefkow... A. Assistant U.S. Attorney 500 S. Australian Aye, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 177 08-80736-CV_MARRA 002160 EFTA00227274 From: Sent: To: Subject: fyi C. (USAFLS) e2.0(37sAllF:L2WM FW: From: Sent: Thursday, August 23, 2007 11:27 AM To: Isanchez@fowler-white.com. Subject: Dear Lilly, Following up on our conversation yesterday, given that Roy Black will be on vacation through Labor Day, we are agreeable to jointly requesting that Judge Marra set the hearing regarding the subpoena during the week of September 11. You may make this representation to the Court on our behalf. With respect to the September 4 return date for Ms. Groff, the agents who served the subpoena were left with the impression, based upon her statements, that she already had an attorney. If this is the case, that attorney should contact to discuss any issues he/she has with the return date. If Ms. Groff does not have an attorney and you intend to procure her one, then please let know. If you are unable to find one quickly and need an extra week, has informed me that she is agreeable to extending the subpoena return date to September 11th as well. However, if she is not already represented, please attempt to procure the attorney as soon as possible so that he or she has time to get up to speed in advance of the 11th. We would like to avoid the need for further extensions. We will wait to hear from you regarding Ms. Groff, but otherwise the above should resolve all the issues raised by telephone yesterday. Regards, 08-80736-CV MARRA 002161 EFTA00227275 C. (USAFLS) From: C. (USAFLS) Sent: I, August 13, 2007 1.18 PM To: 'RBlack@RoyBlack.cont Subfeet: Epstein Computer Litigation Hi Roy —1 have conferred with the appropriate people, and we are not willing to agree to a stay on your Motion to Quash. Res ids, A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 2 08-80736-CV_MARRA 002162 EFTA00227276 11111111m C. (USAFLS) From: C. (USAFLS) Sent: 2007 12:53 PM To: Subject: : i teetter go out on Friday? Thank you! I hope the first day is going well. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: [mailto: Sent: Monday, August 06, 2007 12:36 PM To: III C. (USAFLS) Subject: Re: Did the letter go out on Friday? Yes, I emailed it and then sent hard copies to everyone including you. And thanks for your congrats. I wish you all the best with the case. Kobre & Kim LLP and Affiliates 800 Third Avenue New York, New York 10022 Tel Fax www.kobrekim.com Original Message From: C. (USAFLS) To: Sent: Mon Aug 06 11:23:35 2007 Subject: Did the letter go out on Friday? Hi - Sorry to bother you now that you are gone. (Congratulations!) Did the letter to Lilly go out on Friday? Thank you, and best of luck with your new venture. A. Assistant U.S. Attorney 22 08-80736-CV MARRA 002163 EFTA00227277 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged and/or confidential information. If the reader of this message is not the intended recipient(s), or the employee or agent responsible for delivering the message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this e-mail message is strictly prohibited. If you have received this message in error, please notify the sender immediately and delete this e-mail message and any attachments from your computer without retaining a copy. IRS Circular 230 disclosure: Any tax advice contained in this communication (including any attachments or enclosures) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed in this communication. (The foregoing disclaimer has been affixed pursuant to U.S. Treasury regulations governing tax practitioners.) 23 08-80736-CV_MARRA 002164 EFTA00227278 From: Sent: To: Subject: ht e letter go out on Friday I I i - Sony to bother you now that you are gone. (Congratulations!) Did the letter to Lilly go out on Frill Thank you, and best of luck with your new venture. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 24 08-80736-CV_MARRA 002165 EFTA00227279 C. (USAFLS) From: ea C. (USAFLS) Sent: AM To: Subject: Did the letter go out on Friday? HiMt — Sony to bother you now that you arc gone. (Congratulations!) Did the letter to Lilly go out on Friday? Thank you, and best of luck with your new venture. AM=. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 56l 820-8777 25 08-80736-CV_MARRA 002166 EFTA00227280 C. (USAFLS) From: C. 280898) Sent: Mon ay, !len, 08, 2008 9:46 AM To: jherman@hermanlaw.com; ahorowitz@hermanlaw.com Subject: Correspondence for your clients Dear Jeff and Adam: I apologize, but the attached letters were sent to your offices on September 2id, but were just returned for insufficient postage. I will send the originals out by FedEx today. I received a call, I believe from Mr. Mennelstein, asking why I had sent a letter to a represented party. The enclosed letters are for those victims whom 1 know to be represented by you. If you undertake representation of any other victims, please let me know so that I may keep that in my records. 