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*   **To**: Gary Bloxsome
*   **CC**: Daniel Cundy, Jennifer Richardson
*   **Subject**: U.S. Department of Justice investigation

Subject: RE: U.S. Department of Justice investigation

Date: Tue, 04 Feb 2020 18:23:11 +0000

Inline-Images: image001.jpg; image002.jpg

Gary,

You are aware of our position, and we do not believe any further rehashing of our prior conversations is productive at this point. That said, we can confirm that it is our standard practice to refrain from publicly commenting on the substance of any witness interview, and we intend to abide by that practice in this case. Beyond that, we can make no commitments. Please advise as to whether Prince Andrew will agree to be interviewed and, if so, when such interview will take place.

Regards,



Assistant U.S. Attorney
Southern District of New York

- Document type: Email header (screenshot)
- Top context: "Assistant U.S. Attorney, Southern District of New York" visible
- From: [name redacted]
- Sent: Monday, February 03, 2020 10:46
- To: [recipient(s) redacted]
- Cc: multiple recipients [names redacted]
- Subject: Re: U.S. Department of Justice investigation
- Notes: Many fields heavily redacted; no attachments or body text shown.

Dear



Thank you for your email of 30 January 2020.

On 10 January 2020 you personally assured me that any contact between the Duke of York and the DOJ was confidential and would remain confidential within the investigation team in the DOJ and FBI. You said: "We don't intend to share either the contents or the existence of the conversation beyond our chain of command in the DW. As wellas our partners at the FBI. It is confidential within the investigation team and our supervisors." The note I made of what you said about the confidentiality of the interview process is as follows: "We do not publicise the content or existence of any ofour interviews. We can't guarantee that anyone might not share it with some otherperson or it might be shared with other individuals who might come to have knowledge of its existence, but our office does not advise the press of the interview and doesn't advise other interviewees ofthe fact the interview has taken place or the contents of those discussions. For example, it was reported widely that our office was attempting to interview your client months ago which was inaccurate. We have been working on this request for several weeks now andit has not hit the press. That is consistent with our processes. We take confidentiality very seriously."

At no point did you suggest that, because of a press statement made on behalf of the Duke in November 2019, you or your colleagues in the investigation team would feel able to provide a public commentary on the DOJ's views on

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the degree of cooperation provided by the Duke. DOJ's first contact of any kind with the Duke was in early January 2020, and the first mention of any request for consideration of an interview came solely from you.

I object to your wholly inaccurate statement that the Duke has created a public misimpression. The Duke has made it clear that he has a strong desire to cooperate fully with the ongoing investigation by the Dal. The communications between us were intended to enable him to provide that co-operation. In order for this process to continue, I need to emphasise that we regard the confidential treatment of all contacts between the Dal and the Duke as essential. We do not wish to have any public pronouncements on what we regard as a voluntary and confidential process. Please confirm that any further communications in connection with the requested voluntary interview will be treated as wholly confidential and the DOJ will offer no further commentary on the Duke's co-operation.

Best

Gary Bloxsome

*   **Name:** Gary Bloxsome
*   **Title:** Partner
*   **Firm:** Blackfords LLP
*   **Website:** www.blackfords.com
*   **Rankings:** Ranked in Chambers UK 2020, The Legal 500 Top Tier 2020

Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 1EA. A list of members' names is available at this address.

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On 30 Jan 2020, at 23:51, > wrote:

## External email: is it safe to open attachments and links?

## Gary,

On November 20, 2019, Prince Andrew publicly offered to cooperate with our investigation into Jeffrey Epstein's crimes, stating in a press release: "Of course, I am willing to help any appropriate law enforcement agency with their investigations, if required." In early January 2020, our Office responded to the Prince's public offer by contacting you to set up the interview that the Prince claimed to be willing give us. More than three weeks after our initial contact with you, we still had no date for an interview, nor did we even have a commitment from you that the Prince in fact would agree to an interview.

On January 27, 2020, at a press event held by Safe Horizon to which Mr. Berman was invited, Mr. Berman was asked: "As part of [the Epstein] investigation have you reached out to interview Prince Andrew, and has he been cooperative?"

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Mr. Berman responded: "Ordinarily, our office doesn't comment on whether an individual cooperates or doesn't cooperate with our investigation. However, in Prince Andrew's case, he publicly offered, indeed in a press release, offered to cooperate with law enforcement investigating the crimes committed by Jeffrey Epstein and his coconspirators. So I think in that context, it's fair for people to know whether Prince Andrew has followed through with that public commitment. So let me say that the Southern District of New York and the FBI have contacted Prince Andrew's attorneys and requested to interview Prince Andrew and to date, Prince Andrew has provided zero cooperation."

