EFTA00014598.pdf
443 KB
Extraction Summary
4
People
3
Organizations
3
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Email chain / legal correspondence
File Size:
443 KB
Summary
This document is an email chain between defense attorney Michael Bachner and an Assistant United States Attorney (SDNY) regarding the Epstein investigation. The correspondence discusses scheduling a 'reverse proffer' meeting and addresses a Grand Jury subpoena for Bachner's female client. Bachner formally notifies the prosecution that his client intends to invoke her Fifth Amendment privilege against self-incrimination, while the prosecution pushes back against a 'blanket' invocation. The emails also reference the 2007 Epstein Non-Prosecution Agreement (NPA) being sent as an attachment.
People (4)
| Name | Role | Context |
|---|---|---|
| Michael Bachner | Attorney |
Defense counsel representing a client in the Epstein investigation; arranging meetings and asserting 5th Amendment pr...
|
| [Redacted] (AUSA) | Assistant United States Attorney |
Prosecutor for SDNY; scheduling meetings and challenging the scope of the client's 5th Amendment invocation.
|
| [Redacted] (Client) | Client / Witness |
Female client represented by Bachner; subject of a Grand Jury subpoena; invoking 5th Amendment privilege.
|
| [Redacted] (Associate/Colleague) | Unknown (likely legal team) |
Mentioned as someone who might attend the meeting with Bachner.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Bachner & Associates, PC |
Law firm representing the witness/client.
|
|
| Southern District of New York (SDNY) |
US Attorney's Office conducting the investigation.
|
|
| Queens County Court |
Mentioned regarding a different client's arraignment causing a scheduling conflict.
|
Timeline (2 events)
2019-07-16
Scheduled 'Reverse Proffer' meeting between Michael Bachner and SDNY prosecutors.
1 St. Andrew's Plaza, New York, NY
2019-07-16
Arraignment of a different Bachner client on state RICO charges (scheduling conflict).
Queens County
Locations (3)
| Location | Context |
|---|---|
|
Office of the US Attorney (SDNY).
|
|
|
Office of Bachner & Associates.
|
|
|
Location of a separate arraignment.
|
Relationships (2)
Bachner asserts privilege on her behalf and negotiates her appearance.
Exchange of emails regarding subpoenas and proffer sessions.
Key Quotes (4)
"we hereby notify you that if called as a witness [REDACTED] would invoke her Fifth Amendment privilege against compelled self-incrimination."Source
EFTA00014598.pdf
Quote #1
"we would expect to argue to the court do not implicate a fifth amendment privilege—i.e., that she couldn’t simply blanket invoke."Source
EFTA00014598.pdf
Quote #2
"attached are the non-prosecution agreement, previously publicly filed in civil proceedings in Florida, and a blank version of our standard proffer agreement"Source
EFTA00014598.pdf
Quote #3
"Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?"Source
EFTA00014598.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (13,062 characters)
From: Michael Bachner [REDACTED]
To: '[REDACTED]'
Cc: [REDACTED]
Subject: Re: Epstein investigation
Date: Wed, 17 Jul 2019 19:38:16 +0000
Inline-Images: ~WRD000.jpg
To: '[REDACTED]'
Cc: [REDACTED]
Subject: Re: Epstein investigation
Date: Wed, 17 Jul 2019 19:38:16 +0000
Inline-Images: ~WRD000.jpg
Thanks for the heads up
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 17, 2019, at 2:08 PM, [REDACTED] <[REDACTED]> wrote:
Michael,
Just in an abundance of caution, wanted to let you know that our conference in this case tomorrow was just moved from 9:30 a.m. to 11:30 a.m. We think that should still leave more than enough time to complete the hearing and be back for our 2:00 discussion, but we wanted to advise in case the conference goes extraordinarily long — if so, we'll come back to meet you as soon as it is completed.
thanks,
[REDACTED]
[REDACTED]
From: Michael Bachner [REDACTED]
Sent: Monday, July 15, 2019 19:52
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
Sent: Monday, July 15, 2019 19:52
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
Hi. Perfect. 2:00?
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 15, 2019, at 7:29 PM, [REDACTED] <[REDACTED]> wrote:
Hi Michael,
How about Thursday afternoon?
Thanks,
[REDACTED]
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
[REDACTED]
From: Michael Bachner [REDACTED]
Sent: Monday, July 15, 2019 7:20 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
Sent: Monday, July 15, 2019 7:20 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
Any updates on dates?