1 expect that you will share these letters with your clients so that they may decide how they wish to proceed. 080902 F nal :rs to Herman Cl. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 72 08-80736-CV_MARRA 002167 EFTA00227281 , NM C. (USAFLS) Sent: It•, Reit 02, 2008 1:16 PM From: , C. (USAFLS) To: ' 'Roy BLACK' Cc: Subject: Thank you for your tax Dear Jay and Roy: have received your fax. I will start sending out the victim notifications today. In accordance with your request, I have changed the language regarding the victims' right to receive a copy of the Agreement. Mr. Goldberger will be receiving copies as the letters go out. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 85 08-80736-CV_MARRA 002168 EFTA00227282 From: Sent: To: Cc: Subject: Attachments: C. (USAFLS) C. (USAFLS) Thursday,fugtlti, 2008 3.51 PM RE: pstein Epstein NonProsecution Agrmt w Addendum.pdf Hi Brad — I received your fax with the signed Protective Order, so I have attached the Non-Prosecution Agreement. Please give me a call when you receive. And please send or fax over copies of the signed Protective Order as you receive them from your clients and co-counsel. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Brad Edwards imailto:be@thradecAerdslaw.comj Sen : Th Aat 28, 2008 9:33 AM To: C. (USAFIS) Subject RE: Epstein It has already been faxed to you. Please let me know if you do not receive it. Also, I would appreciate it if you could fax it to me as well as mail it, as I would really like to see it today if at all possible. Thanks Brad Edwards, Esquire Law Office of Brad Edwards & Associates 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 (Broward) 305-935-2011 (Miami-Dade) Facsimile: 954-924-1530(Broward) 305/9354227 (Miami-Dade) e-mail: be©bradedwardslaw.com PRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the use of the individual or entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction. 103 08-80736-CV_MARRA 002169 EFTA00227283 From: ■ MI C. (USAFLS) [mallto Sent: Wednesday, August 27, 2008 6:47 PM To: Brad Edwards Subject: Epstein Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 104 08-80736-CV_MARRA. 002170 EFTA00227284 C. (USAFLS) From: Brad Edwards (be@bradedwardslaw.com] Sent: lit at, 2008 9:33 AM To: C. (USAFLS) Subject: RE: Epstein It has already been faxed to you. Please let me know if you do not receive it. Also, I would appreciate it if you could fax it to me as well as mail it, as I would really like to see it today if at all possible. Thanks Brad Edwards, Esquire Law Office of Brad Edwards & Associates 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 (Broward) 305-935-2011 (Miami-Dade) Facsimile: 954-924-I 530(Broward) 305/935-4227 (Miami-Dade) e-mail: be@bradedwardslaw.coin PRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the use of the individual or entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction. From: MI C. (USAFLS) [malt.° Sent: Wednesday, August 27, 2008 6:47 PM To: Brad Edwards Subject Epstein Hi Brad —I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 106 08-80736-CV_MARRA 002171 EFTA00227285 Fax 561 820-8777 107 08-80736-CV_MARRA 002172 EFTA00227286 C. (USAFLS) From: Brad Edwards (be@bradedwardslaw.com) Sent: ilitithill 27, 2008 6:59 PM To: C (USAFLS) Subject: RE. Epstein Hi I did not know you needed that from me first. The last email I received from Mr. Lee indicated that you do not need the acknowledgement from us prior to disclosure of the agreement, or at least that is how I understood it. So I have just been waiting to receive it. We must have gotten our wires crossed. Either way, no big deal. I have signed it, and I just sent an email to my secretary to fax it to you first thing tomorrow. If you get an opportunity to call me tomorrow afternoon, I would appreciate it. Thanks Sincerely, Brad Edwards, Esquire Law Office of Brad Edwards & Associates 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 (Broward) 305-935-2011 (Miami-Dade) Facsimile: 954-924-1530(Broward) 305/935-4227 (Miami-Dade) e-mail: beta bradedwa rdslaw.com PRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the use of the individual or entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction. From: S • C. (USAFLS) [mailto Sent: Wednesday, August 27, 2008 5:47 PM To: Brad Edwards Subject: Epstein Ili Brad — I haven't received a signed protective order from you yet. so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. 