EFTA00216072Set 9
2008-11-205p2,209w
they for the purpose of obtaining
professional employment.
Ms. Ferguson next referred to Rule 4-4.2, "Communication with Person Represented by
Counsel." As explained above, with two exceptions, letters ... victim who, unbeknownst to me, had retained Mt Mermelstein's firm. Rule 4-4.2(a) only
prohibits communication with "a person the lawyer knows to be represented by another lawyer ... hired Mr. Mermelstein's firm, and,
therefore, there was no violation of Rule 4-4.2. This communication and the communication
described above (where another victim specifically advised the FBI case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00216072.pdf
EFTA00220833Set 9
2008-11-286p3,226w
prospective clients, nor were they for the purpose of obtaining
professional employment.
Rule 4-4.2
Ms. Ferguson next referred to Rule 4-4.2, "Communication with Person Represented by
Counsel ... victim who, unbeknownst to me, had retained Mr. Mermelstein's firm. Rule 4-4.2(a) only prohibits
communication with "a person the lawyer knows to be represented by another lawyer ... hired Mr. Mermelstein's firm, and, therefore, there was no
violation of Rule 4-4.2. This communication and the communication described above (where another
victim specifically advised the FBI case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00220833.pdf
EFTA00216141Set 9
2008-11-256p3,151w
prospective clients, nor were they for the purpose of obtaining
professional employment.
Rule 4-4.2
Ms. Ferguson next referred to Rule 4-4.2, "Communication with Person Represented by
Counsel ... victim who, unbeknownst to me, had retained Mr. Mermelstein's firm. Rule 4-4.2(a) only
prohibits communication with "a person the lawyer knows to be represented by another lawyer ... hired Mr. Mermelstein's firm, and,
therefore, there was no violation of Rule 4-4.2. This communication and the communication
described above (where another victim specifically advised the FBI case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00216141.pdf
EFTA00216228Set 9
2008-11-256p3,174w
prospective clients, nor were they for the purpose of obtaining
professional employment.
Rule 4-4.2
Ms. Ferguson next referred to Rule 4-4.2, "Communication with Person Represented by
Counsel ... victim who, unbeknownst to me, had retained Mr. Mermelstein's firm. Rule 4-4.2(a) only
prohibits communication with "a person the lawyer knows to be represented by another lawyer ... hired Mr. Mermelstein's firm, and,
therefore, there was no violation of Rule 4-4.2. This communication and the communication
described above (where another victim specifically advised the FBI case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00216228.pdf
EFTA00216178Set 9
2008-11-256p3,144w
prospective clients, nor were they for the purpose of obtaining
professional employment.
Rule 4-4.2
Ms. Ferguson next referred to Rule 4-4.2, "Communication with Person Represented by
Counsel ... victim who, unbeknownst to me, had retained Mr. Mermelstein's firm. Rule 4-4.2(a) only
prohibits communication with "a person the lawyer knows to be represented by another lawyer ... hired Mr. Mermelstein's firm, and,
therefore, there was no violation of Rule 4-4.2. This communication and the communication
described above (where another victim specifically advised the FBI case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00216178.pdf
EFTA00220844Set 9
2008-11-184p1,837w
they for the purpose of obtaining
professional employment.
Ms. Ferguson next referred to Rule 4-4.2 "Communication with Person Represented by
Counsel." As explained above, with one exception, letters ... victim who, unbeknownst to me, had retained Mr.
Mermelstein's firm. Rule 4-4.2(a) only prohibits communication with "a person the lawyer
knows to be represented by another lawyer ... victim
had hired Mr. Mermelstein's firm. In all of these instances, Rule 4-4.2 was not implicated.
There is a single instance where, as explained above, a victim specifically
https://www.justice.gov/epstein/files/DataSet%209/EFTA00220844.pdf
EFTA00216024Set 9
2008-11-185p1,831w
they for the purpose of obtaining professional employment.
Ms. Ferguson next referred to Rule 4-4.2 "Communication with Person
Represented by Counsel." As explained above, with one exception, letters ... victim who,
unbeknownst to me, had retained Mr. Mermelstein's firm. Rule 4-4.2(a) only prohibits
communication with "a person the lawyer knows to be represented by another lawyer ... victim had hired Mr. Mermelstein's firm. In all
of these instances, Rule 4-4.2 was not implicated.
There is a single instance where, as explained above, a victim specifically
https://www.justice.gov/epstein/files/DataSet%209/EFTA00216024.pdf
EFTA00220839Set 9
2008-11-185p1,859w
they for the purpose of obtaining professional employment.
Ms. Ferguson next referred to Rule 4-4.2 "Communication with Person
Represented by Counsel." As explained above, with one exception, letters ... victim who,
unbeknownst to me, had retained Mr. Mermelstein's firm. Rule 4-4.2(a) only prohibits
communication with "a person the lawyer knows to be represented by another lawyer ... victim had hired Mr. Mermelstein's firm. In all
of these instances, Rule 4-4.2 was not implicated.
There is a single instance where, as explained above, a victim specifically
https://www.justice.gov/epstein/files/DataSet%209/EFTA00220839.pdf
EFTA00208273Set 9
2008-09-184p1,800w
were they for the purpose of obtaining
professional employment.
next referred to Rule 4-4.2 "Communication with Person Represented by
Counsel." As explained above, with one exception, letters to victims ... victim who, unbeknownst to me, had retained Mr.
Mermelstein's firm. Rule 4-4.2(a) only prohibits communication with "a person the lawyer
knows to be represented by another lawyer ... victim
had hired Mr. Mermelstein's firm. In all of these instances, Rule 4-4.2 was not implicated.
There is a single instance where, as explained above, a victim specifically
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208273.pdf
EFTA00722801Set 9
2009-05-2235p5,059w
counsel then sent a letter on May 21, 2009 citing the
Comment to Rule 4-4.2 of the Rules of Professional Conduct that states that "(pJarties to a matter ... represent Mr. Epstein are well familiar with the Rules of
Professional Conduct, including Rule 4-4.2. At the same time, i am certain you are
equally familiar with that Rule
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722801.pdf