Date: Thu, 25 Jul 2019 6:13:49 PM (UTC) Sent: Thu, 25 Jul 2019 6:11:08 PM (UTC) Subject: Epstein Rinaldo Rizzo From: To: Dea I represent tna o izzo, a potential witness in your Epstein case. As you will recall, we spoke about Mr. Rizzo back in March, when you reached out to see if Mr. Rizzo would speak to you and we agreed that you could. Although you have not contacted Mr. Rizzo, I 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 to Mr. Rizzo, Jesse Rose (his employment lawyer) and me (who represented him in the Maxwell case) by email and phone, as well coming to Mr. Rizzo's home twice. He is seeking our comments and information concerning the Dubins and Mr. Rizzo's testimony in the Maxwell case. According to McIntire, the Times is planning to run story on the Dubins and their ties to Epstein. It also appears that the Times has a copy of all or a portion of the deposition Mr. Rizzo 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 to Mr. Rizzo's deposition testimony), no mandate has issued or documents been unsealed. In addition, the Times tells us that a "representative" of the Dubins has told it that Mr. Rizzo "lied" in his deposition. If a representative did that, it is both defamatory and breaches a non-disparagement provision in the settlement agreement with Mr. Rizzo. The Times also informs that flight documents purportedly do not corroborate certain portions of Mr. Rizzo's deposition. We do not have access to those flight documents, but we understand that Epstein's flight documentation is incomplete, if not materially inaccurate. Also pursuant to his settlement of his employment dispute with the Dubins, Mr. Rizzo destroyed all of the documents he possessed pertaining to the Dubins, which might corroborate some of his testimony, We have rebuffed the Times' entreaties because of confidentiality obligations Rizzo has 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 Mr. Rizzo's deposition 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 ROBERT V. LEWIS 3501.497-003 Page 1 of 2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00096425 EFTA01250176 CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential and may be subject to the attorney-client privilege, or others, ise protected from disclosure by applicable lass. Any disclosure, distribution, copying, or use of the information contained in this message or any attachment by anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not the intended recipient, please telephone or email the sender and delete this message and any attachment from your system. 3501.497-003 Page 2 of 2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00096426 EFTA01250177