108 08-80736-CV MARRA 002173 EFTA00227287 A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 109 08-80736-CV_MARRA 002174 EFTA00227288 • C. (USAFLS) From: ,M C. (USAFLS) Sent: Wednesday, August 27, 2008 6:47 PM To: be@bradedwardslaw.com Subject: Epstein Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 110 08-80736-CV_MARRA 002175 EFTA00227289 S • C. (USAFLS) From: ■ C. (USAFLS) Sent: Wednesday, August 27, 2008 6:36 PM To: be@bradedwards.com Subject: Epstein Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 111 08-80736-CV_MARRA 002176 EFTA00227290 C. (USAFLS) From: . M C. (USAFLS) Sent: tes., August , 2008 1.26 PM To: I fkowi z I i - oy BLACK Cc: Subject: Je rey Epstein Lefkowi z 08082600 .pdf A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 %Vest Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 112 08-80736-CV_MARRA 002177 EFTA00227291 • C. (USAFLS) From: In C. (USAFLS) Sent: Thursday, August 21, 2008 5:32 PM To: iiiry BLACK Cc: Subject: Jeffrey Epstein Dear Jay and Roy —1 have attached a letter in response to Jay's letter of August 18, 2008, and an Order we received today in the Jane Doe'. United States litigation. )80821 Itr to Lefkow... DE26 080821 P Dtective Order.p. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 136 08-80736-CV_MARRA 002178 EFTA00227292 C. (USAFLS) From: , C. (USAFLS) Sent: May, August 20, 2008 3:19 PM To: bertpatton©podhurst.com Subject: Epstein Civil Cases Hi Bert — Here is a chart with all of the information. Please let Mr. Josefsberg know that Mr. Epstein has to answer all of the Complaints in the Jeffrey Herman cases by September 4th• Thank you. ro EPSTEIN CIVIL rIGATION CASES A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 159 08-80736-CV_MARRA 002179 EFTA00227293 C. (USAFLS) From: Jay Letkowdz (JLelkowitz©kirkland.com) Sent: 20, 2008 9:35 AM To: SAFLS) Cc: Subject: Re: Yourfax Thanks MI. We arc working on something and will share it with you. Good luck with the weather. From: 1=, C. (USAFLS)" Sent: 08/20/2008 09:28 AM AST To: Ja Leflcowitz Cc: r <Karen.Atkinson@usdoj.goy> Subject: RE: Your fax gold P.S. In the meanwhile, if you would like to propose language for our joint submission, 1 am happy to look that over. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: C. (USAFLS) Sent: Wednesday, August 20, 2008 9:26 AM To: la Lefl o i ow12 Cc: Subject: Your fax Good morning, Jay. Our office has been closed since Monday afternoon due to the Tropical Storm, so I just received your fax. I have to be in Court this morning, but I will turn my attention to your response upon my return and will get back to you later today or tomorrow morning. 156 08-80736-CV_MARRA 002180 EFTA00227294 Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmasterfakirkland.com, and destroy this communication and all copies thereof, including all attachments. 157 08-80736-CV_MARRA 002181 EFTA00227295 C. (USAFLS) From: Sent: To: Cc: Subject: C. (USAFLS) Wednesday, August 20, 2008 9:28 AM P.S. In the meanwhile, if you would like to propose language for our joint submission, I am happy to look that over. A. Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: C. (USAFLS) Sent: Wednesday, August 20, 2008 9:26 AM To: Cc: Subject: Your fax Good morning, Jay. Our office has been closed since Monday afternoon due to the Tropical Storm, so I just received your fax. I have to be in Court this morning, but I will turn my attention to your response upon my return and will get back to you later today or tomorrow morning. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 158 08-80736-CV_MARRA 002182 EFTA00227296 , • C. (USAFLS) 20, 2008 9:26 AM From: MUM C. (USAFLS) Ser To: Cc: Subject: Your fax Good morning, Jay. Our office has been closed since Monday afternoon due to the Tropical Storm, so I just received your fax. I have to be in Court this morning, but I will turn my attention to your response upon my return and will get back to you later today or tomorrow morning. