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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00226396

453 pages
Pages 301–320 / 453
Page 301 / 453
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Okay. 
BY MS. 
• 
• 
Q 
Then we have two questions that were 
raised earlier. One of which was whether there is 
any evidence to suggest that Mr. Epstein filmed 
any of these encounters? 
A 
We don't have any evidence at this time. 
Some of girls were asked that question but there's 
no evidence to show that he did or indicate that 
he did. 
Q 
All right. And then the second one was 
we had talked earlier about Mr. Epstein leaving 
Florida and not returning. What evidence do you 
have regarding where Mr. Epstein has been since 
October of 2005? 
A 
He has -- and I may have misspoke if I 
said he has not ever come back. 
He has come back 
because of the state charges he has faced. He has 
had to come into Palm Beach County for that. 
We do not believe that he has been here 
other than that since the investigation broke in 
October of '05, other than having to appear before 
the state charges. 
We know where Mr. Epstein resides and we 
have a partner, ICE, Immigration and Customs 
OFFICIAL REPORTING SERVICE, LLC 
(954) 467-8204 
EFTA00226696
Page 302 / 453
51 
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2 
3 
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Enforcement, who can -- is helping us monitor his 
plane activity, and, although, we were not privy 
to all of his domestic flights when he comes in 
and out of the country, we are alerted to that. 
Q 
And you mentioned earlier that you 
6 
interviewed Janusz Banasiak, correct? 
7 
A 
Yes. 
8 
Q 
Who currently serves in what position of 
9 Mr. Epstein? 
10 
A 
He is currently the house manager for 
1 1 
Mr. Epstein and maintains the property over in 
12 Palm Beach. 
13 
Q 
And what did he tell you about Mr. 
14 
Epstein? 
15 
A 
He also said that Mr. Epstein has not 
16 
been back. 
17 
Q 
Okay. 
18 
MR. 
Any other questions? 
19 
All right. You guys get a break next. All 
20 
right. 
We will see you 
I will be out of 
21 
town next week and I will probably see you 
22 
the week after that. 
23 
(Witness was excused.) 
24 
25 
OFFICIAL REPORTING SERVICE, LLC 
(954) 467-8204 
EFTA00226697
Page 303 / 453
52 
CERTIFICATE OF REPORTER 
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I, Paula E. Angelocci, Certified Court 
Reporter and Notary Public, do certify that the 
transcript is a true and correct transcription of 
my stenotype notes of the testimony of 
SPECIAL AGENT E. NESBITT 
taken before 
the Federal Grand Jury, West Palm Beach, Florida. 
PAULA E. ANGEjICCI, CSR #4869 
Certified Cou 
Reporter 
OFFICIAL. REPORTING SERVICE, LLC 
(954) 467-8204 
EFTA00226698
Page 304 / 453
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 3340! 
(561) 820-8711 
Facsimile: (561)8204777 
June 7, 2007 
D LIVERY BY HAND 
Miss 
Re: 
Crime Victims' and Witnesses' Rights 
Dear 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights arc: 
(I) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you have an concen i r this regard, please feel free to contact me at 561 
209-1047, or Special Agen 
from the Federal Bureau of Investigation at 561 
822-5946. 
You also can con ac 
a ustice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above arc being violated, you have the right to petition the Court for 
relief. 
Exhibit 30 
EFTA00226699
Page 305 / 453
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 
June 7, 2007 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' and Witnesses' Rights 
Dearan 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(4) 
(5) 
(6) 
(7) 
(8) 
The right to be reasonably protected from the accused. 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
The reasonable right to confer with the attorney for the United States in the case. 
The right to full and timely restitution as provided in law. 
