U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 January 24, 2007 DELIVERY BY HAND Bruce M. Lyons Lyons and Sanders Fort Lauderdale, FL 33304 Re: Federal Grand Jury Subpoena Dear Bruce: A new grand jury has been aaneled and I have enclosed a new subpoena for . As I mentioned earlier, Ms. is not a target of this investigation and the United States seeks her testimony solely as a witness. During our last conversation regarding Ms. you indicated that she was unwilling to speak with us pursuant to a Kastigar letter. Please confer with her to confirm whether this remains her position. If Ms. is not amenable to an informal meeting, she must still appear pursuant to the subpoena so that I may ask her questions that would not require the invocation of the Fifth Amendment. If she still invokes, I intend to move to compel her answers. If you or your client is unavailable on February 6, 2007, please let me know of another Tuesday when you are available. I also am concerned about a potential conflict of interest in your representation of Ms. . In case of future litigation regarding this issue, please provide me with information regarding who is paying (directly or indirectly) for your services on behalf of Ms. M, the scope of your re resentation, and whether you are taking direction on this matter from anyone other than Ms. . If any formal or informal joint defense agreements exist, whether in writing or otherwise, please provide a copy of such agreements. If the agreement is purely oral, please provide a written summary of its terms. BRUCE LYONS, ESQ. JANUARY 24, 2007 PAGE 2 I look forward to your response. Sincerely, R. Alexander Acosta United States Attorney By: Assistant United States Attorney EFTA00220932