riptaon 3501 134 COI 2005 11 16 Florida DAV I D indnidual summa f et Paul Lavwy 3501.07-037 2005.11.16 Florida DAVID. minsdual summary page for Paul Lavery 3501.134 033 3005.11.22 Leah Noels business report rout for Do Yotrutlf a Favor Inc 3501 I OM 3005.1.22 Leah Nexis person moon results for Pau

June 6, 2007 VIA FACSIMILE Robert I. Targ, Esq. Diaz Reus Rolff & Targ LLP 100 S.E. Second Street, Suite 2600 Miami, FL 33131 Re: Subpoena to Paul Lavery Dear Mr. Targ: Thank you for your letter of June 4, 2007. Following receipt of your letter, I conducted some additional research regarding your bl

y have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

y have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. EPSTE

tein is aware of that classification at this time. From the physical description of the private investigator, I knew that Banasiak was referring to Paul Lavery, a private investigator who had traveled to the homes of several victims. 11. A grand jury subpoena was served on Mr. Lavery at his office in Miami.

refers to as warran ff i ce. F6 Through the FBI's investigation, it was determined that at some point before the execution of the search a l and Paul Lavery, a private investigator, traveled to Epstein's house and collected the computers, which were later turned over to William Riley, the subpoenaed part

y have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

anything with them, and a private investigator came and took them away. Based upon his description. we determined that the private investigator was Paul Lavery. We subpoenaed Paul Lavery. who tried to assert a blanket attorney-client privilege/work product immunity. I informed his attorney that he would ne

EY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton From: William Riley / Paul Lavery Date: August 8, 2009 Re: Epstein /-/ interview Brian Feeney) File: 8577R On Friday, August 7, 2009, Investigator Paul Lavery interviewed Bria

GE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton / Michael Burman From: William Riley / Paul Lavery Date: August 4, 2009 Re: Epstein / / interview Barbara and Martie Rutledge File: 8577R On Tuesday, July 28, 2009, Investigator Paul Lavery in

EY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton From: William Riley / Paul Lavery Date: August 4, 2009 Re: Epstein / / former employer, File: 8577R On Monday, August 3, 2009, Investigator Paul Lavery completed inquiry conc

EY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton From: William Riley / Paul Lavery Date: August 4, 2009 Re: Epstein / / interview Tiffany Avery File: 8577R On Tuesday, July 28, 2009, Investigator Paul Lavery interviewed Tiff

TOR CLIENT PRIVILEGE To: Roy Black From: William Riley Date: October 9, 2005 Re: Jeff Epstein File: 8577R On October 7, 2005, Investigator Paul Lavery visited the residence of Jeff Epstein, 358 El Brillo Way, Palm Beach, Florida and pursuant to the instructions of attorney Roy Black removed items

pstein's home, they found computer monitors and equipment, but no CPUs. From the continued investi ,ation we know that the computers were removed by Paul Lavery, a private investigator, with the help of one of our targets. Now that we know that Lavery removed the computers, I would like to subpoena the comp

have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.