Epstein Secrets

3rd Street New York, New York 10022-4675 Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re' Jeffrey Eps

& Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re' Jeffrey Epstein Dear Messrs. Lefkowitz, Goldberger, and Black: I write to confirm my conversation with Mr. Lefkowitz of June 12, 2009. As I mentioned during that conversation and during the hearing

ack Goldberger Subject Have a great weekend! EFTA00213090 Exhibit 11 EFTA00213091 Jack Goldberger Sent: mas...J11:31 AM From: SAFLS) To: Jack Goldberger Cc: USAFLS); [email protected] Subject: Re: Notice of Non-Compliance Dear Jack: I have conferred with a state court practitioner who stated that

ts, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

e set promptly. On November 15th, Rolando Garcia met with Barry Krisher on another matter, and was told by Mr. Krisher that he had just spoken with Jack Goldberger, and that Mr. Epstein's plea and sentencing were set to occur on December 14, 2007. Since that time, we have tried to confirm the date and time of t

etters. You continue to refer to the plea and sentencing as though it will be in January; Mr. 1Crisher's office has not confirmed any date; and Mr. Goldberger recently told Marie WIlefaile that "there is no date?" I must reiterate that' delayed guilty plea and sentencing - now more than two months beyond

, their credibility and the foundations. il' any. for claiming personal istiory. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the Ponta of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to th

ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion

orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as

ed that, when defense counsel elected to put his investigator on the witness stand at trial, he must turn over the investigator's report pursuant to Jencks, but defense counsel can redact the report to only disclose that portion of the report that relates to the investigator's testimony. 7 EFTA006001

ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion

orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as

ed that, when defense counsel elected to put his investigator on the witness stand at trial, he must turn over the investigator's report pursuant to Jencks, but defense counsel can redact the report to only disclose that portion of the report that relates to the investigator's testimony. 7 EFTA006570

. As you will recall, the plea and sentencing hearing originally was to occur in early October 2007, but was delayed until October 26th to allow Mr. Goldberger to attend. It was delayed again until November to allow you to attend. You have provided no showing of how you and your client have used your best

be set promptly. On November 15th, Rolando Garcia met with Barry Krisher on another matter, and was told by Mr. Krisher that he had just spoken with Jack Goldberger, and that Mr. Epstein's plea and sentencing were set to occur on December 14, 2007. Since that time, we have tried to confirm the date and time of t

nts, their credibility and the foundations, if any, for claiming person! injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the tbnn of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

3rd Street New York, New York 10022-4675 Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re' Jeffrey Eps

& Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re' Jeffrey Epstein Dear Messrs. Lefkowitz, Goldberger, and Black: I write to confirm my conversation with Mr. Lefkowitz of June 12, 2009. As I mentioned during that conversation and during the hearing

ts, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

sentenced on October 26, 2007 is directly contradicted by Mr.. Simian's e-mail to me dated October $1 in which he states. "Your understanding from Jack Goldberger con:hems tomy understanding that Mr.. Epstein's plea and sentence will take place un the same day. I understand that the plea and sentence will occu

n which he states. "Your understanding from Jack Goldberger con:hems tomy understanding that Mr.. Epstein's p

s. their, credibility and the foundations. if any. fir claiming personal injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in tlx: form of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to th

might aid in impeaching government witnesses at trial, "the legislative history expresses a much greater concern with limiting the application of the Jencks decision so that it would not hamper the workings of law enforcement by forcing wholesale disclosure of government materials and files." 33° The Jen

a notes 483-493 and accompanying text. *65 Peter Goldberger, Statement on Behalf of the Nat'l Assoc. of Crim.