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Law Offices of¶
SALNICK, FUCHS & BERTISCH, P.A.¶
Michael Salnick*¶
Jack K. Fuchs¶
Flynn P. Bertisch¶
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Board Certified Criminal Trial Lawyer
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Member of Colorado, District of Columbia and New York Bars
Jennifer L. Shand¶
Certified Legal Assistant¶
MEMO¶
DATE: JANUARY 19, 2007¶
FROM: MICHAEL SALNICK¶
TO: – Assistant United States Attorney¶
RE: Our Client: Janusz Banasiak¶
Thank you for speaking with me this afternoon regarding this matter. I know that during our phone conversation you indicated that my client is not a target. In the spirit of being thorough, I want to confirm that he is a witness and nothing else.¶
When we got off the phone, I began to feel somewhat uneasy with the standard immunity letter. That is in no way a reflection on you, but more my discomfort with what protection that would really provide him. I would please request that you reconsider and offer my client a formal grant of immunity. I realize that requires a procedure within your office, but that would make the situation more comfortable. If this occurs, my client would certainly tell the truth to the extent of his knowledge.¶
Please give this some thought so that we can discuss this next week. Have a nice weekend.¶
3507-005¶
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U.S. Department of Justice¶
United States Attorney¶
Southern District of Florida¶
500 South Australian Ave., Suite 400¶
West Palm Beach, FL 33401¶
(561) 820-8711¶
Facsimile: (561) 820-8777¶
January 23, 2007¶
Re: Federal Grand Jury Subpoena¶
Dear Michael:¶
I am in receipt of your letter regarding Janusz Banasiak. As I mentioned earlier, Mr. Banasiak is not a target of the grand jury investigation and he has been subpoenaed solely as a witness. During our last conversation, you stated that Mr. Banasiak would be willing to speak with investigators pursuant to a Kastigar letter. Please let me know if that is the case and, if so, when you and Mr. Banasiak are available.¶
My office would rightly question why I would ask for immunity for a person who I feel faces no criminal exposure, so, if that remains your position, I would like to discuss the matter further.¶
I look forward to your response.¶
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