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 159 08-80736-CV_MARRA 002183 EFTA00227297 • C. (USAFLS) From: Brad Edwards [be@bradedwardslaw.com] Sent: 8 2:49 PM To: ); Paul Cassell Cc: (USAFLS) Subject: RE: Draft Protective Order - slight tweak It looks ok. Go ahead and submit it. While we would disagree with your statement that our proposed order goes well beyond what is at issue, since it actually covers very thoroughly the ruling by Judge Marra yesterday, at this point we feel that time is of the essence and we will agree with you submitting your proposed order as is. I think we all heard Judge Marra and are thus all clear as to the terms of the protective order and what is required. I would prefer that there is some language that the protective order is entered without prejudice to petitioners (seems like it would go in paragraph b), but if you are unable to incorporate it in your order, then I am sure there is a record from yesterday that could be used to help us get relief from the protective order at a later hearing. Anyway, thanks for preparing the order. We will look out for the "agreement". Thanks From: a [mailto:Dexter.Lee@usdoj.gov] Sent: Friday, August 15, 2008 1:24 PM To: Paul CassL,_II. Brad Edwards Cc: a MI C. (USAFLS) Subject: RE: Draft Protective Order - slight tweak Judge Cassell and Brad, I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e), referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the acknowledgment to the U.S. Attorney's Office. The government has no doubts that counsel for petitioners will ensure the authorized recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not require the acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized recipient. We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners. Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at hand. Thanks. From: Paul Cassell (mailto:cassellp@LAW.UTAKEDU1 Sent: Friday, August 15 2008 12:21 PM To: Brad Edwards; Cc: S C. (USAFLS) Subject: RE: Draft Protective Order - slight tweak Hello and■ First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. 171 08-80736-CV MARRA 002184 EFTA00227298 Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this: Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. How about this: Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly provide a copy of that acknowledgment to the USAO. I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients. Paul G. Cassell Professor of Law 172 08-80736-CV_MARRA 002185 EFTA00227299 C. (USAFLS) From: Sent: Friday, I. ...ist 1 , 08 2:24 PM To: ligifisi dcw.mas) Cc: Subject: RE: Draft Protective Order - slight tweak Attachments: Protective Order_v2 doc Judge Cassell and Brad, I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e), referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the acknowledgment to the U.S. Attorney's Office. The government has no doubts that counsel for petitioners will ensure the authorized recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not require the acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized recipient. We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners. Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at hand. Thanks. From: Paul Cassell [mailto:cassellp(c3lAW.UTAH.EDU1 Sent: Friday, Augu t 15 12:21 PM To: Brad Edwards;_____________________ Cc: IN C. (USAFLS) Subject: RE: Draft Protective Order - slight tweak Hello and First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this: Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. How about this: Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their 173 08-80736-CV_MARRA 002186 EFTA00227300 receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner% must promptly provide a copy of that acknowledgment to the USAO. I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients. Paul a Cassell Ronald M. Boyce Presidential Professor of Law of Law 174 08-80736-CV_MARRA 002187 EFTA00227301 C. (USAFLS) From: . = C. (USAFLS) Sent: Friday, August 15, 2008 2.12 PM To: oy BLACK Cc: Subject: Response to your e-rnail Dear Jay and Roy: Please see the attached. Thank you. )80815 lir to Lefkow... A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 175 08-80736-CV_MARRA 002188 EFTA00227302 C. (USAFLS) From: Paul Cassell [casselip@LAW UTAH EDU] Sent: Friday, August To: Cc: Brad Edw.: AFLS) Subject: RE: Draft Protective Order - slight tweak Hello and ■ First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. Second, on the language — As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this: Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. How about this: Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly provide a copy of that acknowledgment to the USAO. I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients. Paul G. Cassell Ronald M. Boyce Presidential Professor of Law 198 08-80736-CV_MARRA 002189 EFTA00227303 C. (USAFLS) From: Sent: Friday, August 15. 2008 11:41 AM To: b Br d w r w.com Cc: C (USAFLS) Subject: ra Protective Order Brad, Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks. Protective Order.doc 207 08-80736-CV_MARRA 002190 EFTA00227304 C. (USAFLS) From: C. (USAFLS) Sent: il.drieptember 17, 20081:20 PM To: Jack Goldberger Subject: RE: Letter concerning Epstein and the Palm Beach Daily News Thank you, Jack. