Correspondence, 2019-08-27

Document EFTA 02735316¶

GT GreenbergTraurig¶

Stephen A. Mendelsohn • Tel 561.955.7629 Fax 561.659.9119 mendelsohnS09tlaw.Chni¶

August 27, 2019¶

VIA EMAIL and OVERNIGHT_MAIL¶

State Attorney Dave Aronberg 401 N. Dixie Highway West Palm Beach, Florida 33401 Email: daronberu@sa15.state.fl.us¶

Re: Your No. 2019PRO00389AMB — Jeffrey Epstein/The Palm st Records Request¶

Dear State Attorney Aronberg:¶

Greenberg Traurig, P.A. represents The Palm Beach Post in connection with its public records requests for Jeffrey Epstein documents compiled during your predecessor Barry Krischer’s tenure.¶

You may not be aware that on July 15, 2019, The Palm Beach Post reporter Jane Musgrave submitted an initial Florida Public Records Law request for Epstein documents to the Office of State Attorney. A copy of her request is eaCT’ed. Also on July 15, 2019, Lulu Ramadan, who is also a reporter for the newspaper, mad L ecoarequest, which is enclosed as well. c i’ep¶

We understand that on July 22, 204 ,yo ffice provided a thumb drive to The Palm Beach Post containing 24 numbered files. After a review of these documents, the newspaper determined that certain documents responsive to its reporters’ requests have not been produced, although your office has not asserted a statutory exemption. On August 6, 2019, Ms. Musgrave emailed Public Information Officer Mike Edmondson and advised that specific documents in your files have not been produced. Her email is enclosed. Unfortunately, she has not received a response. On August 14, 2019, Ms. Musgrave entailed Mr. Edmondson and asked for copies of (1) a memo purportedly written by Epstein attorney Alan Dershowitz to Mr. Krischer or his assistants, and (2) a “close-0Ut-memo” in reference to Jane Doe 3 ( )• A copy of this email i e° closed. On August 19, 2019, your office sent Ms. Musgrave a form letter indicating that it w Iiiiigently” working on her August 14th request, and assigned it the above number.¶

Beca f the public importance of this matter, we reiterate The Palm Beach Post’s request that the following documents be produced as expeditiously as possible:¶

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• Memos, emails, communications in any form from the State Attorney’s Office describing a plea offered to Epstein in April 2006.
• Memo from Alan Dershowitz to Barry Krischer that alleges that most men in South Florida charged with crimes similar to Jeffrey Epstein have received probation.
• Emails exchanged between Barry Krischer, Assistant State Attorneys and the attorneys within the office of the United States Attorney for the Southern Districkpf Florida or the United States Department of Justice concerning Jeffrey Epstein.
• De osition transcripts of and Britanny

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Moreover, the following documents were not part of your office’s prdt ic6gh, but we have reason to believe that they should be in its files:¶

• Notes, records and related correspondence of 2006, February 16, 2006 and June 1, 2006 meetings with attorneys Krischer’s office and Jeffrey Epstein’s defense attorneys.
• Notes, records and related correspon neeming the FBI’s visit to Barry Krischer in November or December 2007 Ib e the FBI purportedly sought to have Mr. Krischer take steps to render Epstein ineligible for work release. Notes and records of meetings and communications concerning .M-re Epstein with Palm Beach Police Chief Michael Reiter, Palm Beach Detective Recarey, and Epstein defense at orneysipcluding but not limited to Guy Fronstin, Alan Dershowitz, Jack Goldberger, y B ck, Jay LefkoWitz and Gerald Lefcourt.
• Notes rds of meetings and communications concerning Jeffrey Epstein with AUS illafana, AUSA Matthew Menchel, AUSA Andrew Louric and US Aft ey Ale Acosta. d records of meetings and ‘communications with Epstein victims and/or S Communications between Barry Krischer and Assistant State Attorney Lanna Belohlavek and other State Attorneys concerning plea negotiations and a possible plea deal with Jeffrey Epstein, as well as communications concerning the submission of the case to a grand jury. IS.
• Copies of drafts of Palm Beach Detective Epstein. Recarey’s arrest warrants for Jeffrey

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Finally, The Palm Beach Post has also asked for the age of the victikwhg was the basis for the charge against Epstein of solicitation of a minor for prostitution. The newspaper was told by your office that her date of birth is in the records produced, but a careful search by our client has not uncovered that date. As we understand that your office e this date to the Washington Post, we request that it be provided to our client as well.¶

We thank your office for the effort it has maden)proaacing the documents to date, but arc compelled to reiterate the newspaper’s request for the remaining documents and ask that they be produced as soon as practicable given the i rtant public issues they implicate and, presumably, will illuminate.¶

We appreciate your cooperation.¶

Very truly’ yours,¶

Stephen Mendelsohn ti peir¶

Enclosures¶

cc: Mete n elhardt In tiga ive Team Editor The Palm Beach Post¶

Ms. Holly Baltz Senior Editor, Investigations The Palm Beach Post

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• Correspondence or documents pertaining to Mr. Krischer’s’ knowledge of and/or participation in the Epstein non-prosecution agreement negotiated by federal prosecutors.
• Correspondence or documents concerning communications between the State Attorney’s Office and Kirkland & Ellis attorneys pertaining to the investigation, prosecution, and sex offender classification of Jeffrey Epstein.
• Correspondence or documents concerning communications between the State Attorney’s Office and Manhattan (New York) prosecutors Jennifer Gaffney and Egan pertaining to the investigation, prosecution, and sex off classification of Jeffrey Epstein.

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