Text extracted via OCR from the original document. May contain errors from the scanning process.
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0.8/16/2097 17:05 FAX 5618021787
USAO WP8 FL
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave-, Suite 400
Wert Palm Beach, FL 33401
Facsimile:
August 16, 2007
n5, 4FACSINIILE
Gerald Lefcourt, Esq.
. Lefco
P.C.
Re:
Subpoena to Custodian of Records, NES, LLC
Dear Mr. Lefcourt:
I write in response to your letter of July 18, 2007 regarding the grand jury subpoena issued
to the Custodian ofRecords for NES, I Jr. I have attached an identical subpoena containing a return
date of September 11, 2007, and subpoenas for two NES employees, Eric Gany and Harry Beller.
If you will not be representing Messrs. Gany and Beller, please let me know.
First, as I mentioned in my earlier correspondence, a properly executed declaration from the
Custodian of Records is needed, and, if no documents responsive to a particular request exist, the
Custodian should certify that under penalty of perjury.
Second, you write that NES has no documents responsive to Requests 1 through 5. I know
that NES has several credit card accounts for the benefit of the persons who manage Mr. Epstein's
properties, including Janusz Banasiak and Alfredo Rodriguez. I also krtow that NES regularly
receives money from an account that is used to pay expenses at 358 El Grillo Way and also wires
money to that same account. Those wire transfers fall within the time period called for by the
subpoena and number in the hundreds of thousands of dollars. TINES does not maintain records of
its banking activities, then I would like to see a copy of its document retention policy, so I have
added that to the Attachment to the Subpoena.
Third, Mr. Menchel's comment to you about potential money laundering charges related only
to aresolution of the case. In other words, if the sex offense case is resolved, the Office would close
its investigation into other areas as well The matter has not bean, and it does not appear that it will
be, resolved so the money laundering investigation continues, and Request Number 6 will not be
withdrawn. The request is not overbroad and is stated with particularity, so please comply with the
request by the new deadline.
i'
EFTA00317423
08/16/2007 17:065AX 5618021787
MAO WPB FL
003
AUGUST 16, 2007
PAGE 2 OF 2
With respect to paragraph 7, the incarnation provided regarding the pilots came from the
corporate records of Hyperion and JEGE, Inc., not NES. However, I have provided a shorter list in
the new subpoena attachment
I also have enclosed another certification for the Custodian of Records' signature.
Thank you again for your assistance.
cc
cc:
By:
Sincerely,
R. Alexander Acosta
Assistant nited States Attorney
FBI (with enclosures)
EFTA00317424
0.8/16/2007 17:06 FAX 5618021787
U$A0 WPB FL
gins
TO:
Custodian of Records
NES, LLC
United States District Court
07-103(WPB)/No. GLY45/2
SUBPOENA FOR:
n
PERSON
DOCUMENTS OR OBJECT[S)
a
YOUARE HEREBY COMMANDED to appear andtestifybefore tbeGrandImy oftheUnitedStates District
Court at the place, date and time specified below.
Plata,
United States District Courthouse
701 Clematis Street
West Pahn Beath, Florida 33401
ROOM:.
Grand Jury Room
DATE AND TAE:
September 11, 2007
1:00 pm*
YOU ARE ALSO COMMANDED to bring with you the &lowing doctanent(s) or object(s):
*Pleat coordinate your corn fiance with this subpoena and confirm the date, time, and location
or
appearance with S/A
Federal Bureau of Investigation, Telephone:
This subpoena shall remain in effect until you are granted lean to depart by the court or by an officer acting
on behalf of the court.
- C1ERIC
This subpoena is issued upon application
it not applicable, cant lam'
DARE:
August 16, 2007
and Phone Number of Assistant U.S. Attorney
Assistant US. Attorney
500 So. Australian Avenue, Spite 400
33401-6235
Trt
Fax:
to lc wait
a(A0110
FORM ORD-227
.IAN86
EFTA00317425
08/16/2007 17:08 FAX 5618021787
USAO 16PB FL
005
ATTACHMENT TO SUBPOENA OLY-65/2
NES, LLC
For the period of January 1, 2003 to the present, all calendars, agendas, daily
diaries, or other records of a
*
s and the lilm, kept by or
on b
e ey Epstein,
, Lesley Groff, and/or
. This request includes information that is kept in physical
"hard copy" and/or electronic form, whether stored on a personal computer,
database server, cellular telephone, "Blackberry" unit, personal digital assistant
("PDA") or other handheld electronic device, or in any other electronic form, and
all metadata included within the electronic/physical files.
2.
For the period of January 1, 2003 to the present, all address books, contact lists, or
other records of names, telephone nun
•
-
it addresses
kept b or o
a
effrey Epstein,
, Lesley Groff
ancVo
This request includes information that is kept in
physical "hard copy" and/or electronic form, whether stored on a personal
computer, database server, cellular telephone, "Blackberry" unit, personal digital
assistant ("PDA") or other handheld electronic device, or in any other electronic
form, and all metadata included within the electronic/physical files.
3.
For the period of January 1, 2003 to the present, all c-mails, instant messages, text
messages, mee •
E tein,
r electronic commrmi
ent by
JefEre
to Jeffrey Epstein,
, Lesley Groff, and/or
This request includes information that is kept in physical
"hard copy" and/or electronic form, whether stored on a personal computer,
database server, cellular telephone, "Blackberry" unit, personal digital assistant
("PDA") or other handheld electronic device, or in any other electronic form, and
all metadata included within the electronic/physical files.
4.
For the period of January 1, 2003 to the present, all documents and information
referring or relating to the transfer of funds to or from any account owned by NES,
LLC to or from any bank account used for the maintenance of the property located
at 358 El Brillo Way, Palm Beach, Florida, or for the payment of any person
working at 358 El Brillo Way, Palm Beach, Florida.