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Jack Goldberger imalltolgoldberger@agwpa.com] To: SenSI*, e C. mber 17, (USAFLS) 2008 12:59 PM Cc: Jay L f wi ; RBIad0RoyBlack.com; Barry Krischer; (USAF'S); Subject: Re: Letter concerning Epstein and the Palm Beach Daily News We will deal with the state. To answer your? The addendum has been filed Jack Goldberger Sent from my iPhone On Sep 17, 2008, at 12:15 PM, "EM, ■ wrote: C. (USAFLS)" <M M> Gentlemen: Please review the attached letter. Thank you. «Lefkowitz 080917.pdf» A. Vitiitfaria Assistant V.S. Attorney 561 209-1047 <Lefkowitz 080917.pdf, 49 08-80736-CV_MARRA 002191 EFTA00227305 C. (USAF LS) From: To: Sent: C. (USAF ber 17, 2008) 12:59 PM LS Cc: Subject: Jack Goldberger Ugoldberger@agwpa.com] Krischer; Re: Letter concerning Epstein and the Palm Beach Daily News We will deal with the state. To answer your? The addendum has been filed Jack Goldberger Sent from my iPhone On Sep 17, 2008, at 12:15 PM, " wrote: C. (USAI LS)" Gentlemen: Please review the attached letter. Thank you. «Lefkowitz 080917 pdf» A. _Assistant 'U.S. fAttarnry 561 209-1047 <Lefkowitz 080917.pdf, 50 (USAFLS); 08-80736-CV_MARRA 002192 EFTA00227306 Sim From: Sent: Wednesday, September 17, 200812:04 PM To: Jay Lefkowitz; JacliSirir gigldberger " ' cher; (USAFLS); ); n em iall Cc: ) Subject: Letter concerning Epstein and the Palm Beach Daily News C. (USAFLS) C. (USAFLS) Gentlemen: Please review the attached letter. Thank you. Lefkowitz 080917.pdf Assistant . Attorney 561 209-1047 51 08-80736-CV MARRA 002193 EFTA00227307 C. (USAFLS) From: _,. -C. (USAFLS) Sent: Wednesday. September 17. 2008 12.00 PM To: Barry Krischer Cc: Lanna Belo te.fl us); (USAFLS); Subject: Your inquiry regar ing t eEpstein case Hi Barry — The Non-Prosecution Agreement contains a confidentiality provision that requires us to inform Mr. Epstein's counsel before making any disclosure — even a compulsory disclosure. I am cc'ing you on a letter to Jay Lefkowitz, Roy Black, and Jack Goldberger informing them of the request and asking them, as parties to the criminal case, to contact you regarding a possible suit by the Shiny Sheet. On another note, I also will be informing them that I believe that they still have not filed the complete agreement with the Court, as required by the Judge at the hearing. Thank you very much for reaching out to us when you received this request, and if you need any help from us, please let us know. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 52 08-80736-CV_MARRA 002194 EFTA00227308 C. (USAFLS) From: Sent: To: Subject: C. (USAFLS) t ay, 1.008 3:38 AM FIN. confidential communication Original Message From: (USAFLS) To: C. (USAFLS) Sent: Mon May 19 15:37:30 2008 Subject: RE: confidential communication From: Original Message , III C. (USAFLS) Sent: Monday, May 19, 2008 3:37 PM To: Acosta, Alex (USAFLS); Subject: Re: confidential communication ) ; Original Message From: Acosta, Alex (USAFLS) To: (USAFLS); Campos, Cyndee (USAFLS); (USAFLS) Sent: Mon May 19 12:40:32 2008 Subject: FW: confidential communication For your records. From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com] Sent: Monday, May 19, 2008 10:54 AM To: Acosta, Alex (USAFLS) Subject: confidential communication Dear Alex: , (USAFLS) C. I am writing to you because I have just received the attached letter from Drew Oosterbaan. In light of that letter, and given the critical new evidence discussed below, I would like to request a meeting with you, mindful of our July 1026 08-80736-CV MARRA 002195 EFTA00227309 8 deadline, at your earliest opportunity. Given your personal involvement in this matter to date, and the fact that at this juncture it is clear that CEOS has referred the matter back to you, I respectfully request that you not shunt me off to one of your staff. You and I have both spent a great deal of time on this matter, and I know that we both would like to resolve this matter in a way that bestows integrity both on the Department and the process. In our prior discussions, you expressed that you were "not unsympathetic" to our various federalism concerns, but stated that because you serve within the "unitary Executive," you believed your hands were tied by Main Justice. You were also extremely gracious in stating that you did not want the United States to be "unfair". Although CEOS limited its assessment to the federal statutes your Office had brought forth and to the application of those laws to the facts as presented, it is abundantly clear from Drew's letter that Main Justice is not directing this