EFTA01080461.pdf

Case 1:15-cv-07403-RWS Document 161-3 Filed 05/25/16 Page 1 of 17 COMPOSITE EXHIBIT 3 EFTA01080461  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 2 of 17 Sigrid McCawley From: Sigrid McCawley Sent: Monday, March 07, 2016 2:22 PM To: mart Subject: v. Maxwell Attachments: 2015-09-21 [DE 1] Complaint.pdf Hello Marty, I understand that you are one of the lawyer who represent Jeffrey Epstein. My firm is representinnin her defamation action against Ghislaine Maxwell pending in federal court in New York —case number 15-cv-07433-RWS. ( If I am incorrect in my understanding that you represent Jeffrey Epstein kindly let me know.) We would like to take the deposition of Jeffrey Epstein and want to confirm whether you will be willing to accept service of a subpoena on his behalf. Kindly let me know and we can discuss a date for the deposition. If you have any questions, I can be reached a I have included a copy of the complaint for your review. Thank you, Sigrid Sigrid S. McCawley Partner ROTES, SCHILLER & FLEXNER LI,P 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, Fl. 33301 Phone: Fax: Mtp://www.bstilp.com EFTA01080462  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 3 of 17 Sigrid McCawley From: Martin Weinberg Sent: Wednesday, April 06, 2016 11:46 AM To: Sigrid McCawley; Martin Weinberg Subject Re:Mt Maxwell Sigrid, understood. Subject to reserving my rights to make any, all objections, 1 will let you know on facilitating service and discussing time and place no later than midday tomorrow (in court most of today). Let me know if that works. Marty Martin G. Weinberg, Esq. 20 Park Plaza Suite 1000 This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. On Wednesday, April 6, 2016 11:39 AM, Sigrid McCawley Hello Marty — Per your inquiry below - we arc going to need to take a videotaped deposition of Epstein for use at trial. Kindly let me know if you are authorized to accept service on his behalf. We will be glad to coordinate a location and reasonable date that works for you and your client. Thank you, Sigrid Sigrid S. McCawley Partner BOLES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale. FL 33301 Phon Fax httn://www.bsffip.com/ From: Sigrid McCawley Sent: Tuesday, March 08, 2016 1:13 PM To: 'Martin a Subject: RE. v. Maxwell Hello Marty - thank you for your call back this afternoon. I understand from our conversation that you have a "preliminary question" before you can answer whether or not you are authorized to accept service of a subpoena for Jeffrey Epstein's testimony in the Maxwell action. EFTA01080463  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 4 of 17 You explained that it would be Epstein's position that he would be invoking his Fifth Amendment privilege as to all questions relating to the Maxwell action so your "preliminary question" as I understand it, is whether the plaintiff would be willing to accept a form of sworn statement in response to questions whereby Epstein invokes his Fifth Amendment privilege in lieu of Epstein having to sit for a formal in-person deposition. I will endeavor to get you a response shortly. Thank you for your call. Sigrid Sigrid S. McCawley Partner BOLES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phone: Fax: http://www.bsflIp.com/ From: Sigrid McCawley Sent: Monday, March 07, 2016 3:21 PM To: 'Martin Vag; Subject: RE:a Maxwell That would be fine. Thank you. Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort L Pho Fax: http://www.bstlIp.com/ From: Martin Weinberg Sent: Monday, March 07, 2016 2:59 PM To: Sigrid McCawley Cc: Martin It Subject: Re: v. Maxwell Hi Sigrid Give me a few days to check. I represent him on certain matters, not others but will get back to you no later than thursday on the service issue. Let me know if that works for you That Marty Sent from my iPhone On Mar 7, 2016, at 2:22 PM, Sigrid McCawley wrote: Hello Marty, 2 EFTA01080464  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 5 of 17 I understand that you are one of the lawyer who represent Jeffrey