EFTA00724604.pdf

Susman godfrey a registered limited liability partnership 5TH FLOOR 654 MADISON AVENUE NEW YORK, NEW YORK 10065-8404 www.susmangodhey.com Suite moo Suite moo Suite 950 Suite ;Soo 1000 Louisiana Street got Main Street sgen Avenue of the Stars sins Third Avenue Houston, Texas 77002.5096 Dallas, Tend 75102-375 Los Angeles, California goo67.6oag Seattle, Washington 98101.300o Stephen D. Susman Direct Dial Fax (713) 654-667o Direct D E-Mail December 29, 2009 Jack Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Re: Jeffrey Epstein Dear Jack: We represent Mr. Epstein's Virgin Islands corporation, Financial Trust Company, Inc., in a case which is now at the discovery stage. One opposing party in this case has already served an extensive discovery request, which requires Mr. Epstein, in a short period of time, to review considerable documents from the corporation's files in the Virgin Islands in order to assemble potentially responsive documents for our review. We expect to receive similar discovery requests from the other opposing party in this case. In order to properly respond to these discovery requests, it will be necessary for Mr. Epstein to meet with and give guidance to certain of the corporation's Virgin Islands employees to assist in assembling the necessary documents, and, in order to do so, it would not be practical transport to Florida the corporation's files and employees, which are located in the Virgin Islands. In light of the relatively short period for the corporation's required response, we would like to have Mr. Epstein begin this work shortly after the beginning of the new year. As a result, I would request that you provide me with a period of at least two days in the first full week in January, 2010, when Mr. Epstein can travel to the Virgin Islands to meet with the corporation's Virgin Island's employees, review the corporation's files and begin to assemble the appropriate documents for my review and possible production in this case. EFTA00724604 December 29, 2009 Page 2 Thank you. Sincerely, Stephen D. Susman EFTA00724605