U.S. Department of Justice

EFTA01338095

01/19/2007 16:48

01/19/2007 16:48 5616590793 PAGE 01 SAL.NICK. FUCHS & BERTISCH, P.A. Mithael SsMick • Jack K. Fuchs Flynn P. Bertsch • Bard Cs*NW Criminal Trial Infer • member of Cant Dint d Cobans and Now York Bats Jennifer L. Shand Cared Leg& Natant MEMO (1) Page Fax: - AUSA DATE: JANUARY 19, 2007 FROM: MICHAEL SALNICK TO: — Assistant United States Attorney RE: Our Client: Janusz Banasiak Far E-mak: Thank you for speaking with me this afternoon regarding this matter. I know that during our phone conversation you indicated that my client is not a target. In the spirit of being thorough, I want to confirm that he is a witness and nothing else. When we got off the phone, I began to feel somewhat uneasy with the standard immunity letter. That is in no way a reflection on you, but more my discomfort with what protection that would really provide him. I would please request that you reconsider and offer my client a formal grant of immunity. I realize that requires a proced

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: (561) 820-8777 January 24, 2007 DELIVERY BY FACSIMILE AND HAND Michael Salnick One Clearlake Centre 250 South Australian Avenue Suite 1203 West Palm Beach, FL 33401-5014 Re: Janusz Banasiak Dear Mr. Salnick: I am writing to clarify the ground rules for the interview with your client, Janusz Banasiak ("your client"), to occur January , 2007. As I mentioned earlier, Mr. Banasiak is not a target of this investigation. However, to address your concern about criminal exposure, if your client complies with every provision of this agreement, then the United States Attorney's Office for the Southern District of Florida ("this Office") will treat all statements made by your client during said debriefing as statements made pursuant to Rule 11(f) of the Federal Rules of Criminal Procedure. This is not a grant of immunity, w

Petty cash

0 0 r i953 Petty cash - Opening balance Ending balance Date 11/29/2006 1/2/2007 Amount $1,965.43 $120.77 Date Payee Amount Description Deposit Balance 1 11/9/2006 Starbucks $7.41 Coffee $1,958.02 2 11/12/2006 Subway Sandwiches $6.16 Meal $1,951.86 3 11/13/2006 Starbucks $3.41 Coffee $1,948.45 4 11/13/2006 Hale $ Hearty $8.44 Meal $1,940.01 5 11/14/2006 Hale $ Hearty $8.44 Meal $1,931.57 6 11/14/2006 Starbucks $3.41 Coffee $1,928.16 7 11/14/2006 The Container Store $4.19 Scotch tape $1,923.97 8 11/14/2006 The Container Store $8.65 Gift labels $1,915.32 9 11/14/2006 Walgreens $7.49 Medicine $1,907.83 10 11/14/2006 Duane Reade $6.39 Medicine $1,901.44 11 11/15/2006 Hale $ Hearty $8.44 Meal $1,893.00 12 11/16/2006 Gristede's $27.94 Groceries $1,885.06 13 11/16/2006 Starbucks $3.41 Coffee $1,861.65 14 11/16/2006 Starbucks $3.41 Coffee $1,858.24 15 11/16/2006 Hale $ Hearty $8.44 Meal $1,849.80 16 11/18/2006 Hale $ Hearty $8.4

EFTA Document EFTA01338095

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! Facsimile: February 2, 2007 DELIVERY BY HAND Michael Salnick One Clearlake Centre 250 South Australian Avenue Suite 1203 West Palm Beach, FL 33401-5014 Re: Janusz Banasiak Dear Mr. Salnick: I am writing to clarify the ground rules for the interview with your client, Janusz Banasiak ("your client"), to occur today, February 2, 2007. As I m

Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70

Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70 EXHIBIT A PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS EFTA00208682 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70 PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged Objection General Objections -- Inadequate Privilege Log Failure to Prove Factual Underpinnings of Privilege Claim Waiver of Confidentiality Government's Fiduciary Duty to Crime Victims Bars Privilege Communications Facilitating Crime-Fraud-Misconduct Not Covered Factual Materials Not Covered Documents Not Prepared in Anticipation of CVRA Litigation Attorney Client Objections - Ordinary Governmental Communications Not Covered Attorney-Client Relationship Not Established Deliberative Process Objections - Privilege Not Properly Invoked Final Decision Exempted from Privilege Qualified Privilege Ove