Page 1 of 2
EFTA00317426
68/16/2007 17: 07 FAX 5618021787
USA° WFB FL
'Boos
CC
5.
For the period of January 1, 2003 to the present, all documents and information
referring or relating to the transfer of funds to or from any account owned by NES,
LLC to or from any bank account on which Janusz Banasiak and/or Alfredo
Rodriguez had or has check-writing authority and/or access to via debit/ATM card.
'
6.
For the period of January 1, 2003 to the present, all documents and information
•
referring or relating to the transfer of fund to or from any account owned by NES,
.
LLC to or from any account owned by JEGE, Inc., Jeffrey E. Epstein, Hyperion
Air, Inc., Financial Trust Co., New York Strategy Group, Inc., J. Epstein Virgin
Islands Foundations, Inc., and/or Epstein Interests.
7.
For the period of January 1, 2003 to the present, the names of all employees and all
corporate directors, board members, and shareholders.
8.
For the period of January 1, 2003 to the
sen co ies of all W-2s and/or 1099s
for the folio ine persons: ?effrev
ein,
Lesley GrofL
, Janusz Banasiak, Alfredo Rodriguez, Harry
, and Eric T. Gany.
9.
Any and all document retention and/or destruction policies.
Page 2 of 2
L
EFTA00317427
08/1_6//007 17:07 FAX 5618021787
USAO WPB FL
fM007
OLY-65/2
ADDRESSED TO NES, LJc
Cc
°MGM,
L'I
A
/Sc3NKU_CTED ACTIVITY
I, the undersigned,
, declare that I am emp loyed by
NES, LLC in the position of
and, by reason of myposition,
am authorized and qualified to make this declaration.
1.
In my employment with NES, LLC, I am familiar with the business records it
maintains.
2.
I certify that the records attached to this certification:
(a)
(b)
(c)
were made at or near the time of the occurrence of the matters set forth
therein, by or from information transmitted by, a person with knowledge of
those matters;
were kept in the course of regularly conducted business activity, and
were made by the regularly conducted activity as a regular practice.
2.
Among the records so maintained arc the attached records itemized in Appendix A
(Document Inventory).
3.
I further certify that the documents attached hereto arc responsive to Grand Surf
Subpoena 65/2 served upon NES, LLC.
Page 1 of 2
EFTA00317428
08/16/2007 17:07 FAX 5618021787
USAO RFD FL
Ooos
4.
I furthercertifythatNES, LLC has no documents responsive to requestnumber(s)
intimadJurySubpoemanutuber6512.[Fillinorstikeoutasap*opniatej
Pursuant to 28
§ 1746, I declare under penalty of perjury that the foregoing
informaahonis true and correct
Executed this
day of
2001.
Place ofteetelletoW
Signature
Par 2-of -2
EFTA00317429
(C74
08/ 16/2007 17:07 FAX 6618021787.
USA() WPB FL
009
TO:
BARRY BELLER
NES, LLC
United States District Court
FGT 07-103(WPB)/No. OLY-75
SUBPOENA FOR:
Fic PERSON
DOCUMENTS OR OBJECT[S]
YOU ARE HEREBY COMMANDED to appearandtestifybefore the Grand Juryof the United States District • •
Court at the place, date and time specified below.
•
PLACE:
United States District Courthouse
701 Clematis Street
West Palm Beach, Florida 33401
ROOM
Grand Jury Room
DATE AND TIME:
September 11, 2007
1:00 pm`
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
*Please coordinate your cow fiance with this subpoena and confirm the date, time, and location of our
appall-acme with SIA
Federal Bureau of Investigation, Telephone;
This subpoena shall 'main in effect unni you am granted leave to depart by the court or by an officer acting
on behalf of the court.
This subpoena is issued upon application
of the United States of Amaica
DATE:
August 16, 2007-
N
Address and Phone Number of AssistantUS. Attorney
Assistant US. Attorney
venue, Suite 400
Wen Path
FL 33401-6235
Tel:
Fsx;
if co( applicable, enter Thom'
tamt.41•GastA01)0
FORM Olt0427
JANI6
EFTA00317430
08/10/2007 17:07 'Fa 5618021787
USA° KPH FL
(Bolo
United States District Court
TO:
ERIC OANY
NES, LLC
F61 07-103(WPB)/No. OLY-76
SUBPOENA FOR:
PERSON
K
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
Court at the place, date and time specified below.
PLACE:
United States District Courthouse
701 Clematis Street
West Palm 'Scab, Florida 33401
sltoeSit
grad Jury Room .
DATE AND
September 11, 2007
1:00 pm*
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
*Please coordinate
"
subpoena and confirm the date, time, and
appearance with S/A
Federal Bureau of Investigation, Telephone:
This subpoena shall remain in effect tmtil you are granted leave to depart by the court or by m officer acting
on behalf of the court
Iliks ~is
issued upon application
groat groplieobto.ancegtate.•
to Number of Assistant U.S. Attorney
Amirtmt U.S. Attorney
500 So. Australia Avenue, Suitt 400
1-1D35
Tek
Fax:
feksilkkadMilft
FORM ORD-227
JAN.46
EFTA00317431
0$/16/2007 17:0S FAX 1618021787
USAO WPB FL
U.S. Department of Justice
United States Attorney
Southern District of Florida
300 S Australian Ave, 41h Floor
..F7orlda 33401
iacsunA
TO:
Gerald Le:court, Esq.
DATE:
Annul 15 2007
FAX NO.
# OF PAGES:
/ 0
PHONE NO.
RE:
NESALC
FROM:
Assistant U.S. Attorney
PHONE NO.
COMMENTS:
I
EFTA00317432