EFTA00584752.pdf

Reid H. Weingarten 202 429 6238 rweingart@steptoe.com 1330 Connecticut Avenue, NW Washington. DC 20036-1795 202 429 3000 main www.steptoe.com April 18, 2016 Little, Brown & Company Market Place Center 3 Center Plaza Boston, MA 02108 ATTENTION: LEGAL COUNSEL RE: Proposed nook by James Patterson regarding Jeffrey Epstein Dear Sir or Madam: Steptoe STSPTOE $ JOHNSON LIP On December 3, 2015 Martin G Weinberg authored a letter that was hand-delivered to Little, Brown & Co addressing concerns regarding a proposed book about Jeffrey Epstein, see attached letter. At the time Mr. Weinberg understood that the author was John Connolly. No response to that letter has been received. Mr. Weinberg received both by email and fedex a letter dated April 14, 2016, addressed to Mr. Epstein, and authored by James Patterson representing that a book about Mr. Epstein titled "Filthy Rich" was intended for publication this August. Again, both Mr. Weinberg and I want to provide you with clear notice that Mr. Epstein has been the past subject of repeated and widespread untruthful, inaccurate, and defamatory media coverage. It would be in reckless disregard for the truth if a book relying in whole or in part on such media coverage were published or if a book relying on biased and provably untruthful or unreliable sources of information became the basis for further prejudicial publicity about Mr. Epstein. Given that James Patterson is being named as author (or co- author), the proposed book is likely to generate an even wider audience although large portions of the book may be predicated on Mr. Connolly's investigation and writing. Accordingly, we reserve any and all legal rights BEIJING BRUSSELS CENTuaIOTY 04CAGO LONDON LOS ANGELES NEW yORK PALO ALTO HUDAK WASHINGTON EFTA00584752 Little, Brown and Company April 18, 2016 Page 2 of 2 to contest the basis for any inaccurate or untruthful information contained in any future publication. In order to diminish the likelihood of the book containing defamatory falsehoods that could, if known in advance, be identified and redacted, and to begin a communication that I hope would result in a more accurate book if and when it is released, Mr. Weinberg and I would request a meeting with you at which we could address the concerns raised above. Very truly yours, Reid H. Weingarten cc: James Patterson EFTA00584753