DARREN K. INDYKE

DARREN K. INDYKE Darren K. Indyke, PLLC 575 Lexington Avenue, ilth Floor New York, New York 10022 Telephone: Telecopier: email: January 10, 2014 VIA FACSIMILE ( 1.1.) AND CERTIFIED MAIL. RETURN RECEIPT REOUESTED Alan P. Fraade, Esq. Mintz & Fraade, P.C. 488 Madison Avenue New York, NY 10022 Re: Steven Jude Hoffenberg Dear Mr. Fraade: I represent Mr. Jeffrey Epstein. It has come to my attention that your client, Steven Jude Hoffenberg, has been attempting to gain access to the premises at 9 East 7 is' Street, New York, New York in an unsolicited attempt to confront Mr. Epstein. In the past week alone, Mr. Hoffenberg approached the premises on at least two occasions. On the first occasion, on January 7, 2014 at approximately 8:15PM, Mr. Hoffenberg, accompanied by a large-built unidentified male, rang the doorbell at the premises falsely claiming to be an associate of Mr. Epstein and requesting entry. He became agitated and vocal when he could not gain entry. After continuing to watch the premises from his vehicle for a period of time, he ultimately left. Last night, January 9, 2014, shortly before 9 PM, Mr. Hoffenberg again attempted to gain entry to the premises, this time carrying a suspicious package with him that he sought unsuccessfully to slip under the entry door. As Mr. Hoffenberg's counsel, I am sure you are well aware that Mr. Hoffenberg is a convicted felon, as is Mr. Epstein. I understand that Mr. Hoffenberg remains on supervised release and presume that, consistent with the "standard" conditions set forth in Section 5B1.3(c)(9) of the Federal Sentencing Guidelines, his efforts to communicate with another convicted felon are a serious violation of the conditions of his supervised release. EFTA00583986 Alan P. Fraade, Esq. Mintz & Fraade, P.C. January 10, 2014 Page 2 I have received a copy of your letter to Mr. Epstein dated October 23, 2013 transmitting what Mr. Hoffenberg called his "Working Draft Memo", which Mr. Hoffenberg has now published on the intemet. In this document and numerous other documents and web pages published on the internet by Mr. Hoffenberg, all of which are replete with Mr. Hoffenberg's spurious and libelous allegations against Mr. Epstein, as well as unfounded threats of Mr. Epstein's civil and criminal prosecution, Mr. Hoffenberg has made it abundantly clear that he is singularly committed to exacting financial payment from Mr. Epstein by any means necessary: We are moving aggressively to collect your billions of dollars, from our multi- billionaire partner Jeffrey Epstein. * * * Steven Hoffenberg was released and is assisting us 24/7. After spending 18 years in Federal Prison his only mandate is to pay the 200,000 victims full restitution including interest. Towers Investors website (http://www.towersinvestors.com/category/towers-financial- updates°. In addition to the foregoing, Mr. Hoffenberg has been characterized by his sentencing judge to be an "unstable individual with manic tendencies" and "a history of mental illness." Under the circumstances, Mr. Hoffenberg's aggressive efforts to gain access to both Mr. Epstein and 9 East 71g Street in the evening hours, well after the close of business, and in apparent violation of Mr. Hoffenberg's parole are of genuine concern. Mr. Epstein's attorneys have instructed him not to meet, communicate or have any contact whatsoever with Mr. Hoffenberg under any circumstances. In addition, Mr. Hoffenberg's uninvited visits to 9 East 71g Street have caused occupants and employees at the premises to feel harassed and in serious fear for their own safety as they enter and exit the building. Accordingly, demand is hereby made that your client immediately cease and desist from any further efforts to access the premises or contact Mr. Epstein, failing which we will have no alternative but pursue all legal avenues available to protect Mr. Epstein and his employees from Mr. Hoffenberg's harassing conduct. Very truly yours, Darren K. Indyke EFTA00583987