From: "Martin Weinberg" <

From: "Martin Weinberg" < To: Jeffrey Epstein Cc: "Weinberg, Martin" Subject: ATTORNEY-CLIENT PRIVILEGE Date: Mon, 22 Feb 2010 20:32:02 +0000 Was on blackberry My view is (a) we cannot file decl judg action unless we can represent that USAO will not agree that we can file principled motions to dismiss without fear of their declaring breach so we need to first write a letter informing them that the issues Roy, Alan and I raised regarding 2255 and civil litigation rights are no longer advisory or speculative - they are ripe (b) my current thinking is that we should then file the decl judg as a related case to Jane Doe 103 Martin G. Weinberg, Esq. 20 Park Plaza, Suite 1000 Boston, MA 02116 cell This Electronic Message contains information from the Law Office of Martin G. Weinberg, M., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. Original message from Jeffrey Epstein why not dec action? On Mon, Feb 22, 2010 at 2:43 PM, < > wrote: Better standing if jd103 claims 3d p benef which I would expect Issues now ripe We should draft out mtd issues once we see complaint and write to usao that the futurte is now the present Sent from my Verizon Wireless BlackBerry From: Jeffrey Epstein Date: Mon, 22 Feb 2010 14:02:55 -0500 To: Martin Weinberg< Subject: why don't we simply file the dec action , and send a copy to the usao and ask if we can file the mtd.. they said they did not want to give and advisory opinion , because ther was nothing ripe.. now there is. PROT0 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 Jeffrey Epstein 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 and destroy this communication and all copies thereof, including all attachments. 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 Jeffrey Epstein 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 , and destroy this communication and all copies thereof, including all attachments. PROT1