LAW OFFICES¶
LYONS AND SANDERS¶
CHARTERED¶
DALE R. SANDERS *¶
BRUCE M. LYONS **¶
HOWARD L. GREITZER¶
EDWARD D. BERGER¶
(1959-1987)¶
*ALSO ADMITTED IN WYOMING¶
**ALSO ADMITTED IN COLORADO¶
E,¶
5¶
February 14, 2007¶
VIA US MAIL¶
Assistant US Attorney¶
500 South Australian Ave¶
Ste 400¶
West¶
Grand Jury Subpoena¶
Dear Ms. :¶
By agreement, on January 25, 2007, and served me with a grand jury subpoena for my client, to appear on February 13, 2007. I indicated that would assert her rights under the Fifth Amendment and on consent, the appearance has been extended. You have asked me to set out the basis for my request and that you apply through appropriate channels for a formal grant of use immunity for . I do so here.¶
As I indicated to you when we conversed last week, is no longer employed by Mr. Epstein, but has read much of what can be found on the Internet about the investigation of Mr. Epstein. From that review, she is aware that the police considered charging several persons close to Mr. Epstein, including at least one employee. Given that, and the seemingly broad scope of the investigation, asserts her rights under the Fifth Amendment.¶
Indeed, considering that both the state authorities in Palm Beach County and your office are conducting investigations, there is every reason for her to be concerned and therefore to assert her constitutional rights. If you continue to want her to appear before a grand jury, be advised that she will assert¶
EFTA00187034¶
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 24, 2007¶
DELIVERY BY HAND¶
Bruce M. Lyons¶
Lyons and Sanders¶
600 Northeast 3rd Avenue¶
Fort Lauderdale, FL 33304¶
Re: Federal Grand Jury Subpoena¶
Dear Bruce:¶
A new grand jury has been empaneled and I have enclosed a new subpoena for . As I mentioned earlier, is not a target of this investigation and the United States seeks her testimony solely as a witness. During our last conversation regarding , you indicated that she was unwilling to speak with us pursuant to a Kastigar letter. Please confer with her to confirm whether this remains her position. If is not amenable to an informal meeting, she must still appear pursuant to the subpoena so that I may ask her questions that would not require the invocation of the Fifth Amendment. If she still invokes, I intend to move to compel her answers. If you or your client is unavailable on February 6, 2007, please let me know of another Tuesday when you are available.¶
I also am concerned about a potential conflict of interest in your representation of . In case of future litigation regarding this issue, please provide me with information regarding who is paying (directly or indirectly) for your services on behalf of , the scope of your representation, and whether you are taking direction on this matter from anyone other than . If any formal or informal joint defense agreements exist, whether in writing or otherwise, please provide a copy of such agreements. If the agreement is purely oral, please provide a written summary of its terms.¶