The email is from Roberta Kaplan. The email is to an undisclosed recipient and "Conlon". The email is copied to L. Doniger.

Subject: RE: Transcript from yesterday's conference

Date: Fri, 13 Dec 2019 21:52:58 +0000

That is what Bennet Moskowitz said (I believe) at the earlier conference before M.J. Freeman
[ ] can you pls check the transcript? I know they have also said it to me directly and he certainly didn't disagree with me when I said it before J Failla.

Also: we got the Feinberg draft protocol today; its exactly as much of a disaster as we expected.
[ ] : psl send to [ ] along with their recent VI filings.

Robert a ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP

From: <empty>)
Sent: Friday, December 13, 2019 1:09 PM
To: Conlon <<empty>>; Roberta Kaplan <<empty>>
Subject: RE: Transcript from yesterday's conference

This is helpful and interesting, thanks very much for sending. Among other things, notable that Judge Failla assumes, even were punitive damages to be excluded, a claim "for millions upon millions of dollars."

Separately, Robbie, I noticed near the end of the conference you mentioned, at p. 27, that: "They [the estate and/or the trustees?1 have identified the sole beneficiary as Mr. Epstein's brother." I'm wondering if you might have a recollection of what the estate has said or represented to you about that? And if you recall whether any discussion of beneficiaries was in connection with the will versus the trust versus the estate, etc. Just if you feel comfortable sharing any of that information, of course—no obligation at all. And if it's more convenient to relay in real time, rather than drafting up an email, please don't hesitate to give a call. No emergency or rush, but did want to ask.

thanks,



From: Conlon <>
Sent: Thursday, December 12, 2019 18:34
To: <>
Cc: Roberta Kaplan <
Subject: Transcript from yesterday's conference

Hi there,

Attached is the transcript from yesterday's conference that Robbie described in the call today.
Take care,
<empty>
Conlon | Kaplan Hecker & Fink LLP

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