gov.uscourts.nysd.447706.223.2.pdf

Case 1:15-cv-07433-RWS Document 223-2 Filed 06/16/16 Page 1 of 7 EXHIBIT 2 Case 1:15-cv-07433-RWS Document 223-2 Filed 06/16/16 Page 2 of 7 From: Sigrid McCawley Sent: Thursday, April 07, 2016 12:01 PM To: Martin Weinberg Subject: RE: Giuffre v. Maxwell No -I can wait until tomorrow. Thank you for following up. Sigrid Sigrid S. McCawley· Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phone: 954-356-0011 ext. 4223 Fax: 954-356-0022 http://www.bsfllp.com From: Martin Weinberg [mailto:[email protected] Sent: Thursday, April 07, 2016 11:42 AM To: Sigrid McCawley Cc: Martin Weinberg Subject: Re: Giuffre v. Maxwell Sigrid Do you need an answer today? I have several time sensitive conflicts and then afternoon court commitments Sent from my iPhone 1 Case 1:15-cv-07433-RWS Document 223-2 Filed 06/16/16 Page 3 of 7 On Apr 6, 2016, at 11:46 AM, Sigrid McCawley <[email protected]> wrote: That works fine - thank you. Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phone: 954-356-0011 ext. 4223 Fax: 954-356-0022 http://www.bsfllp.com From: MartinWeinberg [mailto:[email protected]] Sent: Wednesday, April 06, 2016 11:46 AM To: Sigrid McCawley; Martin Weinberg Subject: Re: Giuffrev. 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 (617) 227-3700 - Office (617) 901-3472 - 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 ofthe 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. 2 Case 1:15-cv-07433-RWS Document 223-2 Filed 06/16/16 Page 4 of 7 On Wednesday, April 6, 2016 11 :39 AM, Sigrid McCawley <[email protected]> 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: 954-356-0011 ext. 4223 Fax: 954-356-0022 http://www.bsfllp.com/ From: Sigrid McCawley Sent: Tuesday, March 08, 2016 1:13 PM To: 'Martin Weinberg' Subject: RE: Giuffre v. Maxwell Hello Marty - thank you for your call back this afternoon. 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. 3 Case 1:15-cv-07433-RWS Document 223-2 Filed 06/16/16 Page 5 of 7 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: 954-356-0011 ext. 4223 Fax: 954-356-0022 http://www.bsfllp.com/ From: Sigrid McCawley Sent: Monday, March 07, 2016 3:21 PM To: 'Martin Weinberg' Subject: RE: Giuffre 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: 954-356-0011 ext. 4223 Fax: 954-356-0022 http://www.bsfllp.com/ From: Martin Weillberg [maillo:[email protected] Sent: Monday, March 07, 20162:59 PM To: Sigrid McCawley Cc: Martin Weinberg Subject: Re: Giuffre 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 4 Case 1:15-cv-07433-RWS Document 223-2 Filed 06/16/16 Page 6 of 7 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 <[email protected]> wrote: Hello Marty, I understand that you are one of the lawyer who represent Jeffrey Epstein. My firm is representing Virginia Giuffre 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: 954-356-0011 ext. 4223 5 Case 1:15-cv-07433-RWS Document 223-2 Filed 06/16/16 Page 7 of 7 Fax: 954-356-0022 http://www.bsfllp.com/ The information contained in this electronic message is confidential information Intended only for the :Jse 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 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 J <2015-09-21 [DE 1] Complaint.pdf> The infonnation 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 attomey~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. Ifyau 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.1J The information contained in this electronic message is confidential information intended only for the use of the named reclpient(s) and may contain information that. among other protections, is the subject of attorney-client privilege, attomey work product or exempt from disclosure under appli('..able law. If the reader of this e19ctronic message Is not the named recipient or the employee or agent responsible to deliver it to the named reclpient, 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 Immediahi!ly notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1) The information contained in this electronic message IS confidential inf-orrnation intended only for the use of the named re(".ipient(s} and may contain infonnation that. among other protections. is the subject of attomey-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] 6