EFTA00151746¶
Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?¶
Thanks,¶
Subject: Re: Epstein investigation /¶
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¶
Please excuse typographical errors. Messages sent through dictation.¶
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On Jul 10, 2019, at 11:20 AM, Michael Bachner¶
EFTA00151747¶
Sure.¶
Michael Bachner¶
Bachner & Associates, PC¶
39 Broadway-Suite 1610¶
Please excuse typographical errors. Messages sent through dictation.¶
<~WRD000.jpg>¶
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,¶
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?¶
From: Michael Bachner ↵¶
Sent: Wednesday July 10 2019 10:25¶
Subject: Re: Epstein investigation /¶
Dear Counsel:¶
I met with and I need time to evaluate matters. Regarding the subpoena to testify before the Grand Jury on July 24, 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,¶