From: "Martin Weinberg" <

From: "Martin Weinberg" < To: "Martin Weinberg" <->, "Jeffrey Epstein" < Subject: Re: ATTORNEY-CLIENT PRIVILEGE Date: Sat, 20 Feb 2010 20:13:16 +0000 Bob can also inquire whether the "Rule 16" discovery has been received and if so whether it has been received subject to a protective order, formal or informal that can provide protection from civil subpoenas - ordinarily it is the Govt which seeks to protect its criminal discovery from disclosure to 3d parties - this, of course, may not be that case - Original Message From: Martin Weinberg To: Martin Weinberg • Jeffrey Epstein Sent: Saturday, February 20, 2010 3:04 PM Subject: Re: ATTORNEY-CLIENT PRIVILEGE Leave it up to Bob to determine whether Alfredo's attys are opposing compulsion motion - I will look into validity of grounds to intervene on Monday Original Message From: Martin Weinberg To: Jeffre E stein Cc: Sent: Saturday, February 20, 2010 3:01 PM Subject: ATTORNEY-CLIENT PRIVILEGE First thoughts - Alfredo testified in depositions - committed perjury by saying everything he had he gave to Recarey - has not gotten state (or federal) immunity for other crimes - he would therefore have rights to challenge the motion to compel Assuming he chose not to do that, the issue would be whether you could intervene arguing that according to Alfredo's own federal plea/statements/Govt compliant it is stolen property - check with Bob + we can research ability of plaintiff to seek to compel the thief to produce the stolen goods over the objection of its owner who, absent theft, would have 5th Am act of production privilege protection Original Message From: Jeffrey Epstein To: Martin Weinberg Sent: Saturday, February 20, 2010 2:52 PM as usual you raised a good point" how do we keep Alfredos tele book out of the hands of the plaintiffs attnys. marie wrote in the complaint that it was prepared by employees" The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein PROT0 Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to and destroy this communication and all copies thereof, including all attachments. PROT1