EFTA00090571.pdf

From: Michael Bachner To:" Cc: r" Subject: Re: =Attorney Proffer Date: Sat, 15 Feb 2020 20:50:37 +0000 Inline-Images: -WRD000.jpg let me confirm that I am correct on the London Paris thing. Michael Bachner Bachner & Weiner, PC ease excuse typographical errors. Messages sent through dictation. https://www.actl.com/ NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice. On Feb 15, 2020, at 3:44 PM, wrote: Got it -- I had that down as London, rather than Paris, so that's helpful. And I should say, these questions aren't immediately time-sensitive, I just didn't want to forget to ask, since I'm reviewing the notes now. thanks, From: Michael Bachner Sent: Saturday, February 15, 2020 15:41 To: Cc: Subject: Re: ttorney Proffer ) Hi is away for the weekend. In our meeting I indicated that she stayed in the Paris apartment with her us an on one occasion. I will get back to you on Monday or Tuesday regarding the other questions you've asked today as well as at the meeting. Have a nice weekend EFTA00090571 Michael Bachner Bachner & Weiner, PC Please excuse typographical errors. Messages sent through dictation. c-WRD000.jpg> https://www.actl.cotn/ NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice. On Feb 15, 2020, at 3:05 PM, Michael, > wrote: Following up on our meeting, one additional question / clarification we have from reviewing our notes is about whether ever visited certain Epstein properties other than his New York mansion and the brief visit to the Palm Beach residence. I apologize if you addressed that and I missed it, but we wanted to add it to the list of additional questions — in particular, whether she ever visited the New Mexico ranch, the Little St. James Island, the Great St. James island, and/or the Paris residence. Also, is it correct that she just visited the Palm Beach residence the one time you referenced? It's not a problem or issue if she visited any of those other locations, we just wanted to clarify one way or the other. And happy to discuss via phone if that's useful. From: Sent: Thursday, Fe To: Michael Bachn Cc: '4 >; Subject: RE: ttorney Proffer Michael, We do understand that your attorney proffer today will be preliminary, and to the best of your client's current recollection and to the best of your current understanding, and without, e.g., having been provided documents or other materials by the Government. EFTA00090572 We also confirm that your statements will be considered to be made pursuant to Fed. R. Evid. 410 and Fed. R. Crim. P. 11(f), and therefore under those protections. Regarding Rule 408, we'll just note what we have for other counsel in this case and others who have made similar statements or submissions, which is that we don't take any position on the effect or application of Rule 408 in a prospective or hypothetical dispute in civil litigation, because it doesn't implicate any rights the Government would or would not have, but you can consider us advised that your position is that your statements are also covered under 408. (While our Office itself can't guarantee the protections of Rule 408 because any dispute on that issue would be beyond our purview, we are also not taking the position that we believe it does not apply.) u, From: Michael Bachner Sent: Thursday, February 13, 2020 10:08 To: Subject: Mttorney Proffer Hi Prior to our meeting today, I am writing to confirm that s ments I make to you today are preliminary and subject to further refinement once M nd I have the benefit of additional document review and refreshed recollection if necessary b e upon input we may receive from your office. My statements to you are intended in hypothetical form only and in any event, we understand that the provisions of FRE 408 and 410 apply. Please advise if my understanding is correct. Thanks. Michael Bachner Bachner & Associates, PC <image001.jpg> https://www.actl.com/ EFTA00090573