prosecution. In fact, CEOS plainly acknowledged that a federal prosecution of Mr. Epstein would involve a "novel application" of federal statutes and that our arguments against federal involvement are "compelling." Moreover, the language used by Drew in his concluding paragraph, that he cannot conclude that a prosecution by you in this case "would be an abuse of discretion" is hardly an endorsement that you move forward. Moreover, as you know, Drew made clear that the scope of his review did not extend to the other significant issues we have raised with you, such as the undo interest by some members of your staff with the financial and civil aspects of this matter, or with the inappropriate discussion one member of your Office had with alSenior reporter at the New York Times. (In fact, I have met with that reporter and have reviewed copious notes of his conversation with Mr. Weinstein). At this stage, we have no alternative but to raise our serious concerns regarding the issues Drew refused to address with the Deputy or, if necessary, the Attorney General, because we believe those issues have significantly impacted the investigation and any recommendation by your staff to proceed with an indictment. That being said, it would obviously be much more constructive and efficient if we could resolve this matter directly with you in the advance of further proceedings in Washington. Because it is clear that national policy, as determined by Main Justice, is not driving this case, the resolution of this matter is squarely, and solely, your responsibility. I know you want to do the right thing, and it is because you have made clear to me on several occasions that you will always look at all of the relevant and material facts that I call the following to your attention. New information that has come to light strongly suggests that the facts of this case cannot possibly implicate a federal prosecutorial priority. Due to established state procedures and following the initiation of multiple civil lawsuits, Mr. Epstein's counsel was able to take limited discovery of certain women in this matter. The sworn statements provided by these women all confirm that federal prosecution is not appropriate in this case. The consistent representations of witnesses such as , Brittney Beale, , and , and the civil complainants and their attorneys, confirm the following key points: First, there was no telephonic 1027 08-80736-CV MARRA 002196 EFTA00227310 communication that met the requirements of § 2422(b). For example, as many other witnesses have stated, Ms. Beale testified in no unclear terms that there was never any discussion over the phone about her coming over to Mr. Epstein's home to engage in sexual activity: "The only thing that ever occurred on any of these phone calls [witan or another assistant] was, `Are you willing to come over,' or, `Would you like to come over and give a massage.'" Beale Tr. A at 15. Second, the underage women who visited Mr. Epstein have testified that they lied about their age in order to gain admittance into his home and women who brought their underage friends to Mr. Epstein counseled them to lie about their ages as well. Ms. stated the following: "I would tell my girlfriends just like Carolyn approached me. Make sure you tell him you're 18. Well, these girls that I brought, I know that they were 18 or 19 or 20. And the girls that I didn't know and I don't know if they were lying or not, I would say make sure that you tell him you're 18." Tr. at 22. Third, there was no routine or habit suggesting an intent to transform a massage into an illegal sexual act. For instance, Ms. Laduke stated that Mr. Epstein "never touched [her] physically" and that all she did was "massage[ ] his back, his chest and his thighs and that was it." Laduke Tr. at 12-13. Finally, as you are well aware, there was no force, coercion, fraud, violence, drugs, or even alcohol present in connection with Mr. Epstein's encounters with these women. The civil suits confirm that the plaintiffs did not discuss engaging in sexually- related activities with anyone prior to arriving at Mr. Epstein's residence. This reinforces the fact that no telephonic or Internet persuasion, inducement, enticement or coercion of any kind occurred. Furthermore, Mr. Herman, the attorney for most of the civil complainants, was quoted in the Palm Beach Post as saying that "it doesn't matter" that his clients lied about their ages and told Mr. Epstein that they were 18 or 19. In short, the new evidence establishing that the women deliberately lied about their age because they knew Mr. Epstein did not want anyone under 18 in his house directly