Epstein. My firm is representing in her defamation action against Ghislaine Maxwell pending in federal court in New York — case number 15-cv-07433-RWS. ( If I am incorrect in my understanding that you represent Jeffrey Epstein kindly let me know.) We would like to take the deposition of Jeffrey Epstein and want to confirm whether you will be willing to accept service of a subpoena on his behalf. Kindly let me know and we can discuss a date for the deposition. If you have any questions, I can be reached at (954) 356-0011. I have included a copy of the complaint for your review. Thank you, Sigrid Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale FL 33301 Phone: Fax httn://www.bsfilp.com/ The information contained in this electronic message is confidential information intended only teethe use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under apphcabk law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distiibution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer (v.] ) <2015-09-21 [DE I] Complaint.pdf, Tum :cirvoion continol in this oiontronin fultSSagO is confkienhtl infornithon intirolori only tor I:4 uSiF of to Nine i FOC:peard(C,) ,,irit may contain intorrnetan 'itat •,r •-••Ilef plorenkorts, is the n( sttorney-alk.nt p.Mvsga, atICIMOY ..u3(v Pit4t1C1 crompl inter cPsdr,Ro carder appCczbit IM. If ttA: render of this notthe (ozip,ent. Gr Use 1:fripiOyfe Uagentresponsible to c to Uri:rtro.eil fed/Au*. you we fueby nGsti,2,1mg any na!wri de.tributiml. copyirql or otroi use of rids continue:ninon c madly prolitiltod and no pnv;tor,e, in valved. If yea hove: rcizivnd this. contrtmonahflorint error ilorINt cnirmdiandy notify Itic sunder by ioplyIng to INS doe TOM; Inc scage Merl nelttOg this eieCtr011'f: altSfdx1m. ft an ymir coir.ri42. (v.11 3 EFTA01080465  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 6 of 17 Sigrid McCawley From: Martin Weinberg Sent: Thursday, April 07, 2016 11:42 AM To: Sigrid McCawley Cc: Martin Weinberg Subject: Maxwell Sigrid Do you need an answer today? I have several time sensitive conflicts and then afternoon court commitments Sent from my iPhone On Apr 6, 2016, at 11:46 AM, Sigrid McCawley wrote: That works fine - thank you. Sigrid S. McCawley Partner BOLES, SCHILLER & FLEXNER LLP 401 East Las Ohs Blvd.. Suite 1200 Fort Lauderdale. FL 33301 Phonei Fax http://www.bsfllp.com From: Martin Weinberg' Sent: Wednesday, April 06, 2016 11:46 AM To: Sigrid Mccizigy4 • Martin Weinberg Subject: Re: . Maxwell Sigrid, understood. Subject to reserving my rights to make any, all objections, I will let you know on facilitating service and discussing time and place no later than midday tomorrow (in court most of today). Let me know if that works. Marty Martin G. Weinberg, Esq. 20 Park Plaza Suite 1000 16 Office Cell This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. On Wednesday, April 6, 2016 11:39 AM, Sigrid McCawle wrote: 1 EFTA01080466  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 7 of 17 Hello Marty — Per your inquiry below - we are going to need to take a videotaped deposition of Epstein for use at trial. Kindly let me know if you are authorized to accept service on his behalf. We will be glad to coordinate a location and reasonable date that works for you and your client. Thank you, Sigrid Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phon Fax: http://www.bsfIlp.com/ From: Sigrid McCawley Sent: Tuesday, March 08, 2016 1:13 PM To: 'Martin VW Subject: RE v. Maxwell Hello Marty — thank you for your call back this afternoon. I understand from our conversation that you have a "preliminary question" before you can answer whether or not you are authorized to accept service of a subpoena for Jeffrey Epstein's testimony in the Maxwell action. You explained that it would be Epstein's position that he would be invoking his Fifth Amendment privilege as to all questions relating to the Maxwell action so your "preliminary question" as I understand it, is whether the plaintiff would be willing to accept a form of sworn statement in response to questions whereby Epstein invokes his Fifth Amendment privilege in lieu of Epstein having to sit for a formal in-person deposition. I will endeavor to get you a response shortly. Thank you for your call. Sigrid Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort L Phon Fax: http://www.bsfIlp.com/ From: Sigrid McCawley Sent: Monday, March 07, 2016 3:21 PM To: 'Martin Weinberg' Subject: RE v. Maxwell 2 EFTA01080467  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 8 of 17 That would be fine. Thank you. Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phone Fax: http://www.bSflip.com/ From: Martin Weinberg' Sent: Monday, March 0/. 2016 2:b9 PM To: Sigrid McCawley Cc: Martin Weinberg Subject: Re: v. Maxwell Hi Sigrid Give me a few days to check. I represent him on certain matters, not others but will get back to you no later than thursday on the service issue. Let me know if that works for you Thanks Marty Sent from my iPhone On Mar 7, 2016, at 2:22 PM, Sigrid McCawley wrote: Hello Marty, I understand that you are one of the lawyer who represent Jeffrey Epstein. My firm is representing lin her defamation action against Ghislaine Maxwell pending in federal court in New York — case number 15-cv-07433-RWS. ( If I am incorrect in my understanding that you represent Jeffrey Epstein kindly let me know.) We would like to take the deposition of Jeffrey Epstein and want to confirm whether you will be willing to accept service of a subpoena on his behalf. Kindly let me know and we can discuss a date for the deposition. If you have any questions, I can be reached at I have included a copy of the complaint for your review. Thank you, Sigrid Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 3 EFTA01080468  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 9 of 17 Phone: Fax: http: www. s p.com/ The information contained in this electronic message is confidential information Intended only for the use of the named recipient(s) and may contain information that, among other protections, Is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error. please Immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1) <2015-09-21 [DE 1] Complaint.pdf> infer:ham,' contain:-din this iiiiienestit: message confident:el label:Mien into ler ;he t.' 'I, Aimed recipentis) bad may es nasal intermation alai. among (Mier protinliens. is tria tv.tisil of adona•y-ilium atirmei woti. pi chid or from Elk:Mk:SUM tlIttier am:Lc:able taw. If the recdie of !hi:. inattiortic mti sage is not the mimeo :a :piers. or the miSPloyee fficriOnfitgo to tioilifer ft ;II the flame.' resiptent. you are hereby notified tied any daStibIlla:On. OalributiTX1. copying (It tililef tne of Ills a:immunisation is strictly prohibited 'rut no privi i.)e voatirtl. if you have rarefied this aimmtriltstion in afTIDT, pkalt* .irealedIaldlY malt' the SWICIii. f by loPliiog to (tip electronic message and than ottiglan this Li:inhere° nieszage from yo(ir ad:peter. [v.1) The information contained at nth, .21f;drunicratiStiagri re C2nlikkalltIlinicernation intended only for the use Write named reciplent(s) end May cienfatig Woriutilion that. >mono new prcitections, Is the subject of atterney-sfient pinellega. altaraay WON eroded of exempt from disriosult Y'rd if lipppcdnia law. It Inc IT.ider of tifinglrecic roe isaija is net lfn, nnfireil recipient. or the nein:aye& cr :Naiad cosi:onstage to deliver it to ti e named rectprarg. yea imetied drat any d.sr..erninalien, copying m other use of fl Cranmenicatihri iP strictly C/4O1.94 dIV-I le vialvII€1_ If MaN rsco."