| From:                           |                                 |
|---------------------------------|---------------------------------|
| To:                             |                                 |
| Subject: FW: SDNY investigation |                                 |
| Date:                           | Wed. 30 Sen 2020 20:14:04 +0000 |
| Attachments:                    | (CMA)_-yol._1_-_12-04-09.pdf;   |

## Team,

Attached are the transcripts of :repositions. I'd like to schedule a team call for Friday to discuss them. Does 10 a.m. Friday work for everyone for a call to discuss? If you need more time to review them, let me know and we can push to Monday.

Thanks,

From: Weinstein, Marc A. Sent: Wednesday, September 30, 2020 1:52 PM

To:

Cc: Andrew Tomback

Subject: RE: SDNY investigation



The transcripts are attached. We trust that the US Attorney's Office will keep these confidential other than to the extent disclosure is required in any pending case.

Regards, Marc

# Marc A. Weinstein I Partner

Chair. White Collar Defense

Hughes Hubbard & Reed LLP

individual named. If you are not the named addressee you should not • , <I:0y by e-mail if you have received this e-mail by mistake and delete this amail Oill your system. E-mail tranSillisSiOn cannot be guaranteed to be secure or error-free as information could be intercepted. corrupted. lost. destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message. which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

# From: Weinstein, Marc A.

Sent: Wednesday, September 30, 2020 12:03 PM

To:

Cc: Andrew Tomball

# Subject: RE: SDNY investigation

connected with Jack Scarola last week. I just sent him an email to confirm that we can provide you with the transcript. Once we receive confirmation from him, we will send you the transcript.

## Best regards,

Marc

# Fro

Sent: Tuesday, September 29, 2020 3:40 PM To: Weinstein, Marc A

Cc: Andrew Tomback

. .

(CAUTION: This email was sent by someone outside of the Firm.

# Hi Marc,

Hope you're doing well. I wanted to check in on the status of this issue — have you been able to connect with Mr. Scarola?

Thanks,

| From: Weinstein, Marc A                                     |  |
|-------------------------------------------------------------|--|
| Se tember 22 2020 4:54 PM<br>Sent: Tuesda                   |  |
| To                                                          |  |
| Cc: Andrew Tombac                                           |  |
|                                                             |  |
| Subject: RE: SDNY investigation                             |  |
| I will give him a call.<br>Thanks                           |  |
| Marc A. Weinstein I Partner<br>Chair. VThite Collar Defense |  |
| Hughes Hubbard & Reed LLP                                   |  |
|                                                             |  |
|                                                             |  |

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

From:

Sent: Tuesday, September 22, 20204:42 PM To: Weinstein, Marc A Cc: Andrew Tomback

# Subject: RE: SONY investigation

## CAUTION: This email was sent by someone outside of the Firm.

### Marc,

Thanks for following up on this. If it's okay with you, I think it makes sense to connect you with the plaintiff's attorney, Jack Scarola, so that he can convey this to you directly. I have spoken with him and explained the context here, and he has told me that he would be happy to speak with you. He is also seeking a copy of the transcript, as he has informed me that he no longer has his case files for matters this old. Here is his contact information:

#### Jack Scarola

#### Thank you,

To

From: Weinstein, Marc A. Sent: Tuesday, September 22, 2020 11:24 AM

Cc: Andrew Tomback

Subject: RE: SDNY investigation

We haven't found a governing protective order, but to be safe, would you be able to get a letter or email fro attorney stating that they are not aware of a protective order/agreement governing the disclosure of the transcrip , an to the extent one existed, they are waiving any provisions in order to permit the Estate to provide the transcript to the US Attorney's Office, and that they will not claim, in any forum, that the Co-Executors, the Estate, or any representatives of either, breached any such order/agreement in that case by providing the transcript to the US Attorney's Office.

Let us know if that works on your end.

Best regards, Marc

Marc A. Weinstein I Partner Chair. White Collar Defense

This message conta.cs cc -ifict ntra. information. arc is intended only for tne individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

Sent: Monday, September 14 2020 3:01 PM

To: Weinstein, Marc A Cc: Andrew Tomback

# Subject: RE: SDNY investigation

# CAUTION: This email was sent by someone outside of the Firm.

Hi Marc,

Thanks — we have conferred with plaintiff's counsel, who has informed us that he is unaware of any protective order relating to th awsuit.

