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ligence United States Senate Washington, E. 20510 Re: $ubpoena to lieutenant General Michael T. Flynn (Reta Dear Chairman Burr and Vice Chairman Warner: We write in response to the Senate Select Committee on Intelligence's subpoena dated May 10, 2017, requesting that our client, Lieutenant General
o demonstrate prior knowledge of requested subpoenaed documents, the act of producing those documents is testimonial. Two Supreme Court precedents, Fisher v. United States, 425 U.S. 391 (1976) and United States v. Hubbell, as well as Hubbell's progeny, United States v. Ponds, 454 F.3d 313 ( Cir. 2006
e taxpayer adds little or nothing to the sum total of the Government's information by conceding that he in fact has the papers." Id. In contrast to Fisher, a case in which investigators already knew that documents existed and exactly where they were located, the investigators in Hubbell lacked "any pri
of 1988. accompankd by Epstein 's promise to pay more of the debt upon his receipt of personal funds. See Commissioners of the State Ins. Fund I Warner. 156 A.D.2d 131, 548 N.Y.S.2d 883, 883 (1st Dept 1989) (stating the common law rule that the statute of limitations will be tolled if it is reason
case on December 17, 1997. Defendants' sole remaining defenses are that (1) 0FM orally consented to Epstein's proposed sublet of the premises to Fisher, and (2) 0FM did not properly terminate Epstein's lease be- Ron Soifer, and Carmen Tausik (collectively, the -Subtenants"). The Subtenants were add
dant Jeffrey E. Epstein in 1992. Epstein sublet the building to defendant Ivan S. Fish- er in 1996, purportedly without the Govern- ment's consent. Fisher, in turn, sublet a portion of the building to several subtenants. In 1996, the Government purported to ter- minate Epstein's lease and brought this
we are :able to cbtan a price for a septa. - Deposes a seines &nonrated n want other than LI S. dotes se reflected at the exchange rate as of the Warner< date. - For (ertar) SeCUllieS wading ri norscon envy denonwatonk pace ard curtly (We .aloe) nay have been adjusted to facilitate proper velure°
balances 6 the bark deposits May be with:lawn. and shays of a Money Fund may be lizmidated. and the proceeds retuned to you a you' secants acute Fisher incansion about available sweep options, socksing current a-barest rates and Yields. IS available at Amman rorrissemyekt, loom yOUt Financial Advis
Warier had a cou- ple of bad investments. and Jeffrey cleaned those up right away." says a former associ- ate of Epstein's. Before he signed on wih Warner. Epstein had several meetings with Harold Lamt then head of %leaner Investments. in which he enunciated ideas about currencies that Levin found i
ss. In 1998 the L.S. Attorney's Office sued Epstein thr illegally subletting the former home of the deputy consul general of Inn to attorney /van Fisher and cabers. Egstria D panipda5rtlmi n0n0t0. anumiontnehuninargreudnt IFonlinutterState veil his colleagues 520.000. Though the ev_v~ utenurmntsru
Entities connected to both Warner and Fisher

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
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Julie K. Brown
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Ghislaine Maxwell
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Donald Trump
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Department of Justice
ORGANIZATION
Prince Andrew
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Supreme Court
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Scarlett Johansson
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Joe Biden
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Alan Dershowitz
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Eric Trump
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Wilbur Ross
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Stephen Hawking
PERSONthe Southern District
LOCATION
Alexander Acosta
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Colorado
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Virginia Giuffre
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