From: "Weinstein, Marc A.
To:
Cc: Andrew Tomback ■
Subject: RE: SDNY investigation
Date: Wed, 30 Sep 2020 17:51:56 +0000
Attachments: CMA)_-_Vol.
The transcripts are attached. We trust that the US Attorney's Office will keep these confidential other than to the extent
disclosure is required in any pending case.
Regards,
Marc
Marc A. Weinstein I Partner
Chair. White Collar Defense
Hughes Hubbard & Reed LLP
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From: Weinstein, Marc A.
Sent: Wednesday, September 30, 2020 12:03 PM
To:
Cc: Andrew Tomback
investigation
I connected with Jack Scarola last week. I just sent him an email to confirm that we can provide you with the
transcript. Once we receive confirmation from him, we will send you the transcript.
Best regards,
Marc
From:
Sent: Tuesday, September 29 2020 3:40 PM
To: Weinstein, Marc A. C
Cc: Andrew Tomback
Subject: RE: SDNY investigation
EFTA00020881
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Hope you're doing well. I wanted to check in on the status of this issue — have you been able to connect with Mr. Scarola?
Thanks,
From: Weinstein, Marc A.
Sent: Tuesday, September
To:
Cc: Andrew Tomback
u ject: RE: SDNY investigation
Thanks =. I will give him a call.
Marc A. Weinstein I Partner
Chair. While Collar Defense
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disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
.r l rr .r . r •r I ' .•r • • .•r., `.. '.inranteed to be secure or error-free as information could be intercepted, corrupted, lost,
sender therefore does not accept liability for any errors or omissions in the contents of this
.orification is required please request a hard-copy version.
From:
Sent: Tuesday, September 22, 2020 4:42 PM
To: Weinstein, Marc A.
Cc: Andrew Tomback
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Thanks for following up on this. If it's okay with you, I think it makes sense to connect you with the plaintiff's attorney,
Jack Scarola, so that he can convey this to you directly. I have spoken with him and explained the context here, and he
has told me that he would be happy to speak with you. He is also seeking a copy of the transcript, as he has informed me
that he no longer has his case files for matters this old. Here is his contact information:
Jack Scarola
EFTA00020882
Thank you,
From: Weinstein, Marc A.
Sent: Tuesday, September 22, 2020 11:24 AM
F>
To:
Cc: Andrew Tombac
Subject: RE: SONY investigation
We haven't found a governing protective order, but to be safe, would you be able to get a letter or email fro
attorney stating that they are not aware of a protective order/agreement governing the disclosure of the transcript, an
to the extent one existed, they are waiving any provisions in order to permit the Estate to provide the transcript to the US
Attorney's Office, and that they will not claim, in any forum, that the Co-Executors, the Estate, or any representatives of
either, breached any such order/agreement in that case by providing the transcript to the US Attorney's Office.
Let us know if that works on your end.
Best regards,
Marc
Marc A. Weinstein I Partner
Chair. Mile Collar Defense
Hughes Hubbard & Reed LLP
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disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
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From:
Sent: Monday, September 14, 2020 3:01PM
To: Weinstein, Marc A.
Cc: Andrew Tomback
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Thanks — we have conferred with plaintiff's counsel, who has informed us that he is unaware of any protective order
relating to th- lawsuit.
Best,
EFTA00020883
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
From: Weinstein, Marc A. <
Sent: Monda Se tember
To
Cc:
Subject: Re: SDNY investigation
we are still looking to see what confidentiality restrictions might apply. If her lawyer has any such confidentiality
or protective order that governed the case, it might be helpful if you could obtain and share that.
Marc A. Weinstein I Partner
Coarr. Waite Co lar Du!ense
Hughes Hubbard & Reed LLP
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disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
Sr] thuorfore does not accept liability for any errors or omissions in the contents of this
'ed please request a hard-copy version.
On Sep 14, 2020, at 11:56 AM, > wrote:
CAUTION: This email was sent by someone outside of the Firm. ■
Marc,
Thanks very much. Are you able to provide it to us? If there are any issues with providing it to us, or if a call would be
useful to discuss, please let us know.
Thanks,
From: Weinstein, Marc A.
Sent: Monday, September 14, 2020 11:51 AM
To:
Cc: Andrew Tomback
Subject: RE: SDNY investigation
we have the transcript of deposition.
Regards,
EFTA00020884
Marc
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
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disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
ma I ' • ctem. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
des• ate or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
mr -e as a result of e-mail transiniss,on. If verification is required please request a hard-copy version.
From:
Sent: Friday, September 11, 2020 1:40 PM
To: Weinstein, Marc A
Cc: Andrew Tomback
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
Thanks, Marc. We'll look forward to hearing from you, and thanks for your assistance with this.
From: Weinstein, Marc A.
Sent: Friday, September 11, 2020 1:35 PM
To:
Subject: RE: SDNY investigation
Thanks i It wasn't clear to me from the call that it was the plaintiff's deposition that you were after, as opposed to
another witness in the case. Now that it's clear, we will see if we can track it down.
Regards,
Marc
Marc A. Weinstein I Partner
cnay. V r, to Co as Du!ensc
Hughes Hubbard & Reed LLP
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disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
. ' • incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Friday, September 11, 20201:30 PM
To: Weinstein, Marc A
Cc: Andrew Tomback <
EFTA00020885
Subject: RE: SONY investigation
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Thanks for speaking earlier. The plaintiff's name is who is represented by Jack Scarola. The deposition
took place in 2009, and Jeffrey Epstein was represented by Mark Luttier and Bob Critton of Critton, Luttier, and Coleman
LLP in West Palm Beach.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York. NY 10007
From: Weinstein, Marc A. >
Sent: Frida Se tember 11 202011:11AM
To
Cc: Andrew Tomback
>
Subject: RE: SDNY investigation
I just realized that you didn't share with us the deponent's name for the transcript you are looking for. Let us
know so that we can make the appropriate inquiries.
Best regards,
Marc
Marc A. Weinstein I Partner
Chair, Valle Collar Defense
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disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Thursday, September 10, 2020 11:14 AM
To: Weinstein, Marc
Cc: Andrew Tomback
Subject: RE: SDNY investigation
EFTA00020886
CAUTION: This email was sent by someone outside of the Firm.
That works well, thanks very much. Talk to you then.
From: Weinstein, Marc A.
Sent: Thursday, September
. ",
To:
Cc: n rew om ac
Subject: Re: SDNY investigation
I'M if 11:00 works, I can send a dial-in.
Marc A. Weinstein I Partner
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
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• h ••• L cf ••• - friAil ITAIICMiCtill11 V yarifiratinn is ranilircvl nlanca n.nitact n hard -copy version.
On Sep 10, 2020, at 10:46 AM, wrote:
CAUTION: This email was sent by someone outside of the Firm.
Andy and Marc,
Are you available for a brief call tomorrow? I'm available before 1 p.m., if there's a time that works for you in that window.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020887