EFTA00021428.pdf
324 KB
Extraction Summary
4
People
4
Organizations
4
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Email chain / legal correspondence
File Size:
324 KB
Summary
This document is a chain of emails from July 2019 between defense attorney Michael Bachner and the US Attorney's Office (SDNY) regarding the Epstein investigation. The correspondence discusses scheduling a 'reverse proffer' meeting and addresses a Grand Jury subpoena for Bachner's client, who intends to invoke their Fifth Amendment privilege. The prosecution (SDNY) challenges the blanket invocation of the Fifth Amendment and shares the 2007 Epstein Non-Prosecution Agreement (NPA) and a blank proffer agreement with the defense.
People (4)
| Name | Role | Context |
|---|---|---|
| Michael Bachner | Defense Attorney |
Representing a witness/subject in the Epstein investigation; communicating with the US Attorney's office regarding su...
|
| [Redacted] (AUSA) | Assistant United States Attorney |
Prosecutor for the Southern District of New York (SDNY); coordinating with Bachner regarding his client's potential t...
|
| [Redacted] (Client) | Witness/Subject |
Client of Michael Bachner; subpoenaed for Grand Jury; likely to invoke 5th Amendment privilege; lives in a redacted l...
|
| Jeffrey Epstein | Subject of Investigation |
Mentioned in the email subject line 'Epstein investigation' and attachment 'Epstein NPA, dated 2007-09-24.pdf'.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Bachner & Associates, PC |
Law firm representing the witness.
|
|
| FBI |
Federal Bureau of Investigation; recipients in the email chain (NY Field Office).
|
|
| SDNY |
Southern District of New York (US Attorney's Office); prosecuting authority.
|
|
| American College of Trial Lawyers (ACTL) |
Linked in Michael Bachner's email signature.
|
Timeline (3 events)
2019-07-17
Witness interview in Florida (mentioned by one of the email participants as a scheduling conflict).
Florida
[Redacted Participant]
Proposed for mid-July 2019
Reverse Proffer meeting between SDNY/FBI and Michael Bachner regarding his client.
1 St. Andrew's Plaza, New York, NY
[Redacted]
Grand Jury appearance where client intends to invoke 5th Amendment.
New York
[Redacted Client]
Locations (4)
| Location | Context |
|---|---|
|
Office of Bachner & Associates, PC.
|
|
|
Office of the Assistant United States Attorney (SDNY).
|
|
|
Location of a witness interview mentioned by an email participant; also mentioned regarding previous civil proceedings.
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Residence of Michael Bachner's client.
|
Relationships (2)
Bachner writes on behalf of the client regarding subpoenas and meetings.
Client is being subpoenaed in the 'Epstein investigation' and provided with the Epstein NPA.
Key Quotes (4)
"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."Source
EFTA00021428.pdf
Quote #1
"Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?"Source
EFTA00021428.pdf
Quote #2
"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."Source
EFTA00021428.pdf
Quote #3
"attached are the non-prosecution agreement, previously publicly filed in civil proceedings in Florida, and a blank version of our standard proffer agreement"Source
EFTA00021428.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (7,390 characters)
From: [Redacted] <[Redacted]>
To: [Redacted] <[Redacted]>
(NY) (FBI)" <[Redacted]>
Subject: RE: Epstein investigation
Date: Mon, 15 Jul 2019 17:54:49 +0000
Importance: Normal
To: [Redacted] <[Redacted]>
(NY) (FBI)" <[Redacted]>
Subject: RE: Epstein investigation
Date: Mon, 15 Jul 2019 17:54:49 +0000
Importance: Normal
Great, thanks.
-----Original Message-----
From: [Redacted]
Sent: Monday, July 15, 2019 1:54 PM
To: [Redacted]; [Redacted] (FBI)
Subject: RE: Epstein investigation
From: [Redacted]
Sent: Monday, July 15, 2019 1:54 PM
To: [Redacted]; [Redacted] (FBI)
Subject: RE: Epstein investigation
Sounds good, thanks.
-----Original Message-----
From: [Redacted]
Sent: Monday, July 15, 2019 1:54 PM
To: [Redacted]
Subject: RE: Epstein investigation
From: [Redacted]
Sent: Monday, July 15, 2019 1:54 PM
To: [Redacted]
Subject: RE: Epstein investigation
Sorry, forgot about both of those things. Let's say tomorrow at 3:30?
-----Original Message-----
From: [Redacted]
Sent: Monday, July 15, 2019 1:53 PM
Subject: RE: Epstein investigation
From: [Redacted]
Sent: Monday, July 15, 2019 1:53 PM
Subject: RE: Epstein investigation
I'm going to be in Florida for a witness interview on Wednesday. But tomorrow works.
-----Original Message-----
From: [Redacted]
Sent: Monday, July 15, 2019 1:51 PM
To: [Redacted] (NY) (FBI)
Subject: RE: Epstein investigation
From: [Redacted]
Sent: Monday, July 15, 2019 1:51 PM
To: [Redacted] (NY) (FBI)
Subject: RE: Epstein investigation
I have a doctor's appointment Wednesday at 10:30 so if it's possible to do tomorrow at 11:00 or 3:30, Wednesday at 3:30, or Thursday after 4, I could do any of those times. Or if it ends up being Wednesday at 11:00, I'll get the notes after.
EFTA00021428
EFTA00021428
-----Original Message-----
From: [Redacted]
Sent: Monday, July 15, 2019 13:49
To: [Redacted] (NY) (FBI) <[Redacted]>
Subject: FW: Epstein investigation
From: [Redacted]
Sent: Monday, July 15, 2019 13:49
To: [Redacted] (NY) (FBI) <[Redacted]>
Subject: FW: Epstein investigation
Wednesday at 11 work for everyone?
-----Original Message-----
From: Michael Bachner
Sent: Monday, July 15, 2019 1:42 PM
To: [Redacted]
Cc: [Redacted]
Subject: RE: Epstein investigation
From: Michael Bachner
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
Cc: [Redacted]
Subject: Re: Epstein investigation
From: [Redacted] [mailto:[Redacted]]
Sent: Monday, July 15, 2019 12:50 PM
To: Michael Bachner
Cc: [Redacted]
Subject: Re: Epstein investigation
Hi Michael,
EFTA00021429
EFTA00021429
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]
https://www.actl.com/
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] 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]
EFTA00021430
From: Michael Bachner
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/
[Standard Confidentiality Notice]
On Jul 10, 2019, at 11:20 AM, Michael Bachner <[Redacted]> wrote:
Sure.
Sure.
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
<~WRD000.jpg>
https://www.actl.com/
[Standard Confidentiality Notice]
EFTA00021431
EFTA00021431
On Jul 10, 2019, at 11:08 AM, [Redacted] wrote:
Mike,
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
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>
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/
[Standard Confidentiality Notice]
EFTA00021432
EFTA00021432
On Jul 9, 2019, at 11:43 AM, [Redacted] wrote:
Mr. Bachner,
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]
Assistant U.S. Attorney
Southern District of New York
[Redacted]
[Redacted]
[Redacted]
Assistant U.S. Attorney
Southern District of New York
[Redacted]
EFTA00021433
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