& tits communicetion in !lief. pleat& IINTIV.:i2;aly nerdy the ,rimier by replylig to ..itiout,gc %owl or, keilird !No ek•r4ilk message horn yaw cren(;tatar. Iv.9) 4 EFTA01080469  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 10 of 17 Sigrid McCawley From: Martin G. Weinberg Sent: Thursday, April 07, 2016 5:14 PM To: Sigrid McCawley Subject: Rea. Maxwell Thanks From: Sigrid McCawley Sent: Thursday, April 07, 2016 12:01 PM To: natal. Subject: RE: v. Maxwell No - I can wait until tomorrow. Thank you for following up. Sigrid Sigrid S. McCawley Partner 3O11s. st1111,1,112 & FLIANER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phone Fax http://www.bsfllp.com From: Martin Weinberg Sent: Thursday, April 07, 2016 11:42 AM To: Sigrid McCawley Cc: Martin Wei Subject: Re: v. Maxwell Sigrid Do you need an answer today? I have several time sensitive conflicts and then afternoon court commitments Sent from my iPhone On Apr 6, 2016, at 11:46 AM, Sigrid McCawley • wrote: That works fine — thank you. Sigrid S. McCawley Partner [1 DIES, SCHILLER & FLEXISER LIP 401 East Las Olas Blvd.. Suite 1200 Fort Lauderdale, FL 33301 Phone 1 EFTA01080470  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 11 of 17 Fax: http://www.bstIlp.com From: Martin Weinberg Sent: Wednesday, April 06, 2016 11:46 AM To: Sigrid McCawley; Martin Weinberg Subject: Re: v. Maxwell Sigrid, understood. Subject to reserving my rights to make any, all objections, I will let you know on facilitating service and discussing time and place no later than midday tomorrow (in court most of today). Let me know if that works. Marty Martin G. Weinberg, Esq. 20 Park Plaza Suite 1000 Boston, MA 02116 - Office - Cell This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. On Wednesday, April 6, 2016 11:39 AM, Sigrid McCawley wrote: Hello Marty — Per your inquiry below - we are going to need to take a videotaped deposition of Epstein for use at trial. Kindly let me know if you are authorized to accept service on his behalf. We will be glad to coordinate a location and reasonable date that works for you and your client. Thank you, Sigrid Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale. FL 33301 Phone: Fax: http://www.bsflIp.com/ From: Sigrid McCawley Sent: Tuesday, March 08, 2016 1:13 PM To: 'Martin Wtjalagar Subject: RE: a. Maxwell Hello Marty — thank you for your call back this afternoon. I understand from our conversation that you have a "preliminary question" before you can answer whether or 2 EFTA01080471  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 12 of 17 not you are authorized to accept service of a subpoena for Jeffrey Epstein's testimony in the Maxwell action. You explained that it would be Epstein's position that he would be invoking his Fifth Amendment privilege as to all questions relating to the Maxwell action so your "preliminary question" as I understand it, is whether the plaintiff would be willing to accept a form of sworn statement in response to questions whereby Epstein invokes his Fifth Amendment privilege in lieu of Epstein having to sit for a formal in-person deposition. I will endeavor to get you a response shortly. Thank you for your call. Sigrid Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale FL 33301 Phone: Fax: http://www.bsfIlp.com/ From: Sigrid McCawley Sent: Monday, March 07, 2016 3:21 PM To: 'Martin Wilk Subject: RE: v. Maxwell That would be fine. Thank you. Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phone: Fax: http://www.bsfIlp.com/ From: Martin Weinber Sent: Monday, March 07, 2016 2:59 PM To: Sigrid McCawley Cc: Martin Weinberg Subject: Re: a. Maxwell Hi Sigrid Give me a few days to check. I represent him on certain matters, not others but will get back to you no later than thursday on the service issue. Let me know if that works for you Thanks Marty Sent from my iPhone 3 EFTA01080472  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 13 of 17 On Mar 7, 2016, at 2:22 PM, Sigrid McCawley wrote: Hello Marty, I understand that you are one of represent Jeffrey Epstein. My firm is representing in her defamation action against Ghislaine Maxwell pending in federal court in New York — case number 15-cv-07433-RWS. ( If I am incorrect in my understanding that you represent Jeffrey Epstein kindly let me know.) We would like to take the deposition of Jeffrey Epstein and want to confirm whether you will be willing to accept service of a subpoena on his behalf. Kindly let me know and we can discuss a date for the