Mr. Berman's statement corrected a public misimpression — created by the Prince himself — that the Prince is cooperating with our investigation.

As soon as the Prince commits to a date for the interview that he so publicly offered to us more than two months ago, we would be prepared to announce that he has agreed to be interviewed.

Email Summary:

*   **Sender:** Gary Bloxsome
*   **Recipient:** (Redacted)
*   **CC:** (Redacted), Jennifer Richardson, Daniel Cundy
*   **Date:** Tuesday, January 28, 2020, 11:59
*   **Subject:** Re: U.S. Department of Justice investigation

Assistant U.S. Attorney, Southern District of New York is also mentioned.

Dear [ ]

Thank you for your email response claiming that US Attorney Berman's statements were factually accurate and did not create a misleading impression.

We only have access to edited video and newspaper reporting of what the US Attorney said. Those reports suggest the US Attorney described the position of the Duke of York and his advisors in misleading, condemnatory and prejudicial terms. US Attorney Berman is quoted as having stated there has been "zero co-operation". This is not an accurate statement of the position. The following are also false statements ascribed to Mr Berman and to the DOJ/FBI: "F.B.I. agents and federal prosecutors in New York ... reached out to his lawyers and asked to interview him. There was no response at all, according to three people familiar with the investigation." (New York Times 27.01.20) and "Geoffrey Berman, a US attorney, said federal prosecutors and the FBI had asked to interview Prince Andrew about the late paedophile billionaire, but had been met with a wall of silence"(The Telegraph 28.01.20).

Please provide us with an accurate record of the statements made by The US Attorney and/or the DOJ/FBI including a transcript of any relevant questions and answers.

We note from your email that you have not provided any response to our request that you confirm that the DOJ will not be making any further public statements about the Duke of York. We had understood from our conversations with you and from the rules governing media relations that DOJ personnel and the US Attorney would not comment on the nature or progress of any grand jury investigation and in particular would not comment on the willingness of any Subject to make a voluntary statement to the DOJ. We ask you to confirm that there will be no further public comment on any contact between the Duke of York and the Dal.

## Kind regards

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Gary

Gary Bloxsome I Partner

Kimage001.jpg> <image002.jpg>

Blackfords LLP
www.blackfords.com

Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1Mint Walk, Croydon, CR0 lEA. A list of members' names is available at this address.

GDPR: details of how we handle personal data can be found in our Privacy Statement

Authorised and regulated by the Solicitors Regulation Authority under number 462078.

On 27 Jan 2020, at 22:59, wrote:

## External email: is it safe to open attachments and links?

## Gary,

Our understanding is that U.S. Attorney Berman made a factual statement in response to a specific question that suggested the Duke of York either would or was cooperating, and he responded that to date he has not in fact provided cooperation with our investigation. That is, he corrected the record generally in a factually accurate statement; I don't believe this would create a misleading impression. I appreciate that you have advised us that your client has a desire to cooperate, and we look forward to hearing from you when he has made a determination as to whether he is in fact willing to speak with us.

## Regards,



| Field | Value |
|---|---|
| From | [name visible in image — withheld] |
| Sent | Monday, January 27, 2020 13:44 |
| To | [one or more recipients — addresses redacted] |
| Cc | [multiple recipients visible — names withheld; at least two additional entries redacted] |
| Subject | Re: U.S. Department of Justice investigation |
| Notes | Image shows heavy black-bar redactions over most names and email addresses.

The press are reporting that Geoffrey S. Berman, the United States Attorney for the Southern District of New York has disclosed what we understood were confidential communications between us and and

It has also been suggested that Geoffrey S. Berman has stated that the Duke of York has not co-operated with the Southern District. As you know we have made it very clear that the Duke of York has a strong desire to cooperate with the ongoing investigation by the DOJ and we are trying to reach a position where we are able to advise him to do so.

We are concerned about the misleading impression that has been created and the effect this has on our ability to advise the Duke to proceed with any voluntary co-operation. Please confirm that the DOJ will not be making any further public statements on this topic.

Thank you.