The right to proceedings free from unreasonable delay. 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you have an concerns in this regard, please feel free to contact me at 561 
209-1047, or Special Agent 
from the Federal Bureau of Investigation at 561 
822-5946. You also can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
EFTA00226700
Page 306 / 453
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: (56O 820-8777 
June 7, 2007 
DELIVERY BY HAND 
Miss 
Dear 
Re: 
Crime Victims' and Witnesses' Rights 
he Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights arc: 
(1) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you have an concerns in this regard, please feel free to contact me at 561 
209-1047, or Special Agent 
from the Federal Bureau of Investigation at 561 
822-5946. You also can contact the ustice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
EFTA00226701
Page 307 / 453
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 
June 7, 2007 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' and Witnesses' Rights 
Dear 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(4) 
(5) 
(6) 
(7) 
(8) 
The right to be reasonably protected from the accused. 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are *sent for other 
portions of a proceeding. 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
The reasonable right to confer with the attorney for the United States in the case. 
The right to full and timely restitution as provided in law. 
The right to proceedings free from unreasonable delay. 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you 
concerns in this regard, please feel free to contact me at 561 
209-1047, or Special Agent 
from the Federal Bureau of Investigation at 561 
822-5946. 
You also can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
EFTA00226702
Page 308 / 453
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 
June 7, 2007 
DELIVERY B HAND 
Miss 
Re: 
Crime Victims' and Witnesses' Rights 
Dear 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(1) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you have an concerns in this regard, please feel free to contact me at 561 
209-1047, or Special Agent 
from the Federal Bureau of Investigation at 561 
822-5946. You also can contact 
e ustice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
EFTA00226703
Page 309 / 453
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 
June 7, 2007 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' and Witnesses' Rights 
Dear 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(1) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of !once and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you have an concerns in this regard, please feel free to contact me at 561 
209-1047, or Special Agent 
from the Federal Bureau of Investigation at 561 
822-5946. 
You also can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a wcbsitc at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief 
EFTA00226704
Page 310 / 453
From: 
Sent: 
u 
ay, June 14, 2007 2:14 PM 
To: 
Subject: 
Addendum to Pros Memo 
Hi all — I have attached hereto an addendum to the Pros Memo ad 
ing some of the 
• ' • 
cems that 
you raised regarding Jane Doe #6. I have not sent this directly to 
the book containing the pros memo and the attachments. 
li
, but I would ask 
add it to 
On another note, we have all discussed different strategies regarding how the final indictment should appear. 
At this time, I have not made any revisions to the indictment. Based upon the continued investigation there are 
some things that I would like to add (another Jane Doe has been identified and interviewed) and, based upon 
your comments, some items that could be deleted. Do you want me to make those changes now or wait until we 
have received approval of the current charging strategy? 
Thank you. If there is anything that you would like me to prepare in advance of the meeting on the 26th, please 
let me know. 
Addendum to 
Pros Memo.pdf 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West 
0 I 
Tracking: 
132 
Exhibit 31 
EFTA00226705
Page 311 / 453
Read 
Read: 6/14/2007 2:22 PM 
Read: 6/14/2007 3.48 PM 
133 
EFTA00226706
Page 312 / 453
From: 
Sent: 
To: 
Subject: 
RE: Meeting Next Week 
AMP111117,11KIIIISIPZI• 
Sounds good. I will stop by on Monday afternoon. Could you just let you assistant know that I may be 
stopping by to get a copy of whatever the defense sends over? 
Thanks. 
Assistant U.S. Attorney 
500 S. Australian Ave. Suite 400 
West Palm Beach FL 33401 
From: Menchel, Matthew (USAFLS) 
Seniailay, June 21, 2007 2:58 PM 
To: 
, Ann Marie C. (USAFLS) 
Cc: Lourie, Andrew (USAFLS) 
Subject: RE: Meeting Next Week 
Meeting on Monday is fine. I have meetings with Nand Jeff till around 11 but after that I'm gas As for who is going 
to be at the meeting from our side, I thought you, me, Andy, and Jeff. I thought it best to leave 
out of it at this 
venture. As for the Epstein camp, I'm not entirely sure because I don't think Lily was sure last time we spoke. Probably 
her, Lercourt, Black and maybe Lewis. 