Best,



Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York NY 10007

From: Weinstein, Marc A. Sent: Monday, September 14, 2020 12:07 PM To:

Cc: Andrew Tomback

#### Subject: Re: SDNY investigation

we are still looking to see what confidentiality restrictions might apply. If her lawyer has any such confidentiality or protective order that governed the case, it might be helpful if you could obtain and share that.

# Marc A. Weinstein I Partner

Chair. Mile Collar Defense

Hughes Hubbard & Reed LIP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, late or incomplete, or t :7 V rt. l :i"r rc does not accept liability for any errors or omissions in the contents of this !e as a result of r -cd please request a hard-copy version. On Sep 14, 2020, at 11:56 AM wrote:

CAUTION: This email was sent by someone outside of the Firm.

Marc,

Thanks very much. Are you able to provide it to us? If there are any issues with providing it to us, or if a call would be useful to discuss, please let us know.

Thanks,

| From: Weinstein, Marc A. <<br>Sent: Monday, September 14, 2020 11:51 AM<br>To:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
| Cc: Andrew Tombac                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  |
| Subject: RE: SDNY investigation                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  |
| we have the transcript of<br>deposition.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  |
| Regards,<br>Marc                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  |
| Marc A. Weinstein I Partner<br>Chair. White Collar Defense                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  |
| Hughes Hubbard & Reed LLP                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |
| This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not<br>disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e<br>mail from your system. E oral transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,<br>--fete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this<br>destroyed, arrive<br>of e-mail transmission If verification is required please request a hard-copy version.<br>message which |  |
| From:<br>Sent: Friday, September 11 2020 1:40 PM                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  |
| To: Weinstein, Marc A<br>Cc: Andrew Tomback <                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  |
| Subject: RE: SDNY investigation                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  |
| CAUTION: This email was sent by someone outside of the Firm.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  |
| Thanks, Marc. We'll look forward to hearing from you, and thanks for your assistance with this.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  |
| From: Weinstein, Marc A.<br>To                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |
| Cc: Andrew Tombac<br>u ject: RE: DNY investigation                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  |
| It wasn't clear to me from the call that it was the plaintiff's deposition that you were after, as opposed to<br>Thanks                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  |

another witness in the case. Now that it's clear, we will see if we can track it down.

Regards,

# Marc A. Weinstein I Partner

Chair, While Collar Defense

# Hughes Hubbard & Reed LLP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

From:

Sent: Friday, September 11, 20201:30 PM To: Weinstein, Marc A

Subject: RE: SONY investigation

CAUTION: This email was sent by someone outside of the Firm.

Marc,

Thanks for speaking earlier. The plaintiff's name ism who is represented by Jack Scarola. The deposition took place in 2009, and Jeffrey Epstein was represented by Mark Luttier and Bob Critton of Critton, Luttier, and Coleman LLP in West Palm Beach.

Thanks very much,



Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007

From: Weinstein, Marc A. Sent: Friday, September 11, 2020 11:11 AM

To:

Cc: Andrew Tomback

Subject: RE: SDNY investigation

I just realized that you didn't share with us the deponent's name for the transcript you are looking for. Let us now so that we can make the appropriate inquiries.

Best regards, Marc

# Marc A. Weinstein I Partner

Chair. White Collar Defense

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this er I cr 'r' . -'• r ' 'r' ' r' - 'r' • • r • r'r''' ' `'• ' satanteed to be secure or error-free as information could be intercepted, corrupted, lost, 2 sender therefore does not accept liability for any errors or omissions in the contents of this ,orification is required please request a hard-copy version.

#### Fro

Sent: Thursday, September 10, 2020 11:14 AM To: Weinstein, Marc Cc: Andrew Tomback

Subject: RE: SDNY investigation

CAUTION: This email was sent by someone outside of the Firm.

That works well, thanks very much. Talk to you then.

From: Weinstein, Marc A Sent: Thursday, September 10, 2020 11:13 AM To: Cc: Andrew Tombac Subject: Re: SDNY investigation cif 11:00 works, I can send a dial-in.

Marc A. Weinstein I Partner

Clay Virnto Co lar Dli gt'ISI2

Hughes Hubbard & Reed LLP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this 'T' 2 ' ' "J .' • 2 • !•• ' '• ' •••• cf. transmission. If verification is required please request a hard-copy version.

On Sep 10, 2020, at 10:46 AM, wrote:

CAUTION: This email was sent by someone outside of the Firm.

Andy and Marc,

Are you available for a brief call tomorrow? I'm available before 1 p.m., if there's a time that works for you in that window.

Thanks very much,



Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007