Fowler White Burnett

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DOJ Data Set 9

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efta-efta00724534

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EFTA Disclosure

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Fowler White Burnett ATTORNEYS AT LA V June 22, 2010 Charles H. Lichtman, Esq. Berger Singerman PA 350 E. Las Olas Blvd., Suite 1000 Ft. Lauderdale, FL RE: Epstein v. Rothstein Dear Mr. Lichtman: 901 Phillips Point West m South Flagler Drive West Pain) Beach, Florida 33401 wwwlowler-while.corn Rodney J. Janis direct In light of your recent decision not to produce any emails as it relates to the Epstein v. Rothstein subpoena, please provide us a privilege log for the same. In addition, since the emails only encompass a very small portion of the requested items in our subpoena of April 16, 2010, please immediately provide the remaining items requested in the subpoena. If you decide to claim a privilege for any remaining items, please note that the subpoena in question was properly served over two months ago, with no objections filed and no privilege log filed within the time specified by the rules. In addition, as you know, it has come to our attention that there may be a fabricated settlement agreement, to the tune of $200 million dollars, relating to Jeffrey Epstein. Mr. Epstein has never settled any case for anywhere near that amount of money. We have reason to believe that this fabricated settlement agreement is contained in the documents held by the Trustee. I'm sure you can understand the obvious importance of this document to Mr. Epstein. If you want to claim a privilege on the emails, then we can have the Judge decide if that's proper, however, I see no basis for refusing to turn over, or claiming a privilege for, a purported fabricated document. This item, and similar items, were.requested in our April 16, 2010 subpoena and I'd like to make arrangements to obtain this document immediately. As we've mentioned to you, Drew Hinkes and Luis Torres, we are ready to pay the reasonable costs involved to obtain these documents; the Bankruptcy Court has approved a document inspection protocol; the Bankruptcy Court has addressed the privilege issue; and thus we see no reason why your office will not comply with our subpoena. We have set a Motion to Compel for hearing in front of Judge Crow for next week, for which you have already received notice, and please accept this as our attempt to amicably resolve these issues without the need for court intervention. cc: Jack Goldberger Miami • Fort Lauderdale • West Palm Beach EFTA00724534

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Rol Slack lir „kite' 2/949 Arcrwite a." 2434 7 Antai, Liu) 3 cut, , 4,/e EFTA00183732 KIRKLAND & ELLIS LLP AND AfilL/ArtO PART/H.3We; ' Cntercup Cantor 163 East 53'd Street New York, New York 10022-4611 WNW rwerA.COM September 2, 2008 VIA FACSIMILE (56D 820-8777 United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re:Jeffrey Bpstein Dear • Facsimile: In response to your letter dated August 26, 2008, I am confirming that Mr. Goldberger should continue to be listed as the contact pawn in the' mended victim notification letters and should receive the carbon copies of thoso letters as they are sent. • Also, we plan on speaking to Mr. Josofsberg this week to discuss a procedure for paying his fees. We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Josfsberg's usual and customary hourly rates for his work pursuant to the agreement facilitating settlements unde

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