EFTA00880893.pdf

From: Jeffrey Epstein <jeevacation@grnail.com> To: Martin Weinberg Subject: Re: ATTORNEY-CLIENT PRIVILEGE Date: Mon, 15 Jun 2009 15:10:34 +0000 ok for me would you send me the numbers for the two of you On Mon, Jun 15, 2009 at 11:07 AM, Martin Weinberg > wrote: I would add two other points to Alan's analysis which I agree fully with: I) If you file a Decl Judg and lose any significant portion on the merits you will provide a roadmap to every plaintiff - and the remaining complainants in Bob J bullpen - about how to waive every other claim but 2255 and sue you from a position of great strength - clarity may not be in your interest civilly 2) You have options - the option to seek a partial stay when an issue that implicates the NPA would require a defensive response from you that you reasonably fear would trigger an erroneous construction of NPA from USAO (the unit of liability issue in terms of waiver is one) or to ask the court to rule on that specific issue not as a plaintiff seeking broad declaratory judgment jurisdiction but as a civil defendant attempting to litigate a specific focused right that results from an action of the plaintiff Like Alan, we need to know from Bob C and the civil team what are the risks of such a defensive position where you let the plaintiffs create the issues- ALAN AND I CAN DO CIF CALL WITH YOU AT 11:15 IF YOU ARE AVAILABLE Martin G. Weinberg, Esq. 20 Park Plaza, Suite 1000 116 cell This Electronic Message contains information from the Law Office of Martin G. Weinberg, M., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. EFTA00880893