EFTA00189017.pdf

From: Brendan White <brendan@whiwhi.com> Sent: Thi a, 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 prosecu ement with your office that has already been executed. Since this would seem to obviate any need for to testify, please let me know what is going on with respect to this Tuesday. Do we still need to come down there an , i so, will she receive court-ordered immunity? Thanks. Brendan White - Original Messa From: (USAFLS) To: Brendan White Sent: Monday, June 23, 2008 2:09 PM Subject: RE: Grand Jury Appearance Dear Mr. White: .E3. tit* ji; L. 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. Regarding the immunity, at this point, without a written proffer from you regarding t e 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. I I (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:brendan@whiwhi.com] Sent: Monday June 23 2008 1:45 PM To: ni p (USAFLS) Cc: (USAFLS) Subject: Re: Grand Jury Appearance We will be there, and I will make the travel arrangements. I am assuming t ill 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 08-80736-CV-MARRA P-014991 99 EFTA00189017 — Original Messa e From: USAFLS) To: r White Cc: (USAELS) 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 1g to give testimony. Please contact. assistant, = M, 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 08-80736-CV-MARRA P-014992 EFTA00189018 IS • From: Sent To: Subject Dear Mr. White: (USAFLS) I (USARS) 4 11. Thursday, June 26, 200810:55 AM Brendan White RE: Grand Jury Appearance 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 confin it i.at 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 23id, 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: Thursdai, June 26,2008 10:38 AM To: I= (USAFIS) 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 prosec ent 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 a so, will she receive court-ordered immunity? Thanks. Brendan White — Ori inal Mes e — 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 Ica P-014993 EFTA00189019 Regarding the immunity, at this point, without a written proffer from you regarding t ance 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(0 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 To: (USAFLS) Cc: WUSAFLS) Subject Re: Grand Jury Appearance We will be there, and 1 will make the travel arrangements. I am assuming IO W 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 From: To: n de Cc: fUSAFLS1 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 1st to give testimony. Please contaliim assistant, pi, at o make travel arrangements. I expect that Ms. testimony wt gin 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 08-80736-CV-MARRA P-014994 102 EFTA00189020 II 08-80736-CV-MARRA P-014995 103 EFTA00189021 I. (USAFLS) From: Sent To: Subject: Thanks. Brendan White TtiLla, June 26, 2008 11:26 AM , (USAFLS) Re: Grand July Appearance -F76:11111a1Mil Iv,1 To: Brendan White Sent: Thursday, June 26, 2008 10:55 AM Subject: RE: Grand Jury Appearance Dear Mr. White: • t 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 at the lea 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 [rnailtolfli Sent: Thursda 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 prosecu • ment 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 t ere and, if so, will she receive court-ordered immunity? Thanks. Brendan White — 0 • • ssa e — From To: Brendan White Sent: Monday, June 23, 2008 2:09 PM Subject: RE: Grand Jury Appearance 08-80736-CV-MARRA 104 P-014996 EFTA00189022 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. Regarding the immunity, at this point, without a written proffer from you regarding substance of her anticipated testimony,) 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. i ssistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Brendan White Sent: Monday June 23 2008 1:45 PM To: (USAFLS) Cc: n(USAFLS) Subject: Re: Grand Jury Appearance We will be there, and I will make the travel arrangements. I am assuming tbigill 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 -F70:1101 To: r n hite Cc: (USAFLSI Sent: Monday, June 23, 2008 11:27 AM Subject: Grand Jury Appearance Dear Mr. White: Ms. III, 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, will need to appear before the grand jury on July I a1 to give testimony. Please contact Assistant U.S. Attorney 08-80736-CV-MARRA P-014997 los EFTA00189023 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 08-80736-CV-MARRA P-014998 106 EFTA00189024 n il I (USAFLS) From: Brendan White •: e Sent: ThLsc if la, June 26, 2008 3:00 PM To: • . I. (USAFLS) Subject Re: Grand Jury Appearance I've learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning. In understand, of course, that you need confirmation of this before withdrawing the subpoena, but it might make logistical sense to consider putting the contingent appearance off for another week at this point, to avoid our having to make an unnecessary trip to Florida. Although I am confident that things will proceed as scheduled, should there be a problem, we would then be able to appear at a later date. Brendan White Ori inal Mes From: To: Brendan White Sent: Thursday, June 26, 2008 10:55 AM Subject: 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 Seta 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 Sent: Thursdayjune 26j.2008 10:38 AM To: MI (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 prosecut ment with your office that has already been e 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. 08-80736-CV-MARRA P-014999 109 EFTA00189025 Brendan White Ori inal M From: ' To: Bren an ni e 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. Regarding the immunity, at this point, without a written proffer from you regarding t ance 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(0 and Fed. R. Evid. 410. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Brendan White [mallto: n o Sent: Monde June 23 2008 1:45 PM To: =I. (USAFLS) Cc: (USAFLS) Subject: Re: Grand Jury Appearance We will be there, and I will make the travel arrangements. I am assuming t ill 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 Ori inal Mes e From: To: r n a) ite Cc: . fUSAFLSI Sent: Monday, June 23, 2008 11:27 AM Subject: Grand Jury Appearance Dear Mr. White: Ms. assistant, will need to appear before the grand jury on July I g to give testimony. Please contaciiim M, 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. 08-80736-CV-MARRA P-015000 EFTA00189026 Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 08-80736-CV-MARRA P-015001 111 EFTA00189027 USAFLS) From: ■ (USAFLS) Sent: Thursday, June 26, 2008 6:41 PM To: Brendan White Subject RE: Grand Jury Appearance Dear Mr. White: I have not received any such confirmation. At this time, we are still on for July I recommend that you make your travel plans for Monday afternoon or evening and if things change, I will call you right away. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Brendan White Sent: Thursda June 264.2008 3:00 PM To: g (USAFLS) Subject: Re: Grand Jury Appearance I've learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning. In understand, of course, that you need confirmation of this before withdrawing the subpoena, but it might make logistical sense to consider putting the contingent appearance off for another week at this point, to avoid our having to make an unnecessary trip to Florida. Although I am confident that things will proceed as scheduled, should there be a problem, we would then be able to appear at a later date. Brendan White — Ori in IM From: To: Brendan White Sent: Thursday, June 26, 2008 10:55 AM Subject: RE: Grand Jury Appearance Dear Mr. White: CH 11 `11 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 lea 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 23s, which is shown below. if the situation changes, I will contact you. Thank you. 08-80736-CV-MARRA P-015002 112 EFTA00189028 Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Brendan White [mailto To: =1. (USAFLS) Sen : Th m216,2008 10:38 AM 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 Frew To: Bren an ve Sent Monday, June 23, 2008 2:09 PM Subject: RE: Grand Jury Appearance Dear Mr. White: s M 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. 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 tte 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 To: ispmi (USAFLS) Cc: (USAFLS) Subject: Re: Grand Jury Appearance 08-80736-CV-MARRA P-015003 113 EFTA00189029 We will be there, and I will make the travel arrangements. I am assuming t 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 F.roni ; To: fl tp, Cc:M. NI= (USAFLS) Sent: Monday, June 23, 2008 11:27 AM Subject: Grand Jury Appearance Dear Mr. White: Ms. will need to a car before the nd jury on July In to give testimony. Please contacti assistant, im M , 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. U Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 08-80736-CV-MARRA P-015004 114 EFTA00189030