EFTA02729618

PodhurstOrseck TRIAL & APPELLATE LAWYERS Aaron S. Podhurst Robert C. Josefsberg Joel D. Eaton Steven C. Marks Victor M. Diaz. Jr. Katherine W. Ezell Stephen F. Rosenthal Ricardo M. Martinez-Cid Ramon A. Rasco Alexander T. Rundlet John Gravante, III June 2, 2009 Barbara Burns Assistant State Attorney The State Attorney's Office Fifteenth Judicial Circuit of Florida 401 North Dixie Highway West Palm Beach, FL 33401 Re: Jeffrey E. Epstein HIV test results Dear Ms. Burns: Robert Orseck (1934-1978) Walter H. Beckham, Jr. Karen Podhurst Dem Of Counsel During a recent meeting with you, undersigned counsel was informed that your office is in possession of the HIV test results of Defendant Jeffrey E. Epstein. You suggested that we contact the Health Department to obtain those results; however, it has come to our attention that this would require that we name our client who wishes to remain anonymous. Pursuant to Fla. Sta. Ann. § 796.08(3) (2008), the results of an HIV test of a person convicted of prostitution under section 796.07 "shall be made available by the Department of Health to the offender, medical personnel, appropriate state agencies, state attorneys, and courts of appropriate jurisdiction...." The statute does not make these tests results available directly from the Department of Health to the victims of sexual exploitation of Defendant Epstein. In addition, subsection (m) of Defendant Epstein's plea agreement in the Circuit Court of the Fifteenth Judicial Circuit of Florida states that HIV test results shall be released to the victims. We left an authorization by our client, A. H., D.O.B. 12/30/86, for release of records, information, and data to undersigned counsel, with you when we visited your office. Defendant Epstein agreed to this and was notified by the court during his sentencing that he would "submit to...an HIV test, the result of which is to be released to the victims or victim's parent or guardian...within 48 hours." 09/12/2019 Page 3885 Agency to Agency Requet 19-411 Podhurst 0rseck. A. 25 West F1agler Street Q1 0.114,4 ENTIAL Miami 305358.2800 Fax 30535/L2382 • Fort Lau a . EA SDNY_GM_00331907 EFTA_00204633 EFTA02729618 I Barbara Burns Assistant State Attorney June 2, 2009 Page 2 If you could kindly provide us with a copy of these test results by fax or US mail (listed below), it would be greatly appreciated. Thank you for your cooperation in this matter. Very truly yours, 471rt v's tj % RA Katherine W. Ezell KWFJmce 09/1212019 Page 3886 CONFIDENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331908 EFTA_00204634 EFTA02729619 O 6061£C00—rde—ANOS PodhurstOrseck TRIAL & APPELLATE LAWYERS City National Bank Building 25 West Nagler Street. Suite 800 Miami, Saida 33130 ZW:1031.442."6 csasmet,... ass •••••• .1=••••••• *OW V %OWLS 02 1M $ 00.44° 0004273379 MAILED FROM ZIP CODE 33130 Barbara Burns Assistant State Attorney The State Attorney's Office Fifteenth Judicial Circuit of Florida 401 North Dixie Highway West Palm Beach, FL 33401 I It ii t III 111 1 1Ill li JI 11 f1 I IJ EFTA02729620