deposition. If you have any questions, I can be reached at I have included a copy of the complaint for your review. Thank you, Sigrid Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort L Pho Far http://www.bsfIlp.com/ The Information contained in this electronic message Is confidential information Intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege. attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distnbution, copying or other use of this communication is strictly prohibited and no priviege Is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. lv.11 <2015-09-21 [DE 1] Complaint.pdf> 1, 'airarnetion contained in Ma electronic message b conixt•: : • urreqrnaik,n fltencial me use cdtho mimed rocipiongs) and may kmirliatron umong miler promotions. b rho sat:jet; tt: atorney.cllinst privdoi.•. •i. I work product or romp front disdesuro alder :sapient:a lira. if the reader ot leis seciamnic message Is riot tile !rained faC:phir4. or : ployee Cr agent import:Wm to deliver it to itztatcHt incipient l'eltby Iltdattki Mai any ussemnation, dishrtiurron, copyinti ." use of gris communissegor is Wittily Jacobean and no privilege is waived. if you Isle mounted this counnuniaition in utter. ,,ver nately notdy me bonder by replying le e'er:1;06C message ;esi rhea ditiefing :net tilectmiti mess;tge Nan yet/ Comptilti . ti it it:, inearnation contained faltes electrunic message Is confidentialIntotmaiion 'laminae may tor ils» use of me named recipaull(s) and may contain 'Moorman Mid. among ogler rafttattr0115. Is six subject of intomey-tdient pilv2ege. attorney work product or exempt from disclosure under applIctible law. If the ractor of Itas race:male Ines-snide is not me named renpitve, or the emplosne a agent responsible to deliver it to the named ii.Xtpkell, you are hereby notified Mil any øissenfinelmn, distribution, copyinz.; or nicer use ot coluntunir,stion is strictly prohibited and no puvileryi Is waived. if ycu have lecehred this conenunisation In cam, please immediately notify the sender by repaying to eieritrerric message and tien deleting this electronic message from you, eompiiter iv.11 4 EFTA01080473  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 14 of 17 The timloinso in this t:lectrorm: c. COrrkr< vie] inionoistion Orys ;Of the use of tha :tamed triple:0(s) and nay contain information 4.:n it::113tho: prolaciiona, i rh, Uubk,d of attorney-ciont Icon sy e. Amfolly work tiic,idcA or exempt from distioix.74 tiader applTnt re. 13w. It the reader of el\ electronic rreessaosi is not the named ie.:tweet. or the empioyoe a apent resroirrible to diiirvor it to the n4mel reC.4):CrIt. you are :ietety nodfied that my dT;semiasticri, isseibution. copying cr other use of ;Ss coderun:cition r VA* prohibited and no prialeqe: is waned. 0 you have rec.,: iw.cl the osminuririatioit in ecter. steitse inarnediale:y notify die stork r hy replying totie &tiar: stesto :NI then delittino this eleerrni tic mess fig° from yOi:^ 1 zOntpule1. Iv.1] 5 EFTA01080474  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 15 of 17 Sigrid McCawley From: Martin G. Weinberg Sent: Friday, April 08, 2016 4:31 PM To: Si rid McCawley; [email protected] Subject: Maxwell Sigrid, Friday is winding down and due largely to my client's travel/business schedule I have not, today, received final authority to accept service or discuss related arrangements. I will have contact with him over the weekend and get you an answer Monday (or we can default to a no if for any reason I don't have an unconditional communication on the service issue by then) if that works. Marty Martin G Weinberg PC 20 Park Plaza Suite 1000 Boston. MA 02116 Tel Cel 1 EFTA01080475  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 16 of 17 Sigrid McCawley From: Sigrid McCawley Sent: Wednesday, May 25, 2016 10:30 AM To: Cc: Sigrid McCawley Meredith Schultz Subject: Subject: Re: Service on Jeffre E stein Attachments: Re xwell; Re: v. Maxwell; Re: a. Maxwell; Re v. Maxwell; v Mame Hello Marty, Thank you for the response. I