Lily told me that they wanted to present something in writing before the meeting which was why she was pushing us for 
the statutes. I view the meeting more as us listening and them presenting their position so I would say that you don't 
need to prepare anything (you are quite knowledgeable on the law in any event) but if you disagree we can discuss on 
Monday. As for the documents that they have yet to produce, I'll mention it to Lily if you like or we can raise it with 
them at the Tuesday meeting. 
From:1=, Ann Marie C. (USAFLS) 
Sent: 
ursday, June 21, 2007 1:37 PM 
To: 
Cc: 
Su
Importance: High 
Hi =I 
would like to prepare for next week's meeting, and I am wondering if you can tell me who will 
attend, both from our side and for Mr. Epstein. I am hoping that we can meet on Monday to discuss any issues 
and/or strategy before the meeting on Tuesday, so please let me know when you will be available on Monday. 
114 
EFTA00226707
Page 313 / 453
Also, if there are any issues that you would like me to be prepared to address — either with you on Monday or 
with defense counsel on Tuesday — please give me a list and I will bring the appropriate items with me. 
Since Lilly has been communicating with you directly about the meeting, and I have given them the list of 
statutes that they have requested, perhaps you could ask her to reciprocate by providing us with their written 
analysis (or documents they want us to consider) prior to the meeting so we can address any issues then and 
there. Also, during a previous meeting, I asked Lilly and Gerry for copies of Epstein (or his assistants') agendas 
and calendars to show that, as they claim, Epstein's travels to Florida were consciously coordinated so that he 
could maintain his Florida residency for tax purposes. Lilly said she would try to get them to us, but has never 
done so. I have subpoenaed all of the corporate entities with which Epstein is affiliated and they all claim that 
they do not have any responsive documents. 
I will plan to be in Miami by around 10:00 on Monday morning, so any time after that is fine. 
Thank you. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
115 
EFTA00226708
Page 314 / 453
Recipient 
Reed 
Menchel. Matthew (USAF LS) 
Read: 6121/20073:28 PM 
116 
EFTA00226709
Page 315 / 453
From: 
Sent: 
ur ay, une 
To: 
Cc: 
Jeff (USAFLS) 
Subject: 
Meeting Next Week 
Importance: 
High 
Hi Matt: I would like to prepare for next week's meeting. and I am wondering if you can tell me who will 
attend, both from our side and for Mr. Epstein. I am hoping that we can meet on Monday to discuss any issues 
and/or strategy before the meeting on Tuesday, so please let me know when you will be available on Monday. 
Also, if there are any issues that you would like me to be prepared to address — either with you on Monday or 
with defense counsel on Tuesday — please give me a list and I will bring the appropriate items with me. 
Since Lilly has been communicating with you directly about the meeting, and I have given them the list of 
statutes that they have requested, perhaps you could ask her to reciprocate by providing us with their written 
analysis (or documents they want us to consider) prior to the meeting so we can address any issues then and 
there. Also, during a previous meeting, I asked Lilly and Gerry for copies of Epstein (or his assistants') agendas 
and calendars to show that, as they claim, Epstein's travels to Florida were consciously coordinated so that he 
could maintain his Florida residency for tax purposes. Lilly said she would try to get them to us, but has never 
done so. I have subpoenaed all of the corporate entities with which Epstein is affiliated and they all claim that 
they do not have any responsive documents. 
I will plan to be in Miami by around 10:00 on Monday morning, so any time after that is fine. 
Thank you. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
117 
EFTA00226710
Page 316 / 453
Recipient 
Road 
Read: 6121/2007 1:52 PM 
Read: 6/21/2007 2:24 PM 
Read. 6/27/2007 4:43 PM 
Read: 6/21/2007 2:03 PM 
118 
EFTA00226711
Page 317 / 453
JsI-16-07 
I I :00il 
From-Fowl ur-Illitte Burnett 
3057898301 
FOWLER WHITE BURNETT P.A. 
