EFTA00027375

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From: Robert Lewi To: Subject: Epstein -- Date: Thu, 25 Jul 2019 18:11:08 +0000 Deai I represent a potential witness in your case. As you will recall, we spoke about Mr. back in March, when you re ached out to see if Mr. would speak to you and we agreed that you could. Although you have not contacted Mr. = I thought you should know about some recent developments. For the last week or so the New York Times (Mike McIntire) has been aggressively reaching out to Mr. =, Jesse Rose this employment lawyer) and me (who represented him in the Maxwell case) by email andi , as wella to Mr. home twice. He is seeking our comments and information concerning the and Mr. testimony in the Maxwell case. According to McIntire, the Times is planning to run story on th and their ties to Epstein. It also appears that the Times has a copy of all or a portion of the deposition Mr. gave in the Maxwell case, which is troubling because it was subject to confidentiality in that case and, although the Second Circuit has ordered the unsealing of the summary judgment papers (which likely include references to Mr. deposition testimony), no mandate has issued or documents been unsealed. In addition, the Times tells us that a "representative" of the has told it that Mr. "lied" in his deposition. If a representative did that, it is both defamatory and breaches a non-disparagement provision in the Mi msettlement agreement with Mr. . The Times also informs that flight documents purportedl