MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW 20 PARK PLAZA, SUITE 1000 EMAIL ADDRESSES: BOSTON, MASSACHUSETTS 02116 owlmcb@att.net owlmgw@att.net (617) 227-3700 FAX (617) 338-9538 NIGHT EMERGENCY: (617) 901-3472 July 22, 2011 Southern District of Florida 500 S. Australian Ave. Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the NPA. Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order. Very truly yours, Mak. 3 Wasbe Le Martin G. Weinberg ce: Roy Black EFTA00206166