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CDuilel dg at Oe tegtinh a D orbhel paca Pe eo — <hita tack 2) boy act of product on priikg-fi- ® Me oe oe ol @ Cover tH a) procduschon Gene inunivYuvadt the EFTA00179235

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Dees he ator cod wivikee opply | _~ privilege taee ws ata & for -Allen vi Mehr PoC e BEZ, Coe (44 Civ. 9F1 —fre pivi ers tre & si ape ¢ ee Facks . GOY Citing Up, GUL <a ot 346) Re “ser voor godt doctrine ov yank aval an a bor I Axxo oo the laude» Sh Lato ~ Rk eth av Lot og hvcaphe Borel vp. V. Kons, 1466 2 653, URL (LO Gy. | 1Aea) (exkuit Cio hoy owiklead EFTA00179236

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RETURN OF SERVICE: RECEIVED DATE PLACE BY SERVER os/e aod West Puln Beat =e. SERVED DATE os/2 fags PLACE Heleok, Fu SERVED ON (NAME) Paw! A. Lavery SERVED BY TITLE Frei S4 STATEMENT OF SERVICE FEES DECLARATION OF SERVICE? | declare under penalty of perjury under the laws of the United States of America that the foregoing Information contained in the Return of Service and Statement of Service Fees Is true and correct. Executed on_OS7 poyse ? DATE ture of Server es Address of Server ADDITIONAL INFORMATION 1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or Rule 45(c), Federal Rules of Civil Procedure. 2."Fees and mileage need not be tendered to the witness upon service of a subpoena Issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC 1825, Rule 17(b) Federal Rules of Criminal Procedure)" EFTA00179237

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U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 ‘acsimile: June 6, 2007 VIA FACSIMILE Robert I. Targ, Esq. Diaz Reus Rolff & Targ LLP 100 S.E. Second Street, Suite 2600 Miami, FL 33131 Re: Subpoena to Paul Lavery Dear Mr. Targ: Thank you for your letter of June 4, 2007. Following receipt of your letter, I conducted some additional research regarding your blanket assertion of the attorney-client and work product privileges prior to the appearance before the grand jury. My research shows that the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States v. Schaltenbrand, 930 F.2d 1554 (11th Cir. 1991); United States v. Mujioz, 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables, 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co., 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty Advisors, Inc., 185 F.R.D. 251 (N.D. Ill. 1999). Furthermore, blanket assertions are not proper, and the assertion must be made on a question-by-question and document-by- document basis. See, e.g., Nguyen v. Excel Corp., 197 F.3d 200 (5th Cir. 1999); Clarke v. American Commerce Nat. Bank, 974 F.2d 127 (9th Cir. 1992); United States v. White, 950 F.2d 426, 430 (7th Cir. 1991). I do not intend to ask questions that fall within these privileges and the documents requested also do not fall within either of these privileges. Accordingly, I have enclosed a revised grand jury subpoena that provides, in greater detail, the list of documents requested. I have asked for Mr. Lavery to appear on June 19, 2006, so that, if you believe that you have a basis for a pre-appearance motion for protective order or motion to quash, you will have time to prepare and file that motion. In case you decide to file such a motion, United States District Judge Middlebrooks is assigned to handle EFTA00179238

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ROBERT I. TARG, EsQ. JUNE 6, 2007 PAGE 2 OF 2 matters related to the relevant grand jury. Pursuant to Fed. R. Crim. P. 6(e)(6), any such motion must be filed under seal. If you elect not to file such a motion, I will expect Mr. Lavery’s appearance before the grand jury on June 19, 2006. Please contact myself or Special — on June 18, 2006, to confirm the time for appearance. Ifa motion is not filed and Mr. Lavery does not appear, I will proceed in accordance with Fed. R. Crim. P. 17(g). If you have any questions, please do not hesitate to call me. Sincerely, R. Alexander Acosta United States Attorney By: Assistant United States Attorney ce: fF ss FBI (with enclosure) EFTA00179239

