From: To: Sigrid McCawley Subject: RE: Deposition Subpoena/Notice Date: Mon, 13 Apr 2020 19:09:12 +0000 Thank you. From: Sigrid McCawley Sent: Monday, April 13, 2020 15:06 To: Subject: FW: Deposition Subpoena/Notice Sigrid McCawley Partner BOIES SCHILLER FLEXNER LLP From: Daniel J. Kaiser [mailto Sent: Monday, April 13, 2020 2:35 PM To: Sigrid McCawley Cc: Josh Schiller ; Sabina Mariella Andrew Villacastin Subject: Re: Deposition Subpoena/Notice CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender. Her criminal lawyers have told me that until the criminal proceedings are done she is asserting her fifth amendment rights. So if you want substantive testimony you will have to wait. Out of curiosity have any of your clients been criminally pursued for their role in recruiting for Epstein? My client never did any recruiting which is far worst than anything she is accused of. And in any event, mid-May given the current crisis will not work. Dan Daniel J. Kaiser Kaiser Saurborn & Mair, P.C. EFTA00030316

On Apr 13, 2020, at 1:13 PM, Sigrid McCawley wrote: Hello Daniel, Thank you for accepting service of the subpoena for We will consider any suggestion you have with respect to date and location of the deposition if you make them promptly, but we do not accept that you have the unilateral right to dictate anything about the deposition—your client has an obligation to appear unless the Court decides otherwise in response to a prompt motion by you. Let me know if you have a different date in early to mid-May that you would like to propose. Thanks, Sigrid Sigrid McCawley Partner BOIES SCHILLER FLEXNER LLP From: Daniel J. Kaiser [mailto Sent: Friday, April 10, 2020 5:31 PM To: Sigrid McCawley Cc: Josh Schiller Sabina Mariella ; Andrew Villacastin Subject: Re: Deposition Subpoena/Notice CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender. I will accept service subpoena. I take no position at this time regarding the assertion of her Fifth Amendment rights. The place and timing of any deposition must be coordinated with me and agreed to by me. Dan Daniel J. Kaiser Kaiser Saurborn & Mair, P.C. On Apr 10, 2020, at 5:03 PM, Sigrid McCawley < wrote: EFTA00030317

Hello Daniel, It is my understanding that you now represent and are willing to accept service of a subpoena on her behalf. If I am incorrect, kindly let me know. It is also my understanding that she will no longer be asserting her 5th Amendment Privilege. Accordingly, I am attaching a subpoena for her deposition and a Schedule A for documents that we will need from Ms _in advance of her deposition. Thank you, Sigrid Sigrid McCawley Partner BOIES SCHILLER FLEXNER LLP The information contained in this electronic message is confidential information intended only for the use of the named recipientts) and may contain information that, among other protections. is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination. distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error• please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSFI <2020-04-10 Depo Notice May <2020-04-10 Subpoena & Schedule A to Subpoena May 7.pdf> EFTA00030318