EFTA00598044.pdf

JUL-27-2011 15:01 From: 5618021787 To:16173389538 Page:2/3 U.S. Department of Justice United States Attorney Southern District ofFlorida SODS Australian Ave. Ste 400 West Palm Beach. FL 33401 (561)820-8711 Facsimile: (561)8204777 July 27, 2011 PELIVERY BY FACSIMILE Martin G. Weinberg, Esq. 20 Park Plaza, Suite 1000 Boston, MA 02116 Re: Jeffrey Epstein Dear Mr. Weinberg: objections that 2011. In order to review and address the Thank you for your letter of July 22, District Attorney lette r, the Offi ce defe rred making its planned disclosure to the you raised in that Yor k of the Non -Pro secu tion Agreement ("Agreement") and the list of of the County of New nt. Nonetheless, after vict ims that was prov ided to Mr. Epstein pursuant to the Agreeme ned identified s, the Office still intends to proceed with the plan revi ew of you r obje ction completing a full disclosures. r to a only to provide Mr. Epstein with notice prio The Agreement requires the Office est of the Agre eme nt "(i) f the Unit ed States receives a Freedom of Information Act requ disclosure in any nt does not require Mr. Epstein's concurrence or any compulsory process"; the Agreeme not make losu re. Con trary to you r sugg estio n, the Agreement (including paragraph 13) also does disc emplates that On the contrary, the Agreement expressly cont the Agreement itself "confidential." lates , contrary to e, and the Agreement further contemp disclosures of the Agreement may be mad to sugg estio n, that such disc losu res of the Agreement may be made other than in response your k, as a local the District Attorney of the County ofNew Yor "compulsory process." Here, moreover, ested legitimate request for disclosure of the requ law enforcement agency, has provided a rly the n the confidentiality of the information, particula information, as well as a promise to maintai names of the minor victims. Criminal Procedure 6(e) also does not impact the Your objection pursuant to Federal Rule of grand jury material, and, thus, disclosure of that list planned disclosures. The victim list itself is not violate Rule 6(e). to the District Attorney's Office will not citation to Rule 6(e) and to If you wish to supply any additional authority (other than Office cannot disclose the Agreement and paragraph 13 of the Agreement) for your claims that the EFTA00598044 —was 44itu. rrom: 56180217)37 To:16173399538 Paee:3.3 ESQ. MARTIN WEINBRO, Jay 27,2011 PAGE 2 OF 2 to consider un ty of Ne w Yo rk, we would be willing to vic tim lis t to the District Attorney of the Co ide d tha t an y su ch authorities are furnished the sure, pr ov sly-planned those authoriti fore making any disclo ise , se ein g no obstacle to the previou rw t July 29, 2011. Ot he tion Agreement and the lis us before 5:004.1. on be disclosing copies ofboth theNon-Prosecu ty ot'New disclosures, the Office will M r. Ep ste in to th e Di st rict Attorney of the Coun was provided to of identified kigims that 29, 201i York at 5:00M. on July Sincerely, Wifredo A, Ferrer United States Attorney_ By. A. arie Vt lafafta rney Assistant United States Atto ern Division cc: Karen Atkinson, Chief, North w York ra h L. M or se , As sis ta nt Di strict Attorney, County of Ne Debo Roy Black, Esq. EFTA00598045