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SERVED ON (NAME) Robert T. larg, Ese. STATEMENT OF SERVICE FEES DECLARATION OF SERVICE’ | declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and Statement of Service Fees is true and correct. Executed on 6 5 hI DATE Signature of Server 4.S..Adtornugs OF ee, W. fal BA, FZ ADDITIONAL INFORMATION srvee VA facounily mm CDinael Air the 1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or Rule 45(c), Federal Rules of Civil Procedure. 2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC 1825, Rule 17(b) Federal Rules of Criminal Procedure)" EFTA00179240

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ATTACHMENT A SUBPOENA TO PAU AVERY All computer equipment and electronic storage media removed from the residence located at 358 El Brillo Way, Palm Beach, Florida, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. All documents and information related to the nature of the relationship between Mr. Paul A. Lavery and/or Paul A. Lavery and Associates Investigative Services, Inc. and Mr. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates of communications with Mr. Epstein (or with a third party on Mr. Epstein’s behalf); appointment calendars/datebooks and the like (whether in hard copy or electronic form) for any period when work was performed on behalf of Mr. Epstein or when any communication was had with Mr. Epstein (or with a third party on Mr. Epstein’s behalf); and records of fee arrangements and payments received for work performed on Mr. Epstein’s behalf. EFTA00179241

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06/06/2007 19:09 FAX 5618021787 USAO WPB FL Mooi LELELERALELASLSRRSRSS Se TX REPORT ee HELELELALASLALATLSRSS TRANSMISSION OK TX/RX NO 4844 CONNECTION TEL 13053758050 SUBADDRESS CONNECTION ID ST. TIME 06/06 19:08 USAGE T 00'43 PGS. SENT 5 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 h, Florida 33401 FACSIMILE COVER SHEET TO: ROBERT I. TARG, ESO. DATE: June 6, 20 Fax NO. _— ss #«OF':~PAGES: 5 puone NO. [MM RE: PA VE FROM: ASS U.S. ~ PHONE NO. PY ve COMMENTS : EFTA00179242

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U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 Facsimile FACSIMILE COVER SHEET TO: ROBERT I. TARG, ESQ. DATE: June 6, 2007 rax No. [stor paces: 5 PHONE NO. [x RE: _PAUL A. LAVERY FROM: ASSISTANT U.S. ATTORNEY PHONE NO. FP —— COMMENTS : EFTA00179243

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United States District Court SOUTHERN DISTRICT OF FLORIDA TO: Paul A. Lavery, in his individual SUBPOENA TO TESTIFY capacity and as custodian of records BEFORE GRAND JURY for Paul A. Lavery and Associates ; : ; Investigative Services, Inc. FGJ 05-02(WPB)-Fri./No. OLY-49/2 5325 West 20" Lane company Hialeah, FL 33016 SUBPOENA FOR: PERSON DOCUMENTS OR OBJECTS] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time specified below. ROOM: Grand Jury Room PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 DATE AND TIME: June 19, 2007 1:00 pm* YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): THE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT A. *Please coordinate your compliance with this subpoena and confirm the date, time, and location of your appearance with Federal Bureau of Investigation, Telephone: This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court. (BY) DEPUTY CLERK This subpoena is issued upon application Name, Address and Phone Number of Assistant U.S. Attorney of the United States of ic HR Assistant U.S. Attomey 500 So. Australian Avenue, Suite 400 West Palm Beach, FL 33401-6235 Tel: Fax: *if not applicable, enter “none.” To be used in liew of AQTIO FORM ORD-227 JAN.86 EFTA00179244

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\ RETURN OF SERVICE' \ SERVED PLACE (A SAO -LFB V 10. foxy. to Robert SERVED ON (NAME) Robert T. larg ! ESE . STATEMENT OF SERVICE FEES TRAVEL SERVICES TOTAL DECLARATION OF SERVICE? | declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Retum of Service and Statement of Service Fees is true and correct. Executed on 5 7 DATE Signature of Server U.S Attorrugs OfGe2, W. Fal BA, H. Address of Server ADDITIONAL INFORMATION Sve Via facounrily an Canal Air He 1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or Rule 45(c), Federal Rules of Civil Procedure. 2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC 1825, Rule 17(b) Federal Rules of Criminal Procedure)” EFTA00179245

