EFTA00187010¶
TRANSMISSION OK¶
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U.S. Department of Justice¶
United States Attorney¶
Southern District of Florida¶
A. Marie Villafaña¶
500 S. Australian Ave, 4th Floor¶
West Palm Beach, Florida 33401¶
FACSIMILE COVER SHEET¶
TO: Gerald Lefcourt, Esq.¶
DATE: August 16, 2007¶
FAX NO.¶
OF PAGES: 10¶
PHONE NO. ___¶
RE: NES, LLC¶
Assistant U.S. Attorney¶
COMMENTS:¶
EFTA00187011¶
U.S. Departme⁻⁴ of Justice¶
United States Attorney¶
Southern District of Florida¶
A. Marie Villafaña 500 S. Australian Ave, 4th Floor West Palm Beach, Florida 33401¶
FACSIMILE COVER SHEET¶
TO: Gerald Lefcourt, Esq.¶
DATE: August 16, 2007¶
FAX NO.¶
OF PAGES: 10¶
PHONE NO. ___¶
RE: NES, LLC¶
COMMENTS:¶
EFTA00187012¶
U.S. Department of Justice¶
United States Attorney¶
Southern District of Florida¶
August 16, 2007¶
VIA FACSIMILE¶
Gerald Lefcourt, Esq.¶
Gerald P. Lefcourt, P.C.¶
148 East 78th Street¶
New York, NY 10021¶
Re: Subpoena to Custodian of Records, NES, LLC¶
Dear Mr. Lefcourt:¶
I write in response to your letter of July 18, 2007 regarding the grand jury subpoena issued to the Custodian of Records for NES, LLC. I have attached an identical subpoena containing a return date of September 11, 2007, and subpoenas for two NES employees, Eric Gany and Harry Beller. If you will not be representing Messrs. Gany and Beller, please let me know.¶
First, as I mentioned in my earlier correspondence, a properly executed declaration from the Custodian of Records is needed, and, if no documents responsive to a particular request exist, the Custodian should certify that under penalty of perjury.¶
Second, you write that NES has no documents responsive to Requests 1 through 5. I know that NES has several credit card accounts for the benefit of the persons who manage Mr. Epstein’s properties, including Janusz Banasiak and Alfredo Rodriguez. I also know that NES regularly receives money from an account that is used to pay expenses at 358 El Brillo Way and also wires money to that same account. Those wire transfers fall within the time period called for by the subpoena and number in the hundreds of thousands of dollars. If NES does not maintain records of its banking activities, then I would like to see a copy of its document retention policy, so I have added that to the Attachment to the Subpoena.¶
Third, Mr. Menchel’s comment to you about potential money laundering charges related only to a resolution of the case. In other words, if the sex offense case is resolved, the Office would close its investigation into other areas as well. The matter has not been, and it does not appear that it will be, resolved so the money laundering investigation continues, and Request Number 6 will not be withdrawn. The request is not overbroad and is stated with particularity, so please comply with the request by the new deadline.¶
EFTA00187013¶
GERALD LEFCOURT, ESQ. AUGUST 16, 2007 PAGE 2 OF 2¶
With respect to paragraph 7, the information provided regarding the pilots came from the corporate records of Hyperion and JEGE, Inc., not NES. However, I have provided a shorter list in the new subpoena attachment.¶
I also have enclosed another certification for the Custodian of Records’ signature.¶
Thank you again for your assistance.¶
EFTA00187014¶