Email:

*   From: redacted
*   To: Marc A. Weinstein, redacted
*   Cc: Andrew Tomback, redacted

## Subject: RE: SDNY investigation

Date: Fri, 02 Oct 2020 14:39:09 +0000

Marc,
Received, thanks very much.
Hope you're doing well—

From: Weinstein, Marc A.
Sent: Wednesday, September 30, 2020 1:52 PM
To: <empty>)
Cc: Andrew Tomback ; <empty>)
Subject: RE: SDNY investigation

The transcripts are attached. We trust that the US Attorney's Office will keep these confidential other than to the extent disclosure is required in any pending case.

Regards,

Marc

## MarcA.Weinstein | Partner

Chair, White Collar Defense

## Hughes Hubbard & Reed LLP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

From: Weinstein, Marc A.

Sent: Wednesday, September 30, 2020 12:03 PM

The image shows an email header.
*   **To:** [Name censored]
*   **Cc:** Andrew Tomback, [Name censored]


## Subject: RE: SDNY investigation

I connected with Jack Scarola last week. I just sent him an email to confirm that we can provide you with the transcript. Once we receive confirmation from him, we will send you the transcript. Best regards,

Marc

The image is of an email header, with the following information:
*   **From:** [Redacted]
*   **Sent:** Tuesday, September 29, 2020 3:40 PM
*   **To:** Weinstein, Marc A. [Redacted]
*   **Cc:** Andrew Tomback [Redacted]
*   **Subject:** RE: SDNY investigation

EFTA00024015

## CAUTION: This email was sent by someone outside of the Firm.

Hi Marc,

Hope you're doing well. I wanted to check in on the status of this issue — have you been able to connect with Mr. Scarola? Thanks,

Key details from the email:

*   **From:** Marc A. Weinstein
*   **Sent:** Tuesday, September 22, 2020, 4:54 PM
*   **To:** [Redacted]
*   **Cc:** Andrew Tomback
*   **Subject:** RE: SDNY investigation
*   **Sender:** Marc A. Weinstein | Partner, Chair, White Collar Defense

Hughes Hubbard & Reed LLP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

| Field | Value |
|---|---|
| Subject | RE: SDNY investigation |
| From | [REDACTED] <[redacted]> |
| Sent | Tuesday, September 22, 2020 4:42 PM |
| To | [RECIPIENT NAME REDACTED] <[redacted]> |
| Cc | [RECIPIENT NAME REDACTED] <[redacted]>; additional recipients redacted |
| Other visible detail | Multiple email addresses and lines are redacted with black bars |

Confidentiality notice is present above the header.

Subject: RE: SDNY investigation

CAUTION: This email was sent by someone outside of the Firm.

Marc,

Thanks for following up on this. If it's okay with you, I think it makes sense to connect you with the plaintiff's attorney, Jack Scarola, so that he can convey this to you directly. I have spoken with him and explained the context here, and he has told me that he would be happy to speak with you. He is also seeking a copy of the transcript, as he has informed me that he no longer has his case files for matters this old. Here is his contact information: Jack Scarola

Thank you,

From: Weinstein, Marc A. <

Sent: Tuesday, September 22, 2020 11:24 AM

To:

Cc: Andrew Tomback

Subject: RE: SDNY investigation



We haven't found a governing protective order, but to be safe, would you be able to get a letter or email from attorney stating that they are not aware of a protective order/agreement governing the disclosure of the transcript, and to the extent one existed, they are waiving any provisions in order to permit the Estate to provide the transcript to the US Attorney's Office, and that they will not claim, in any forum, that the Co-Executors, the Estate, or any representatives of either, breached any such order/agreement in that case by providing the transcript to the US Attorney's Office. Let us know if that works on your end.

EFTA00024016

Best regards,
Marc 
Marc A. Weinstein I Partner
Chair, White Collar Defense

## Hughes Hubbard & Reed LLP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

The image is of an email header:

*   **From:** [redacted]
*   **Sent:** Monday, September 14, 2020 3:01 PM
*   **To:** Weinstein, Marc A. [redacted]
*   **Cc:** Andrew Tomback [redacted]

Subject: RE: SDNY investigation

CAUTION: This email was sent by someone outside of the Firm.