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 15, 2019, at 2:28 PM, Michael Bachner [REDACTED] wrote:
[REDACTED] I was just notified that a client was arrested and is being arraigned in Queens County tomorrow on a state RICO charge at about 11 or 1130. I'm concerned that the 330 may be cutting it close. It may be better to do it at four or on Wednesday. Please advise
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 15, 2019, at 1:55 PM, [REDACTED] <[REDACTED]> wrote:
Thanks very much. Let's plan for tomorrow at 3:30pm. You and [REDACTED] can come to our office at 1 St. Andrews and just give security my name.
Best,
[REDACTED]
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
[REDACTED]
-----Original Message-----
From: Michael Bachner [REDACTED]
Sent: Monday, July 15, 2019 1:42 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: RE: Epstein investigation
From: Michael Bachner [REDACTED]
Sent: Monday, July 15, 2019 1:42 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: RE: Epstein investigation
Hi [REDACTED]
Tomorrow or Wednesday at 11 or 3:30. Thursday any time after 11:30 to 4.
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
[REDACTED]
www.bhlawfirm.com
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
[REDACTED]
www.bhlawfirm.com
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally privileged. If you are not the intended recipient, you are hereby notified that any retention, dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the sender that you have received the message in error and then delete it. Thank you.
-----Original Message-----
From: [REDACTED] [mailto:[REDACTED]]
Sent: Monday, July 15, 2019 12:50 PM
To: Michael Bachner [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
From: [REDACTED] [mailto:[REDACTED]]
Sent: Monday, July 15, 2019 12:50 PM
To: Michael Bachner [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
Hi Michael,
Apologies for the delay. Would you please let us know what times would work for you and [REDACTED] in the next two or three days? We’ll then figure out a time when we can all meet.
Thank you,
[REDACTED]
[REDACTED]
On Jul 11, 2019, at 10:43 PM, Michael Bachner [REDACTED] wrote:
Hello [REDACTED] 6 o’clock is somewhat late. The client lives in [REDACTED]
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
[X]
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
[X]
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 11, 2019, at 9:01 PM, [REDACTED] <[REDACTED]> wrote:
Michael,
Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?
Thanks,
[REDACTED]
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
[REDACTED]
From: Michael Bachner [REDACTED]
Sent: Thursday, July 11, 2019 12:26 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
Sent: Thursday, July 11, 2019 12:26 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
[REDACTED]
Regarding the reverse proffer, We are available next week from the 15-18. I have a 2 o’clock meeting in my office on the 16th and 17th that should last an hour. So I can meet with you on those days at 11 or 1030 in the morning if that works. Please let me know
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 10, 2019, at 11:20 AM, Michael Bachner [REDACTED] wrote:
Sure.
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 10, 2019, at 11:08 AM, [REDACTED] <[REDACTED]> wrote:
Mike,
I think it would be useful to get a better understanding of your position—it would be helpful for us to know, for example, how much time you propose to take to evaluate matters, and whether we can provide any additional information that might be useful for that process of evaluation. That likely will affect our determination regarding the grand jury appearance, at which we would expect, were we to call [REDACTED] to ask her a number of questions we would expect to argue to the court do not implicate a fifth amendment privilege—i.e., that she couldn’t simply blanket invoke. Would it be useful to discuss via phone?
thanks,
[REDACTED]
[REDACTED]
From: Michael Bachner [REDACTED]
Sent: Wednesday, July 10, 2019 10:25
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
Sent: Wednesday, July 10, 2019 10:25
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: Epstein investigation
Dear Counsel:
I met with [REDACTED] and I need time to evaluate matters. Regarding the subpoena to testify before the Grand Jury on [REDACTED] we hereby notify you that if called as a witness [REDACTED] would invoke her Fifth Amendment privilege against compelled self-incrimination. Please let me know if you will require her to invoke in person or whether this communication suffices and no appertaining will be required.
Yours truly,
Michael Bachner
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD026.jpg>
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
[REDACTED]
Please excuse typographical errors. Messages sent through dictation.
<~WRD026.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 9, 2019, at 11:43 AM, [REDACTED] <[REDACTED]> wrote:
Mr. Bachner,
Following up on our conversation earlier this morning, we wanted to provide you with the additional information and materials we discussed. In the first instance, so that you have full contact info for the team, please feel free to reach out to any of us at any time; we’re all available via email or at the following phone numbers:
[REDACTED]
Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in Florida, and a blank version of our standard proffer agreement, both as discussed.
As we mentioned, please don’t hesitate to reach out with any questions, and we look forward to setting a time to speak again after you’re able to confer with [REDACTED]
thank you,
[REDACTED]
[REDACTED]
[REDACTED]
Assistant U.S. Attorney
Southern District of New York
[REDACTED]
Assistant U.S. Attorney
Southern District of New York
[REDACTED]
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