Epstein Secrets

KIRKLAND & ELLIS LLP MEMORANDUM Attorney Work Product Privileged and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric

o impart correct information to another. The special relationship requires a closer degree of trust than that in an ordinary business relationship." Wright v. Selle, 27 A.D. 3d 1065, 1066-67 (4th Dep't 2006). Thus, Jeepers would need to establish that Dubin had a special relationship of trust that crea

EFTA00185238 U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: 500 S Australian Ave, Ste 400 West Palm Bea

stitutionality or even impropriety. Incendy at 956 (citing United States' Kordel, 397 U.S. I, 11 (1970)). See also Securities and Exchange Comm'nl. Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o 'special circumstances' existed in this case warranting a stay, as there is no record evidence sug

07/29/2011 13:11 FAX E6 0 0 1 /004 KIRKLAND & ELLIS LLP Fax Transmittal 300 North LaSalle Street Chicago, Illinois 60654 Phone: (312) 882-2000 Fax: (312) 862-2200 Please notify us Immediately if any

laim against Robson must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. Cf. Churr