Hi Marc,
Thanks – we have conferred with plaintiff's counsel, who has informed us that he is unaware of any protective order relating to the [REDACTED] lawsuit.
Best,

[REDACTED]
Assistant United States Attorney
Southern District of New York

From: Weinstein, Marc A. <[REDACTED]>
Sent: Monday, September 14, 2020 12:07 PM
To: [REDACTED]
Cc: Andrew Tomback <[REDACTED]>;

Subject: Re: SDNY investigation

Weinstein | Partner
Chair, White Collar Defense

Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

On Sep 14, 2020, at 11:56 AM, [REDACTED] <REDACTED> wrote:

CAUTION: This email was sent by someone outside of the Firm.

Marc,

Thanks very much. Are you able to provide it to us? If there are any issues with providing it to us, or if a call would be useful to discuss, please let us know.

Thanks,

EFTA00024017

From: Weinstein, Marc A. <
Sent: Monday, September 14, 2020 11:51 AM
To: |
Cc: Andrew Tomback <

Subject: RE: SDNY investigation



we have | the transcript of

deposition.

Regards,

Marc

## Marc A. Weinstein I Partner

Chair, White Collar Defense

## Hughes Hubbard & Reed LLP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

## From:

Sent: Friday, September 11, 2020 1:40 PM

To: Weinstein, Marc A. <

Cc: Andrew Tomback

## Subject: RE: SDNY investigation

CAUTION: This email was sent by someone outside of the Firm.

Thanks, Marc. We'll look forward to hearing from you, and thanks for your assistance with this.

From: Weinstein, Marc A. <masked>
Sent: Friday, September 11, 2020 1:35 PM
To: masked >
Cc: Andrew Tomback <masked>; masked;

## Subject: RE: SDNY investigation

Thanks M. It wasn't clear to me from the call that it was the plaintiff's deposition that you were after, as opposed to another witness in the case. Now that it's clear, we will see if we can track it down. Regards,

## Marc

## Marc A. Weinstein I Partner

Chair, White Collar Defense

## Hughes Hubbard & Reed LIP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

From: <empty> <> <empty>
Sent: Friday, September 11, 2020 1:30 PM
To: Weinstein, Marc A. <>
Cc: Andrew Tomback <> ; <empty> ;
<empty>

Subject: RE: SDNY investigation

CAUTION: This email was sent by someone outside of the Firm.

EFTA00024018

Marc,
Thanks for speaking earlier. The plaintiff's name is <empty>, who is represented by Jack Scarola. The deposition took place in 2009, and Jeffrey Epstein was represented by Mark Luttier and Bob Critton of Critton, Luttier, and Coleman LLP in West Palm Beach.
Thanks very much,
<empty>
Assistant United States Attorney
Southern District of New York
<empty>
<empty>
<empty>
From: Weinstein, Marc A. <
Sent: Friday, September 11, 2020 11:11 AM
To: <empty> >
Cc: Andrew Tomback <<empty>>; <empty>;

Subject: RE: SDNY investigation

I just realized that you didn't share with us the deponent's name for the transcript you are looking for. Let us know so that we can make the appropriate inquiries. Best regards, Marc Marc A. Weinstein I Partner Chair, White Collar Defense

## Hughes Hubbard & Reed LLP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

From: <empty> <> <empty>
Sent: Thursday, September 10, 2020 11:14 AM
To: Weinstein, Marc A. <>
Cc: Andrew Tomback <> ; <empty>

Subject: RE: SDNY investigation

CAUTION: This email was sent by someone outside of the Firm.
That works well, thanks very much. Talk to you then.

From: Weinstein, Marc A. <<empty>>
Sent: Thursday, September 10, 2020 11:13 AM
To: <empty>
Cc: Andrew Tomback <<empty>>; <empty>;
Subject: Re: SDNY investigation
<empty>, if 11:00 works, I can send a dial-in.
Marc A. Weinstein | Partner
Chair, White Collar Defense

Hughes Hubbard & Reed LLP

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate. distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email from your system. li-mail transmission cannot be guaranteed to be secure or

EFTA00024019

error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
On Sep 10, 2020, at 10:46 AM, [REDACTED] <[REDACTED]> wrote:

CAUTION: This email was sent by someone outside of the Firm.

Andy and Marc,

Are you available for a brief call tomorrow? I'm available before 1 p.m., if there's a time that works for you in that window. Thanks very much,



Assistant United States Attorney
Southern District of New York



EFTA00024020