sunject: ML: Revised JointStatement ae s Date: Mon, 29 Nov 2010 14:13:56 +0000 Importance: Normal The afternoon of December 1 is a good time for Subject: RE: Revised Joint Statement of Facts Dear Dexter, Thanks for giving us a proposed statement of facts from the Government. It immediately raises many question for us, including: 1. We notice that you have objected to a number of our facts that are based -- word-for-word -- on e-mails prepared by the Government. You mention that you would like tosee these e-mails. Marie has a full copy of what we were sent by Epstein's counsel. And, of course, these are all the Govemmen't e-mails to begin with. 2. Given that you have copies all of these emails, can you agree to all the facts reflected by the e-mails? We really don't understand the basis for your objection to our facts quoting THE GOVERNMENT'S e-mails? Is there really some dispute about these facts? 3. As you and Marie know, the emails in our possession were, improperly, redacted by Epstein's attronehys to indude only the government's half of the conversation. Will you provide us with the other half of these converations? 4. Our previous e-mail to you, we requested a copy of various documents in your possession, including (for example) the reports of interviews of our clients. Your responsive e-mail did not reply to that question at all. Will you provide a copy of these materials? 5. Our previous message to you -- indeed, our messages dating back to October -- requested that you provide an outline of what you believe is the proper procedure for resolving our client's claims. In your view, do we need to file a new civil complaint? Can we file in the nature of our summary judgment motion in our existing case -- the procedure I have followed in our courts around the country? You have not responded -- just we needed to take two years to get you to respond regarding your statement of facts. (We understood, as you recounted in your previous e-mail, t