Espirito Santo Plaza 
Fourteenth Floor 
1395 Bnckell Avenue 
Atom. Florida 33131.3302 
(305) 789-9200 
Date: 
To: 
Fax Number: 
FAX TRANSMITTAL 
Monday, July 16.2007 
1-151 
F.001/004 
F-95; 
From: 
Fax Number: 
Matter No: 
Remarks: 
(305) 789-9201 
Telephone Number: (305) 789-9200 
71200 - Epstein 
Please see attached correspondence from Roy BI 
e 
Jeffrey Epstein matter and the letter in response of 
Gerald Lefcourt and I would like to speak to you further regar ing same 
since we do not believe that Marie's letter 
es 
raised by Roy Black. I am in my office at 
Original documents will not Follow by mail. 
Time of Transmittal: 
a.m./p.m. 
Transmitted By: 
Photocopy:them& be token of this tronpuission VII IS 10 6, martinet,  sate facsimile paper has limited stu•ate hie 
THE INFORMATION CONTAINED IN THIS FACSIMILE MESSAGE IS ATTORNEY PRWILEGED AND CONFIDENTIAL 
INFORMATION INTENDED ONLY FOR THE USE OF THE INDNIDU.N. OR ENTITY NAMED ABOVE. M THE READER 
OF THIS MESSAGE IS NOT THE INTENDED REGIMENT. YOU ME HERESY NOTIFIED THAT ANY crasersNAnoN. 
OtSTroatfriON OR COPYING OF THIS COMMUNICATION IS STRICTLY PROMOTED. IF YOU HAVE RECEIVED 
THIS COMMUNICATION IN ERROR. PLEASE IMMEDIATELY NOTIFY uS BY TELEPI-IONE 
(IF LONG DISTANCE. PLEASE CALL COLLECT) AND RETURN THE ORIGINAL MESSAGE 
TO US AT THE ABOVE ADDRFCs VIATHE U.S. POSTAL SERVICE. THANK YOU. 
PLEASE NOTIFY US IMMEDIATELY BY CALLING (305) 789-9200, IF THERE IS ANY PROBLEM. 
Case No. 08-80736-CV-MARRA 
Exhibit 32 
P-011924 
EFTA00226712
Page 318 / 453
;,!-16-07 
II:00at 
From-Fowler—P..14 Burnett 
3051099201 
07/16/2667 
09:06 
3053582006 
BLACK SFEB 8 K0RN 
Roy BLACK 
Hones M. EiRtAtatek 
SCUTT A. KORNAPAN 
WRY A. STUMPF 
MARIA NCYHA 
JACtIt PtRCZIK 
MARX A.J. SHAPIRO 
JAIME) 
BLACK 
SREBNICK 
KORNSPAN 
& STUMPF 
July 13, 2007 
MneantatigliallatatinaliktflatiSIL 
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 
Re: 
Grand Jury Subpoena William Riley 
Dear Ms. 
T-I5I 
P 002/004 
F-050 
PAC£ 
32 
CHRRITIKZ It No 
Jessica FOWSZCA-NADLP 
Kan-0.102d P. PHIU1P11 
WON ANNOta 
Iturcoe Defacer. JR. 
MArnave P. 0llevi 
RElioolagtoplack.coro 
represent
I 
 Jeffrey Epstein, the target of a pending Grand Jury investigation. 
Prior to the initiation of this federal investigation, I represented Mr. Epstein on a 
Palm Beach Florida State Attorney's Office investigation and subsequently an 
Information, the factual basis of which is identical to, and gave rise to, the federal 
investigation presently underway. 
In connection with my earlier representation of Mr. Epstein, I hired Mr. 
William Riley as a private investigator to act under my direction in anticipation of 
defending Mr. Epstein against possible criminal charges and any litigation which 
may have followed. All his investigations were done as my agent and thus are 
covered by the work product privilege, and all communications to him are 
protected by the attorney client privilege. 
