U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 Nest Palm Beach, FL 33401 (561) 8204711 August 31, 2007 DELIVERY BY FACSIMILE Ms. In care of Bruce Lyons, Esq. Re: Grand Jury Investigation—Confidential Dear Ms. • This letter is an invitation for you to testify before a federal Grand Jury, and is supplied in order to provide helpful background information about the Grand Jury. The Grand Jury consists of from sixteen to twenty-three persons from the Southern District of Florida. It is their responsibility to inquire into federal crimes which may have been committed in this District. As a Grand Jury witness you will be asked to testify and answer questions under oath, and to produce records and documents. Only the members of the Grand Jury, attorneys for the United States and a stenographer are permitted in the Grand Jury room while you testify. The U.S. Department of Justice encourages prosecutors to notify an individual in appropriate cases that he or she is a target of a grand jury investigation. Accordingly, you are hereby notified that you are a target of a federal grand jury investigation in the Southern District of Florida concerning suspected violations of federal law, including but not limited to, possible violations of Title 18, United States Code, Sections 2, 371, 1512, 1591, 1952, 1956, 1960, 2421, 2422, and 2423. You are advised that the destruction or alteration of any document required to be produced before the grand jury constitutes serious violation of federal law, including but not limited to Obstruction of Justice. A "tar et" is a person as to whom the prosecutors or the Grand Jury have substantial Ms. August 31, 2007 Page 2 evidence linking him or her to the commission of a crime and who, in the judgment of the prosecutors, is a putative defendant. This letter constitutes an invitation to you to testify on your own behalf before the grand jury about matters under investigation. Of course, you are not required to appear before the grand jury. The decision whether to do so is a voluntary matter which is entirely up to you. The grand jury, if in fact it learns of this opportunity afforded to you, will be instructed not to draw any adverse inference from your failure to appear should you decide not to accept this invitation. You must further understand that should you decide to testify, your testimony could be used against you if any criminal charges should be filed against you. Should you decide to appear before the grand jury, you will have the same rights and obligations as any non-immunized grand jury witness. Specifically, You may refuse to answer any question if a truthful answer to the question would tend to incriminate you. You have the right to stop answering questions at any time. EFTA00189875 Anything you say may be used against you at the grand jury or in a subsequent legal proceeding. The grand jury will permit you a reasonable opportunity to step outside the grand jury room to consult with your attorney, if you so desire, at any point during the testimony you give. Please be further advised that the giving of false testimony before the grand jury will subject you to a prosecution for perjury in addition to the violations set forth above. As a target of a grand jury investigation who has been asked to appear before the grand jury, you may wish to retain the services of an attorney. If you cannot afford the services of independent counsel, the Court may be able to appoint counsel to represent you. If you would like the United States to ask the Court to appoint an attorney to represent you, please contact the undersigned at 561 209-1047. The United States is investigating other individuals, and you may be interested in cooperating with the United States against those other targets. If you hire an attorney, or if the Court appoints one to represent you, that counsel can contact me to discuss that possibili Ms. August 31, 2007 Page 3 Please advise me whether you wish to testify before the grand jury by close of business Wednesday, September 12, 2007. If I do not receive notification from you or your counsel by this date, I will assume that you do not wish to testify before the grand jury. Sincerely, UNITED STATES ATTORNEY By: Ms. July 20, 2007 Page 3 bee: EFTA00189876