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Gary Bloxsome

- Role: Partner (name redacted)
- Firm: Blackfords LLP
- Website: www.blackfords.com
- Legal form: Limited liability partnership registered in England & Wales
- Company reg. number: OC325398
- Registered office: Hill House, 1 Mint Walk, Croydon, CR0 1EA
- Members' names: list available at registered address
- GDPR: details available in Privacy Statement (link referenced)
- Regulator: Solicitors Regulation Authority, number 462078
- Email thread line: On 22 Jan 2020, at 17:34, [sender redacted] <[redacted]> wrote:

## External email: is it safe to open attachments and links?

## Gary,

We've received your response. We look forward to hearing whether the Duke of York is willing to speak with us.

- Top line: "thank you," followed by a large redaction block.
- From: [name redacted]
- Sent: Wednesday, January 22, 2020 11:35
- To: [recipient(s) redacted — email addresses redacted]
- Cc: [multiple recipients redacted]
- Subject: Re: U.S. Department of Justice investigation
- Visual note: Several black redaction blocks obscure names and email addresses in the header.

We are very grateful for your offer of assistance. At present we do not believe you can help us but we would welcome a real-time conversation once we have achieved some of the more immediate preliminary tasks, including the need to gather information from the Royal Household and others. Best

- Organization: Blackfords LLP  
- Individual: name redacted in image — Role: Partner  
- Website: www.blackfords.com  
- Address (from surrounding text): Hill House, 1 Mint Walk, Croydon, CR0 1EA  
- Registered number (from surrounding text): OC325398 (registered in England & Wales)  
- Note: signature block contains multiple redacted (black-bar) lines.

8lackfords LIP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk. Croydon, CR0 lEA. A list of members' names is available at this address.

GDPR: details of how we handle personal data can be found in our Privacy Statement

Authorised and regulated by the Solicitors Regulation Authority under number 462078.

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On On 20 20 Jan Jan 2020, 2020, at at 18:52, 18:52,

> > wrote: wrote:

External email: is it safe to open attachments and links?

## Gary,

Thank you for your response. It would be useful for us if you were able to help us understand the nature of the issues and procedures with which you are dealing, particularly as it sounds like it will take at least a couple additional weeks to address even minor preliminary issues, which suggests likely additional subsequent time to handle further processes—and without a response to the question of whether he is willing to speak with us, separate from a general desire to cooperate. Our investigation is moving forward expeditiously and so we would be grateful for some understanding of the relevant issues (especially, though not exclusively, to the extent we may be able to assist in their resolution) and would be happy to speak via phone if a real-time conversation would be more conducive to that discussion.

## thank you,



| Field | Value |
|---|---|
| From | Gary Bloxsome |
| Sent | Monday, January 20, 2020 11:23 |
| To | Multiple recipients (redacted) |
| Cc | Multiple redacted; Jennifer Richardson; Daniel Cundy |
| Subject | Re: U.S. Department of Justice investigation |
| Notes | Many names/addresses redacted in image. Surrounding text references the Duke of York's desire to cooperate fully with the DOJ investigation.

Thank you for your email. The Duke of York has made it clear to us that he has a strong desire to cooperate fully with the ongoing investigation by the DOJ.

It is our responsibility to deal with the various issues and procedures that arise here that will need to be addressed to enable him to do so. We should be able to deal with at least some of the minor preliminary issues in the next two weeks and we will update you on our progress once we have done so.

Regards,

Gary

- Name: (personal name present in signature — redacted / not disclosed)
- Title: Partner
- Firm: Blackfords LLP
- Website: www.blackfords.com
- Image links shown: <image001.jpg>  <image002.jpg>
- Several contact lines are blacked out (likely address/phone/email)
- Surrounding/company registration (from context): Blackfords LLP, registered in England & Wales, registered number 0C325398, Hill House, 1 Mint Walk, Croydon, CR0 1EA.

Blackfords LLP is a limited liability partnership registered in England & Wales with registered number 0C325398 at Hill House, 1 Mint Walk, Croydon, CRO lEA. A list of members' names is available at this address.

GDPR: details of how we handle personal data can be found in our Privacy Statement

EFTA00017047

Authorised and regulated by the Solicitors Regulation Authority under number 462078.

On 18 Jan 2020, at 01:06, wrote:

## External email: is it safe to open attachments and links?

## Gary,

We write to follow up on our phone conversation of a week ago. Could you please advise regarding status, in particular the initial question, separate from any logistics, of whether you expect your client will be willing to speak with us? And of course please let us know if any additional information would be useful to you.