undercuts the claim that Mr. Epstein willfully blinded himself as to their ages. Willful blindness is not a substitute for evidence of knowledge nor is it a negligence standard. It requires proof beyond reasonable doubt of deliberate intent and specific action to hide one's knowledge. There is absolutely no such evidence of that here, so it is not even a jury issue. Furthermore, willful ignorance cannot constitute the required mens rea for a crime of conspiracy or aiding and abetting. Through the recent witness statements, we have also discovered another serious issue that implicates the integrity of the federal investigation. We have learned that FBI Special Agent Kurkendayl attempted to convince these adult women, now in their twenties, that they were in fact "victims" even though the women themselves strongly disagreed with this characterization. This conduct, once again, goes to the heart of the integrity of the investigation. In a sworn statement, Ms. Beale was highly critical of the overreaching by federal law enforcement officers in this case. She testified—in no uncertain terms—that she does not, and never did, feel like a "victim," despite the fact that the FBI repeatedly tried to convince her otherwise. I am mindful of the fact that we have a state court date of July 8 on which either to enter a plea or to commence trial. As I review the trial options with 1028 08-80736-CV MARRA 002197 EFTA00227311 Mr. Epstein, I certainly want to make sure I do everything within my power to obviate a need for trial through a reasonable alternative resolution. Although it is clear that CEOS is not directing a prosecution here, and has stated only that you have the authority to commence such a prosecution, I am well aware that the decision whether to proceed, subject to any further process in Washington, is now within your discretion. I think the new facts should greatly influence your decision and accordingly, I hope you will agree to meet with me, both to discuss the new evidence and to discuss a resolution to this matter once and for all. I am available to meet with you at your earliest convenience subject to our mutual availability. Respectfully, Jay **************###44#*##*######################*#*44******** The information contained in this communication is confidential, may be attorney- client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e- mail to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. ******44####*##*###*####*********************************** 1029 08-80736-CV_MARRA 002198 EFTA00227312 C. (USAFLS) From: Sent: Thursday. August 14, 20084:21 PM To: 'I tk wit ki 'Roy BLACK' Cc: Subject: Dear Jay and Roy: ■ C. (USAFLS) Hearing with Judge Marra We just finished our hearing with Judge Marra. He has ordered us to make the Agreement available to the plaintiffs in this case pursuant to a protective order limiting the disclosure to the victims and their counsel only. He further has ordered that we have to make the agreement available to any other identified victim and her attorney, so long as they also agree to be bound by the protective order. Judge Marra stated that the plaintiffs can litigate the issue of further disclosure directly with Mr. Epstein in the context of their civil suits. When I receive the Court's order and a signed protective order, I will provide them to you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 234 08-80736-CV_MARRA 002199 EFTA00227313 1= • From: • C. (USAFLS) Sent: Thursday, August 14, 2008 3:27 PM To: Cc: ): Roy BLACK' Subject: E. Follow-up point C. (USAFLS) Dear Jay: The modification contained in the December letter is clear and simple, that is why we were not surprised by Mr. Epstein's and his attorneys' actions affirming acceptance of the modification. Mr. Epstein's acceptance of the modification by pleading guilty was equally clear and simple -- it followed written communications from Mr. Sloman and myself that read: "Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of' the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's December 19'h letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his sentence of imprisonment." As clearly stated in the December letter, only those "individuals whom [the United States] was prepared to name in an Indictment as victims of an enumerated offense" are the beneficiaries of the agreement. That is the list of names that I provided to Messrs. Goldberger and Tein following the change of plea. Under the September/October agreement, all "individuals whom [the United States] has identified as victims" are the beneficiaries, so I would prepare a supplement to the earlier list to include