From: Robert Lewis < To: Subject: Epstein -- Date: Thu, 25 Jul 2019 18:11:08 +0000 Dear Alexander and Alison: I represent a potential witness in your Epstein case. As you will recall, we spoke about r back in March, when you reached out to see if mm would speak to you and we agreed that you could. Although you have not contacted AE | 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 toa Jesse Rose (his employment lawyer) and me (who represented him in the Maxwell case) by email and phone, as well coming t ome twice. He is seeking our comments and information concerning the Dubins an estimony in the Maxwell case. According to McIntire, the Times is planning to run story on the Dubing and their ties to Epstein. It also appears that the Times has a copy of all or a portion of the deposition 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 toiiileposition testimony), no mandate has issued or documents been unsealed. In addition, the Times tells us that a "representative" of the Dubins has told it a RE ia in his deposition. If a representative did that, it is both defamatory and breaches a non-disparagement provision in the settlement agreement with The Times also informs that flight documents purportedly do not corroborate certain portions 0 eposition. We do not have access to those flight documents, but we understand that Epstein's flight documentation is incomplete if pot materially inaccurate. Also pursuant to his estroyed all of the documents he possessed his testimony, settlement of his employment dispute with the Dubins pertaining to the Dubins, which might corroborate some o We have rebuffed the Times’ entreaties because of confidentiality obligation Eas pursuant to a settlement agreement in the employment case and the confidentiality order in the Maxwell case, as well as his desire to avoid doing anything that would undermine your criminal prosecution. Should you need or want a copy of FE ceposition transcript in the Maxwell case, we would provide it to you pursuant to subpoena. If you wish to discuss these matters, please do not hesitate to call. Best regards, Bob Lewis wa ROBERT Y. LEWIS www.freemanlewis.com EFTA00095361

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