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ATTACHMENT A SUBPOENA TO PAUL A. LAVERY All computer equipment and electronic storage media removed from the residence located at 358 El Brillo Way, Palm Beach, Florida, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. All documents and information related to the nature of the relationship between Mr. Paul A. Lavery and/or Paul A. Lavery and Associates Investigative Services, Inc. and Mr. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates of communications with Mr. Epstein (or with a third party on Mr. Epstein’s behalf); appointment calendars/datebooks and the like (whether in hard copy or electronic form) for any period when work was performed on behalf of Mr. Epstein or when any communication was had with Mr. Epstein (or with a third party on Mr. Epstein’s behalf); and records of fee arrangements and payments received for work performed on Mr. Epstein’s behalf. EFTA00179246

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is as FAX DIAZ REUS ROLFF & TARG REUS ROLFF TARG LLP JRNEYS & COUNSELORS YOUR GLOBAL EXPANSION TEAM TELEFAX TRANSMITTAL SHEET DaTE: June 4, 2007 os BN Esquire Assistant U.S. Attorney U.S. Attorney’s Office FAK | OM: Robert I. Targ Ruy Vis Paul Lavery Federal Grand Jury Subpoena ]' 3SSAGE: Please see attached correspondence. Lurabeer of pages transmitted (including cover sheet): 2 Goo1/o02 Lk NE SOOO Cera He EEE OE KER OOREE DEES TS S25 2555225 F EOE ORE AREER ESTEE RODE S OT EEE EHEHR EER EOE “| § wensmittal is intended only for the use of the addressce and may contain information that is privileged, confidential and exitop: from disclosure by law. If the reader of this transmittal is not the intended recipient, you are hercby notified that any |;etvbaation, distribution or copying of this communication is strictly prohibited, If you have received this communicution in er ot please notify us immediately by telephone and return the original transmittal to us by mail. ret peretion. Thank you for your Ch PSU SRE eee ee Oke eek eke EKECKEHHE EE HEHG ROO DORR EEE e ETE TESEEHE SHE EH OEP ESSE TES ESE SSCS ER SHEOEH /f+/ou rave not received a clear and aun transmission or if there are any problems with this transmission, please ta :ohome us immediately at 100 Southeast Second Street, 2600 Bank of America Tower * Miami, Florida 33131 + www drtlaw.com info@drrtlaw.com fo Caracas, Venezuela EFTA00179247

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Hf Ili, gil i] ne): 1:49 aX OIAZ REUS ROLFF & TARG | b DIAZ REUS_ S_ ae TARG "8S @ COUNSELORS te GaN con Gaeur June 4, 2007 Via Facsimile FY MS Esquire Assistant U.S. Attorney U.S, Attorey’s Office 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 Re: Paul Lavery ‘a d Jury Subpoena Dear Ms. Villafara: oo2/o0c2 MIAMI] OFFICE 100 S.E. Second Streer Suite 2600 Bank of Americn Tuwer Mia BUSA Tel: Fax: wow. drrtuw.com, This will confirm our telephone conversation of earlier today wherein I advised you that my client, Mr. Paul Lavery, would assert the privilege (both work product and attomey-client) on behalf of Mr. Jeffrey Epstein if called before the Grand Jury pursuant to the Grand Jury Subpoena issued on May 21, 2007. Based upon this confirming letter, it is my understanding that Mr. Lavery is excused from appearing before the Grand Jury tomorrow, June 5, 2007. Thank vou for your professional courtesies in these regards. jncerely, Robert I. Tar, RTeg ce: Paul Lavery EFTA00179248

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ATTACHMENT A OEN PAUL A. LAVE All computer equipment and electronic storage media removed from the residence located at 358 El Brillo Way, Palm Beach, Florida, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. All documents and information related to the nature of the relationship between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates of communications with Mr. Epstein (or with a third party on Mr. Epstein’s behalf); appointment calendars/datebooks and the like (whether in hard copy or electronic form) for any period when work was performed on behalf of Mr. Epstein or when any communication was had with Mr. Epstein (or with a third party on Mr. Epstein’s behalf); and records of fee arrangements and payments received for work performed on Mr. Epstein’s behalf. EFTA00179249