## thank you,



Email details:
*   From: Gary Bloxsome
*   Sent: Wednesday, January 08, 2020 07:38
*   Cc: Daniel Cundy, Jennifer Richardson
*   Subject: Re: U.S. Department of Justice investigation

Thank you for your email.

Friday 10th January at 1400(LDN) time is fine.

Please forward dial in details.

Kind regards

Gary

Gary Bloxsome is a Partner at Blackfords LLP. Their website is www.blackfords.com.

8lackfords LLP is a limitec Tabil q• partnership registered in ing,ana & Wales with registered number O[325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. A list of members' names is available at this address.

G0PR: details of how we handle personal data can be found in our Privacy Statement

EFTA00017048

Authonsed and regulated by the Solicitors Regulation Authority under number 462078.

On 7 Jan 2020, at 18:56, wrote:

## External email: is it safe to open attachments and links?

## Gary,

We are available for a preliminary call this Friday, January 10. If it would be convenient for you, we are available at 9:00 local time for us (which I believe would be 14:00 your time). If that works, we can plan to call you at your office line unless you'd prefer we use another number or a conference line.

## thank you,



- From: [name redacted]
- Sent: Tuesday, January 07, 2020 11:20
- To: [recipient(s) redacted]
- Cc: [multiple recipients redacted]
- Subject: Re: U.S. Department of Justice investigation
- Notes: Header contains extensive black redactions; surrounding text includes "Thank you for your email."

Thank you for your email.

Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.

Kind regards.

Gary

| Field | Value |
|---|---|
| Name | [redacted] (shown as blacked-out) |
| Role | Partner |
| Firm | Blackfords LLP |
| Website | www.blackfords.com |
| Firm status | Limited liability partnership registered in England & Wales |
| Registered number | OC325398 |
| Registered address | Hill House, 1 Mint Walk, Croydon, CR0 1EA |
| Regulation | Authorised and regulated by the Solicitors Regulation Authority (SRA) under number 462078 |
| GDPR / Privacy | "Privacy Statement" link referenced |
| Visible redactions | Multiple contact lines (email/phone) blacked out |
| Timestamp in surrounding text | On 4 Jan 2020, at 01:38 |

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External email: is it safe to open attachments and links?

Mr. Bloxsome,

Thank you for your response and for confirming your representation. To respond to your question generally, in connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to request a consensual, voluntary law enforcement interview with your client. Generally, we would expect to inquire about his relationship and communications with Jeffrey Epstein and his associates, as well as certain allegations that have arisen publicly and in our investigation to date.

Although we recognize we separately have the ability to convey such a request through diplomatic and law enforcement channels, we understand we may also alternatively inquire directly with counsel, when an individual has legal representation. Given your representation, we are inquiring directly with counsel in the first instance.

Certainly we can discuss our request in more detail, but we hope this will provide the information you were seeking as a threshold matter, and we look forward to being in touch.

Regards,



Assistant U.S. Attorney
Southern District of New York

| Field    | Value                                                     |
| -------- | --------------------------------------------------------- |
| From     | Gary Bloxsome                                             |
| Sent     | Friday, January 03, 2020 10:30                            |
| To       |  [Redacted]                                               |
| Cc       | [Redacted], Daniel [Redacted], Jennifer Richardson [Redacted] |
| Subject  | Re: U.S. Department of Justice investigation              |

Dear Sirs,

Thank you for your email dated 2 January 2020.

I confirm that we do represent HRH the Duke of York.

I would be grateful if you could please clarify what specifically you invite us to contact you about.

Kind regards

Gary Bloxsome

Gary Bloxsome I Partner

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## Blackfords LLP ||

www.blackfords.com

Blackfords LIP is a limited liability partnership registered in England & Wales with registered number O(325398 at Hill House, 1Mint Walk, Croydon, CR0 lEA. A list of members names is available at this address.

GOPR: details of how we handle personal data can be found in our Privacy Statement

Authorised and regulated by the Solicitors Regulation Authority under number 462078.

On 2 Jan 2020, at 18:54, wrote:

External email: is it safe to open attachments and links?

Mr. Bloxsome,

We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department of Justice, Southern District of New York. We have been advised that you currently represent HRH The Duke of York. Could you please advise whether that is correct? We — my colleagues S and I — can be reached anytime at these email addresses, or please let us know if you would prefer to set up a time to discuss via phone.

Regards,



Assistant U.S. Attorney
Southern District of New York

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