identified victims whom we were not yet prepared to name in an indictment. Again, as stated in the letter, the modification replaces paragraphs 7 and 8 of the Agreement, including paragraphs 7A through 7C that are included in the October Addendum. This means that Mr. Epstein's waiver of "his right to contest damages up to an amount as agreed to between the identified individual and Epstein" will no longer exist, nor will Mr. Epstein's obligation to pay for the victims' counsel. Paragraphs 9 and 10 are still in effect. This includes the statement that there is no admission of civil or criminal liability, and that, "[e]xcept as to those individuals who elect to proceed EXCLUSIVELY under 18 USC § 2255, ... Epstein's signature [cannot] be construed as admissions or evidence of civil or criminal liability." This addresses your question regarding exclusivity. I don't think that Mr. Epstein has to make any constructive admissions of conviction. He only needs to admit that the 32 girls whose names I have provided to Mr. Goldberger are "victims" of an offense listed in 18 U.S.C. 2255. Please let me know if you have any additional questions. Thank you. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Jay leficowItz [malltoaLeficowitz@kirldand.com] Seat: Thursday.,_Augua 14, 2008 2:39 PM To: MEM, C. (USAFLS) 236 08-80736-CV_MARRA 002200 EFTA00227314 Cc: ; lefkowitz@kirkland.com Subject: Re: Follow-up point - In reviewing your December proposal, there are a couple of things I don't understand. What limits are placed upon individuals who proceed under 2255 as if "Mr. Epstein had been tried federally and convicted of an enumerated offense." In other words, what individuals would have this right? And would these individual only have this right if they proceeded exclusively under 2255? Also, to what enumerated offenses do you think would Mr. Epstein have to make constructive admissions of conviction? and how many such offenses? And against whom? Remember that while you may have investigated various offenses, he only plead guilty to certain state crimes. Finally, would paragraphs 8-10 of the September Agreement still be operative? I am trying hard to understand what you have intended by the December letter. Alex has says he thinks it benefits Jeffrey, and I am open to understanding it that way. But I would like some clarity on these issues. Thanks — Jay n 08/142008 12'44 PM To clentowitzelkirktand.com, cc <Karen,Atkinson©usdoj.gov> Subject Follow:up pant Hi Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmasterakirkland.com, and 237 08-80736-CV_MARRA 002201 EFTA00227315 destroy this communication and all copies thereof, including all attachments. Tracking: 238 08-80736-CV_MARRA 002202 EFTA00227316 • C. (USAFLS) From: Jay Leflcowitz pLelkowitz©kirkland.com) Sent: 4, 2008 2:39 PM To: SAFLS) Cc: ); lefkowdz@kirkland.com Subject: e. of w-up point - In reviewing your December proposal, there are a couple of things I don't understand. What limits are placed upon individuals who proceed under 2255 as if "Mr. Epstein had been tried federally and convicted of an enumerated offense." In other words, what individuals would have this right? And would these individual only have this right if they proceeded exclusively under 2255? Also, to what enumerated offenses do you think would Mr. Epstein have to make constructive admissions of conviction? and how many such offenses? And against whom? Remember that while you may have investigated various offenses, he only plead guilty to certain state crimes. Finally, would paragraphs 8-10 of the September Agreement still be operative? I am trying hard to understand what you have intended by the December letter. Alex has says he thinks it benefits Jeffrey, and I am open to understanding it that way. But I would like some clarity on these issues. Thanks — Jay =Ma C. MIL & 08/1412006 12:44 PM To <StMagaggiitUiSeP cc • )" 1(fPn Atkimoneuscloi Q0V> Subject Follow-up Pont Hi Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 The information contained in this communication is confidential, may be attorney-client privileged, may 246 08-80736-CV_MARRA 002203 EFTA00227317 constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. 247 08-80736-CV_MARRA 002204 EFTA00227318 C. (USAFLS) From: .. C (USAFLS) Sent: Thursday. August 14, 2008 1243 PM To: I tk wit 1 6.16.. (1 m Cc: ) Subject: Follow-up point Ili Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 250 08-80736-CV_MARRA 002205 EFTA00227319 C. (USAFLS) From: C (USAFLS) Sent: Thursday, August 14, 2008 12 28 PM To: Jay Lefkowitz Subject: RE: Telephone Call Fine. A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm