ROY BLACK
HOWARD M. SREBNICK
SCOTT A. KORNSPAN
LARRY A. STUMPP
MARIA NEYRA
JACKIE PERCZEK
MARK A.J. SHAPIRO
JARED LOPEZ

BLACK
SREBNICK
KORNSPAN
& STUMPF
=P.A.

JESSICA FONSECA-NADER
KATHLEEN P. PHILLIPS
AARON ANTHON
MARCOS BEATON, JR.
MATTHEW P. O'BRIEN
JENIFER J. SOULIKIAS
NOAH FOX

E-Mail:

# December 9, 2009

Assistant United States Attorney
United States Attorney's Office
Southern District of Florida
500 South Australian Avenue
Suite 400
West Palm Beach, Florida 33401

## RE: Jeffrey Epstein

Dear

You emailed me a letter on November 2, asking whether Jeffrey Epstein's place of employment remained constant. It has. I reviewed a Google map to confirm that the distance between that place of employment and the location where he was stopped by Palm Beach Police is less than 3 miles (and that the location where he was walking was on a direct route to his place of work).

# December 9, 2009 (cont.)

## RE: Jeffrey Epstein (cont.)

It has taken us a while to respond to your letter because other matters have consumed our time and effort. Over the past five weeks, the massive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the Complaint is enclosed with this letter.

As you know, Rothstein's firm represents | and three of the plaintiffs who have brought civil actions against Mr. Epstein. The Rothstein firm was a criminal enterprise that used the litigation against Mr. Epstein to lure investors into its billion-dollar ponzi scheme. We believe that Rothstein and his co-conspirators used the government's criminal investigation as a means to perpetrate and further their fraud. For example:

201 S. Biscayne Boulevard, Suite 1300 Miami, Florida 33131 Phone: 305-371-6421 • Fax: 305-358-2006. www.RoyBlack.com

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December 9, 2009

Page 2

# December 9, 2009 (cont.)

## RE: Jeffrey Epstein (cont.)

1. The Rothstein lawyers sought disclosure of the NPA to prove who the victims were, and used the NPA to "corroborate" their false claims.

2. Rothstein and his co-conspirators abused the legal process in other cases. They forged the signature of judges, and even forged an Eleventh Circuit opinion.

	3. Rothstein lawyers demanded phony protective orders.

4. In our case, they sought discovery of Epstein's plane logs to fish for celebrities to extort and convince investors that huge amounts of settlement money was available from them.

5. Rothstein lawyers litigated claims using Jane Doe names to make the phony settlements appear plausible to investors, and also to prevent any investigation into the claims by the investors.

6. Rothstein and others told investors that your office directed the women to the Rothstein firm.

# December 9, 2009 (cont.)

## RE: Jeffrey Epstein (cont.)

7. Rothstein and his co-conspirators gathered information illegally, and shared it with the other plaintiffs' attorneys in this case.

8. Rothstein deceived investors into believing that he had the confidential victim list you prepared, and that he had a copy of the NPA.

9. Rothstein told investors that his investigators had sophisticated electronic bugging equipment to gather evidence against Epstein.

10. Rothstein told investors that Epstein had offered to settle the cases for $200 million, when there have been no such discussions about any settlement at any price.

And it does not stop there. Rothstein, his partners, and his employees

investigated and litigated the

and



cases with funds derived

from their criminal enterprise and their fraud and misrepresentations to investors.

But we have been stymied from debunking fraudulent claims brought by the

Rothstein criminal enterprise because you have threatened that such action on

Black, Srebnick, Kornspan & Stumpf, P.A.

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December 9, 2009

Page 3

# December 9, 2009 (cont.)

## RE: Jeffrey Epstein (cont.)

our part would constitute a breach of the NPA. So the Rothstein lawyers, once again, are using the power of the federal government to perpetrate and further their fraud. And the expense of litigating these cases has been extreme. For example, who I do not believe was aware of the Rothstein crimes, is now demanding over $2 million in legal fees.

As a lawsuit brought by some of the investors' claims, Rothstein and his partner Edwards used Jeffrey Epstein as bait. The litigation strategy, media pronouncements, and investigatory initiatives of Rothstein and Edwards were calculated to support Rothstein's deceptions rather than to advance the position of his clients. I bring these facts to your attention so that if you had contact with Edwards or those associated with him in the past concerning Mr. Epstein, you consider not continuing communications with any of them in the future.

# December 9, 2009 (cont.)

## RE: Jeffrey Epstein (cont.)

I would like a short conference with you in person to talk about Mr. Epstein's progress through the state criminal justice system, to discuss several outstanding issues that I want to make sure you have accurate information about, and, from my perspective, most importantly, so that I can provide Mr. Epstein with proper counsel going forward. If you email me some dates when you are available this month, we can schedule a short meeting in your office hopefully before the year ends.

Sincerely,
Ron

Roy Black

RB/wg

Enclosure

Black, Srebnick, Kornspan & Stumpf, P.A

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