Thursday, June 26, 2008 10:55 AM
Brendan White
RE: Grand Jury Appearance
Dear Mr. White:
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I received information confirming that the plea will be in conformance with our agreement. As such, at this time, I still intend to present Ms. testimony to the grand jury on Tuesday. With respect to the immunity question, I refer you to my e-mail of June 23rd, which is shown below.
If the situation changes, I will contact you.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From:
Brendan White [mailto]
Sent:
Thursday, June 26, 2008 10:38 AM
To:
(USAFLS)
Subject:
Re: Grand Jury Appearance
Dear Ms.
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been executed. Since this would seem to obviate any need for Ms. to testify, please let me know what is going on with respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered immunity? Thanks.
Brendan White
From:
To: Brendan White
Sent: Monday, June 23, 2008 2:09 PM
Subject: RE: Grand Jury Appearance
Dear Mr. White:
Please feel free to make your own travel arrangements, but if you would like Ms. travel costs to be reimbursed, they must be made through the government’s approved agency on the approved carriers.
08-80736-CV-MARRA
P-014993
101
EFTA00189019
Regarding the immunity, at this point, without a written proffer from you regarding the substance of her anticipated testimony, I believe that the more prudent course will be to question Ms. to determine the limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to criminal liability, then I can make the motion ahead of time. Your written statement would be treated as an attorney statement made in the course of confidential plea discussions and related negotiations, and would be governed by Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From: Brendan White [mailto]
Sent: Monday, June 23, 2008 1:45 PM
Subject: Re: Grand Jury Appearance
We will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an order of immunity. Please let me know if that is correct so I can advise Ms. . Thanks.
Brendan White
----- Original Message -----
From:
To: Brendan White
Cc: (USAFLS)
Sent: Monday, June 23, 2008 11:27 AM
Subject: Grand Jury Appearance
Dear Mr. White:
Ms. will need to appear before the grand jury on July 1 st to give testimony. Please contact my assistant, at to make travel arrangements. I expect that Ms. testimony will begin either in the late morning or early afternoon, but she should be available for the whole day.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
102
P-014994
EFTA00189020
103
P-014995