From: Richard Kahn
To: Jeffrey Epstein <jeevacation@gmail.com>
Subject: Noam
Date: Thu, 13 Dec 2018 16:26:56 +0000
still no reply from Vincent..
please advise
thank you
Richard Kahn
HBRK Associates Inc.
575 Lexington Avenue 4th Floor
New York, NY 10022
tel
fax
cell
Begin tbrwarded message:
From: Richard Kahn
Subject: Re: Mediation
Date: November 16, 2018 at 11:41:36 AM EST
To: Vincent Pisegna
no reason to delay as it is only about a number that Harry will want..
documentation should be left for court..
Richard Kahn
HBRK Associates Inc.
575 Lexington Avenue 4th Floor
New York NY 10022
tel
fax
cell
On Nov 14, 2018, at 2:07 PM, Vincent Pisegna > wrote:
No date set.
EFTA01013670
Original Message
From: Richard Kahn
Sent: Wednesday, November 14, 2018 2:07 PM
To: Vincent Pisegna
Subject: Re: Mediation
please advise on mediation timing
thank you
Richard Kahn
HBRK Associates Inc.
575 Lexington Avenue 4th Floor
New York NY 10022
tel
fax
cell
On Oct 29, 2018, at 8:25 PM, Vincent Pisegna < wrote:
Yes.
Sent from my iPhone
On Oct 29, 2018, at 8:13 PM, Noam Chomsky
:mailto >> wrote:
I understand. In that case, it seems that all that is necessary right now is to assure that the timing will work
out for Richard.
Noam
On Mon, Oct 29, 2018 at 9:10 AM Vincent Pisegna < mails
'> wrote:
Let me explain the process a bit so you can understand how this works. Our case is unusual because the
parties will participate by remote hookup, at least as presently contemplated. In any event, the mediation
will begin with all parties and counsel joining to hear a message from the mediator about the benefits of
settling the matter. The lawyers and the mediator will be in a conference room and the parties will
participate by Skype or similar hookup. The joint session is usually brief. Then the lawyers and their
respective clients break out into separate rooms and the mediator meets with one side first and then the other
side, conveying proposals until the case either settles or it is determined that the case will not settle.
Richard can listen to the mediator's introductory remarks and he can participate in the discussion in "our
room" during the shuttle diplomacy of the mediator, as well as any discussions I have with you and Valeria
during the mediation. Ordinarily non-lawyers do not otherwise participate, for example, if there are direct
discussions among counsel.
Vincent J. Pisegna
Krokidas & Bluestein LLP
600 Atlantic Avenue
EFTA01013671
mailto:
www.kb-law.comchttp://www.kb-law.comi>
From: Noam Chomsky < mailto:
Sent: Saturday, October 27 2018 4:39 PM
To: Vincent Pisegna
Cc: Valeria Chomsk
Subject: Mediation
I assume that if I grant Richard Kahn power of attorney, he can represent me during the mediation, probably
on the phone. Is that correct.
Noam
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