U.S. Department of Justice¶
United States Attorney Southern District of Florida¶
500 South Australian Ave., Suite 400¶
West Palm Beach, FL 33401¶
Facsimile:¶
May 15, 2007¶
VIA FACSIMILE¶
Jack A. Goldberger, Esq.¶
Atterbury, Goldberger & Weiss, P.A.¶
One Clearlake Centre, Suite 1400¶
250 Australian Ave S.¶
West Palm Beach, FL 33401-5015¶
Re: Subpoenas to JEGE, Inc. and Hyperion Air, Inc.¶
Dear Mr. Goldberger:¶
It was a pleasure speaking with you today. As we discussed, the deadlines for complying with the subpoenas to JEGE, Inc. and Hyperion Air, Inc. have been extended to May 29, 2007. If there are any categories for which no documents exist, please ask the Custodian of Records to provide a certificate of nonexistence of records.¶
Also, following our conversation I received a voicemail from Lilly Ann Sanchez addressing the subpoenas. Since you have provided a written statement that you represent JEGE and Hyperion, I will assume that you alone serve as their counsel unless you tell me otherwise. With that in mind, pursuant to Rule 6(e), I do not intend to discuss matters related to these subpoenas with other attorneys.¶
Thank you again for your assistance.¶
Sincerely,¶
EFTA00188126¶
JOSEPH R. ATTERBURY¶
JACK A. GOLDBERGER¶
JASON S. WEISS¶
Board Certified Criminal Trial Attorney Member of New Jersey & Florida Bars¶
May 10, 2007¶
A. Marie Villafaña, Esq.¶
Assistant United States Attorney¶
Office of the United States Attorney¶
Southern District of Florida¶
500 South Australian Avenue, Suite 400¶
West Palm Beach, Florida 33401¶
VIA HAND-DELIVERY¶
JEGE, Inc. (“JEGE”) and Hyperion Air, Inc. (“Hyperion”)¶
Dear Ms. Villafaña:¶
I write as counsel to the above noted entities to respond to the subpoenas dated April 24, 2007, served, respectively, on those entities. I understand from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting:¶
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Ownership of JEGE and Hyperion;
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Assets of JEGE and Hyperion; and
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Employees of JEGE and Hyperion.
As I believe Mr. Lefcourt and Ms. Sanchez told you, JEGE and Hyperion are each wholly owned by Mr. Epstein. Enclosed is an IRS Form 2553 (“Election by a Small Business Corporation”) filed by JEGE, showing that Mr. Epstein is the sole shareholder of that entity. A similar document was filed on behalf of Hyperion, but we have not been able to locate it. As soon as we do, we will forward it to you. I have instead enclosed a share certificate reflecting Mr. Epstein’s ownership of 100 shares of Hyperion. I can also represent that I have examined the books and records of that company and state that no other shares have been issued. Thus, Mr. Epstein is the sole owner of Hyperion, as well.¶
One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401¶
EFTA00188127¶
As to the assets of these entities, both entities exist solely for the purpose of owning their respective aircraft. JEGE owns Mr. Epstein’s Boeing 727 and Hyperion owns Mr. Epstein’s Gulfstream G-IIB. To demonstrate this, enclosed are (i) the Certificate of Aircraft Registration and Standard Airworthiness Certificate for the Boeing 727, showing ownership by JEGE; and (ii) the Certificate of Aircraft Registration and Standard Airworthiness Certificate for the Gulfstream, showing ownership by Hyperion.¶
As to employees, each of JEGE and Hyperion pays crew costs for the crew members (whom we understand you have interviewed), as well as the costs of contract crew members whom JEGE or Hyperion may sporadically engage. Neither JEGE nor Hyperion employs any other crew members or other personnel.¶
Thank you for your cooperation in this matter. If you have any questions, please do not hesitate to call.¶
Very truly yours,¶
JACK A. GOLDBERGER¶
cc: Federal Bureau of Investigation¶
Gerald B. Lefcourt, Esq.¶
Lilly Ann Sanchez, Esq.¶
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