SDNY and defense counsel emails scheduling a reverse proffer, July 2019

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From: ‘
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Cc: ‘	iSIIYS ”		, “	SANYS “
Subject: Re: Epstein investigation
	Date: Mon, 15 Jul 2019 18:48:33 +0000
Importance: Normal
Hey- we are scheduling a reverse proffer fo	been arrested, but this is a different client, so wires crossed here).	(I think	quick first read was that	might have
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On Jul 15, 2019, at 2:31 PM,		) <i< td="">	> wrote:		> wrote:
Begin forwarded message:
From: Michael Bachner Date: Jul 15 2019 at 2: 8:5
To: “
Cc: ‘
Subject: Re: Epstein investigation A

I was just notified that a client was arrested and is being arraigned in Queens County tomorrow on a state RICO charge at about 11 or 1130. I’m concerned that the 330 may be cutting it close. It may be better to do it at four or on Wednesday. Please advise¶

Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York NY 10006¶

ease excuse typographical errors. Messages sent through dictation. Ir¶

https://www.actl.com/¶

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On Jul 15, 2019, at 1:55 PM,	> wrote:
Thanks very much. Let’s plan for tomorrow at 3:30pm. You and Andrews and just give security my name.	an come to our office at 1 St.
Best.

Assistant United States Attorney Southern District of New York 1 St. Andrew’s Plaza New York. NY 10007¶

Original Message---
From: Michael Bachner
Sent: Monda Jul	15, 2019 1:42 PM
To:
Cc:
Subject: RE: Epstein investigation
Hi

Tomorrow or Wednesday at 11 or 3:30. Thursday any time after 11:30 to 4.¶

https://www.actl.com/¶

Michael Bachner, Esq. Bachner & Associates, PC 39 Broadway, Suite 1610 New York NY 10006¶

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Original Message ) mailto: From: Sent: Monday, July 15.2019 12:50 PM To: Michael Bachner Cc:
Subject: Re: Epstein investigation.
Hi Michael,
Apologies for the delay. Would you please let us know what times would work for you and next two or three days? We’ll then figure out a time when we can all meet.	n the
Thank you
>> On Jul 11, 2019, at 10:43 PM, Michael Bachner wrote:
6 o’clock is somewhat late. The client lives in Hello
Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610
New York, NY 10006

Please excuse typographical errors. Messages sent through dictation. [X]¶

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NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.¶

On Jul 11, 2019 at 9:01 PM,
	mailto:	> wrote:

Michael,¶

Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?¶

Thanks,¶

Assistant United States Attorney Southern District of New York 1 St. Andrew’s Plaza New York, NY 10007¶

mailto:¶

Regarding the reverse proffer, We are available next week from the 15-18. I have a 2 o’clock meeting in my office on the 16th and 17th that should last an hour. So I can meet with you on those days at 11 or 1030 in the morning if that works. Please let me know¶

Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York, NY 10006¶

Please excuse typographical errors. Messages sent through dictation. c—WRD000.jpg>¶

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NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.¶

On Jul 10, 2019, at 11:20 AM, Michael Bachner wrote:¶

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Sure.¶

Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 6¶

Please excuse typographical errors. Messages sent through dictation. <—WRD000.jpg>¶

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NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.¶

On Jul 10 2019, at 11:08 AM,
	mailto:	> wrote:
Mike,

I think it would be useful to get a better understanding of your position—it would be helpful for us to know, for example, how much time you propose to take to evaluate matters, and whether we can provide any additional information that might be useful for that process of evaluation. That likely will affect our determination regarding the grand jury appearance, at which we would expect, were we to call to ask her a number of questions we would expect to argue to the court do not implicate a fifth am n m n privilege—i.e., that she couldn’t simply blanket invoke. Would it be useful to discuss via phone?¶

thanks, Alex.¶

From: Michael Bachner
Sent: Wednesda Jul	10 2019 10:25
To:
Cc:
Subject: Re: Epstein investigation

Dear Counsel:¶

I met with and I need time to evaluate matters. Regardin the sub ena to testify before the Grand Jury on we hereby notify you that if called as a witness ould invoke her Fifth Amendment privilege against compelled self-incrimination. Please let me now if you will require her to invoke in person or whether this communication suffices and no appertaining will be required.¶

Yours truly,¶

Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York, NY 10006¶

Please excuse typographical errors. Messages sent through dictation. <—WRD026.jpg>¶

https://www.actl.com/¶

NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.¶

•¶

Mr. Bachner,¶

Following up on our conversation earlier this morning, we wanted to provide you with the additional information and materials we discussed. In the first instance, so that you have full contact info for the team, please feel free to reach out to any of us at any time; we’re all available via email or at the following phone numbers:¶

Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in Florida, and a blank version of our standard proffer agreement, both as discussed.¶

As we mentioned, please don’t hesitate to reach out with any questions, and we look forward to setting a time to speak again after you’re able to confer with¶

Assistant U.S. Attorney £outhern_District of New York¶

<Epstein NPA, dated 2007-09-24.pdf>¶