A. Marie Villain& Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Brendan White [malito:[email protected]] Sent: Thursday, June 26, 2008 10:38 AM To: Vlllafana, Ann Marie C. (USAFLS) Subject: Re: Grand Jury Appearance Dear Ms. Villafana: I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been executed. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on with respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered immunity? Thanks. Brendan White Original Message -- Freim: Vil Ana &Wert (USAFLS) To: Brendan White Sent: Monday, June 23, 2008 2:09 PM Subject: RE: Grand Jury Appearance Dear Mr. White: Please feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be reimbursed, they must be made through the government's approved agency on the approved carriers. Regarding the immunity, at this point, without a written proffer from you regarding the substance of her anticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to criminal liability, then I can make tte motion ahead of time. Your written statement would be treated as an attorney statement made in the course of confidential plea discussions and related negotiations, and would be governed by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Brendan White (mailto:[email protected]] Sent: Monday, June 23, 2008 1:45 PM To: Villafana, Ann Marie C. (USAFLS) Cc: Ball, Shawn (USAFLS) Subject: Re: Grand Jury Appearance 08-80736-CV-MARRA P-015003 113 EFTA00225397