Though we are not conceding the existence of any computers that would be 
/Lk 
responsive to the subpoena served upon Mr. Riley, to the extent there are any 
i n. 
such computers, they would contain documents that are privileged attorney-client / 
f -t!:›1
communications and attorney work-product. 
Your subpoena also asks fo -e:). -, ) r 
materials describing the scope of hits investigation and thus they are our work 
i r ,.../ 
product.  
201 S. tusayne Boulevard. Suite COO - Miami. !bride Bpi Phone. IDS-3714421 • Fax: 305-3584006 wirmRojEllaeLcom 
Case No. 08-80736-CV-MARRA 
P-011925 
EFTA00226713
Page 319 / 453
LIP -1 6-01 
I I:0las 
Fros-Falsr-/hit. Surat' 
3057809201 
T-!3I 
P 003/004 
F-853 
97/16/2097 09:46 
3853582886 
PACK SRFB 8 KERN 
2007
Page 2 
PACE 
23 
C
As you know, the ;Inked States Attorneys Office Manual., Guideline. for 
Issuing Grand Jury and Thal Subpoenas to Attorneys for Information Relating to 
the Representation of Clients, requires that the attorney client and work-product 
privilieged information sought by the Grand Jury subpoena issued to Mr. Riley 
must first be authorized by the Assistant Attorney General for the Criminal 
Division before it may issue. 
Therefore, please advise me as to whether the applicable sections of the 
United States Attorneys Office Manual was complied with prior to the issuance,
' 
epv
of the Grand Jury subpoena to Mr. Riley. Please also advise as to the preliminary 
steps taken in advance of the issuance of the subpoena, as required by the 
Manual. Finally, please provide rue with the name of the Assistant Attorney 
General of the Criminal Division who undertook the evaluation of the request for 
the Grand Jury subpoena, as required by the same section of the Manual and, if 
an evaluation was made, the basis upon which the Assistant determined that the 
information sought in the subpoena was not protected by a valid claim of privilege. 
RB/wg 
Sincerely, 
R r  Black 
Black Srebnick.. Komspan & Stumpf. P). 
Case No. 08-80736-CV-MARRA 
P-011926 
EFTA00226714
Page 320 / 453
n1-16-07 
11:01 eta 
Pros—fowler-014 Burnett 
07/14/:UUY VU:J4 !AA auspu4sio.
3051000201 
T-151 
P 004/004 
F-050 
U.S- Department of Justice 
United States Attorney 
Southern District ofFlorida 
300 South Aktznaten AYR, Suite 400 
Wert Palm Beath, FL 13401 
(561)820-8711 
Facrtmik: (561) 820-8777 
July 16, 2007 
VIA FACSIMILE 
Roy Black, Esq. 
Black Srebnick 1Cornspan & Stumpf PA 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Correspondence Dated July 13, 2007 
Dear Mr. Black: 
Thank you for your letter ofJuly 13, 2007. You and your firm are neither a subpoenaedparty 
nor counsel to a subpoenaed parry. Accordingly, pursuant- to the Federal Rules of Criminal 
Procedure, I am not at liberty to discuss this matter with you. Moreover, it is nor the practice of this 
Office to discuss internal Department of Justice policies Aith non-Justice Department persormel. 
If Mr. Riley believes he has cause to move to quash the subpoena, or if Mr. Epstein does for that 
matter, counsel for the respective parties should so move. Otherwise, we expect compliance by 
tomorrow, which includes a one-week extension already requested by Ms. Sanche2 prior to Mr. 
Richey's appearance as counsel for Mr. Riley. 
Sincerely, 
Assistant United States Anorncy 
cc; 
Andrew Laurie, Esq. 
William Richey, Esq. 
Lilly Ann Sanchez, Esq. 
Case No. 08-80736-CV-MARRA 
P-011927 
EFTA00226715
Pages 301–320 / 453