EFTA00068043¶
On Jul 10, 2019, at 11:20 AM, Michael Bachner¶
Sure.¶
Please excuse typographical errors. Messages sent through dictation.¶
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 e-mail 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,¶
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 amendment privilege—i.e., that she couldn’t simply blanket invoke. Would it be useful to discuss via phone?¶
thanks,¶
Dear Counsel:¶
EFTA00068044¶
I met with and I need time to evaluate matters. Regarding the subpoena to testify before the Grand Jury on we hereby notify you that if called as a witness would invoke her Fifth Amendment privilege against compelled self-incrimination. Please let me know if you will require her to invoke in person or whether this communication suffices and no appertaining will be required.¶
Yours truly,¶
Michael Bachner¶
Please excuse typographical errors. Messages sent through dictation.¶
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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 e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.¶
On Jul 9, 2019, at 11:43 AM,¶
wrote:
¶
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¶
thank you,¶
Assistant U.S. Attorney Southern District of New York¶
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<Epstein NPA, dated 2007-09-24.pdf>¶
EFTA00068046¶