# MARTIN G. WEINBERG, P.C.
ATTORNEY AT LAW



20 PARK PLAZA, SUITE 1000

BOSTON, MASSACHUSETTS 02116



EMAIL ADDRESSES:



July 22, 2011

Assistant United States Attorney

United States Attorney’s Office

Southern District of Florida

500 S. Australian Ave. Suite 400

West Palm Beach, Florida 33401

Re: Jeffrey Epstein

Dear Ms.

Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the NPA. Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order.

Very truly yours,

Martin Wanling KC

Martin G. Weinberg

cc: Roy Black

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# MARTIN G. WEINBERG, P.C.
ATTORNEY AT LAW



20 PARK PLAZA, SUITE 1000

BOSTON, MASSACHUSETTS 02116



EMAIL ADDRESSES:



July 22, 2011

Assistant United States Attorney

United States Attorney's Office

Southern District of Florida

500 S. Australian Ave. Suite 400

West Palm Beach, Florida 33401

## Re: Jeffrey Epstein

Dear Ms. Villafaña:

Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the NPA. Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order.

Very truly yours,

Martin J Wanling 1920

Martin G. Weinberg

cc: Roy Black