EFTA Document EFTA01480567

Confidential Due Diligence Report 6 Defense attorney Marc Shiner said defense attorneys sometimes put off overtly conducting discovery — deposing witnesses, requesting documents and the like -- because doing so creates more work for harried prosecutors who may become angry and not offer a plea deal. "Sometimes defense lawyers, knowing that, will try and do discovery without taking depositions," said Shiner, a former prosecutor for 13 years. Instead, they may conduct a below-the-radar probe such as having a private investigator check out leads, he said. Shiner and others say a plea deal for Epstein probably would result in pretrial intervention, in which a defendant may be ordered to undergo a psychological evaluation, counseling or other conditions in return for dropping the charge. Edmondson, spokesman for State Attorney Krischer, said there is no plea offer and no request for the prosecution to show its cards. "To my knowledge, it's never happened before on a filed case," he said. larty_keller£pbpost.com NOTES: Ran all editions. GRAPHIC: PHOTO (C) Jeffrey Epstein (mug) Money manager in New York has powerful allies. LOAD-DATE: March 14, 2007 Confidential - This report is not to be disseminated or photocopied to any third party without the express consent of Global Corporate Security. 2496207B.doc Confidential Treatment Requested by JPMorgan Chase CONFIDENTIAL JPM-SDNY-00002760 SDNY_GM_00271958 EFTA01480567