went back through my e-mail communications and I didn't see anything about an agreement by you to accept service of Jeffrey Epstein's deposition for a deposition in the Virgin Islands near his residence. I have attached the e-mails that I have from you above. I do not have an "April 11th" e-mail as referenced below. That said, we can work to accommodate that location request for a deposition in the Virgin Islands. If Mr. Epstein can accommodate us on his island, assuming he can provide transportation as I understand it is remote, we would be willing to take the deposition at that location. Please confirm given the agreement on relocating the deposition to the Virgin Islands that you will agree to accept service of the subpoena for Jeffrey Epstein's deposition. Thank you, Sigrid Sigrid S. McCawley Partner 00IES, SCIIILLER & FLEXNER LLP 401 East Las Olas Blvd.. Suite 1200 Fort Phone: Fax http://www.bsfIlp.com From: Martin G. Weinber Sent: Wednesday, May 25, 2016 8:33 AM To: Sigrid McCawley, Subject: Re: Service on Jeffrey Epstein Sigrid, first to "correct the record" — I did not simply refuse to accept service in response to your April 6 email, instead, on April 11 I emailed you saying that if you agreed to the deposition being near Mr Epstein's Virgin Island residence, I could accept service subject to our agreeing on a date and my reserving legal objections to the deposition request. I received no answer to that email. As to Monday's email, I would first request that you inform me whether you are agreeable to a deposition in the Virgin Islands (the predicate for my April 11 email and Mr Epstein's sole residential and business venue as defined by Rule 45) in which case I will determine immediately whether I am still authorized to accept service (particularly given the new {to me) and expansive request for documents that like the anticipated testimony would be subject to a principled Fifth Amendment assertion). I remain of the view that Mr. Epstein (indisputably I would contend) has a Fifth Amendment right and intends to assert it in relation to any and all questions and document requests relevant to the subject matter of your case. Thanks. Marty EFTA01080476  Case 1:15-cv-07433-RWS Document 161-3 Filed 05/25/16 Page 17 of 17 From: Sigrid McCawlev Sent: Monday, May 23, 2016 9:30 AM To Cc: Meredith Schultz Subject: Service on Jeffrey Epstein Hello Marty, As you are aware we initially reached out to you back on March 7, 2016 to inquire as to whether you would accept service on your client, Jeffrey Epstein's behalf. You did not agree to accept service so we proceeded with numerous service attempts on Jeffrey Epstein. I am attaching above the latest subpoena that we have been attempting service of. Please confirm whether you will accept service of this subpoena on behalf of Jeffrey Epstein or whether we will be required to seek court intervention for alternative service. As I mentioned previously, if you accept service, we can work with you and your client on a the date and location of the deposition to make it convenient for the parties. Thank you, Sigrid Sigrid S. MeCawley Partner DIES, SC HILLER & FLEXNER LLI' 401 Fast Las Olas Blvd., Suite 1200 Fort Lauderdale FL 33301 Phone: Fax: lutp://www.bsflIp.com The .41!'enigtion con:oiratti in thio triegnorut MeStage. is csmersolitLI intonation In:elitiocl ofgy toe ate tesu et t • .. I ,attaais) and rogy contgoi triturtiostit Mot. .-::10,14 tither prOtatrots. k ttutt.:4 Oi 4aalltarthtna privilege. ottigney wogs product Wake:apt fryta •: • . tietilet apfZetabaf guts. If fibs pane( of mrs electronic inesssge "ri not the named recipient, or ttei uniptorst Cl wan! cespansThlo ID deliver it foe tiantia tett:p.m', yep an: kaaby maitiecl ttsst Any sitserburets copying or often use sr Ints communication is strictly protaletoJ end no (✓,vilege is waited. I! you Non reatived Innt crougur•!Cating fr ;Nose im mediately notify tin sender by rinlYnib llr,. niettlinic Ineisti4o and than deleting U s earaltflat message got your computer. (v.1) EFTA01080477