vision-joined/ds9-unparsed-05/092cb95b80dea57a66ce989dc8d36e4ea0d691c3191f080d2073c76d80a232b6.md

OLY-76
EFTA00187009

TO: ERIC GANY
NES, LLC
Uruted States District vourt
SOUTHERN DISTRICT OF FLORIDA
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
FGJ 07-103(WPB)/No. OLY-76
SUBPOENA FOR:
PERSON
DOCUMENTS OR OBJECTISI
YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
Court at the place, date and time specified below.
PLACE:
United States District Courthouse
701 Clematis Street
West Palm Beach, Florida 33401
ROOM:
Grand Jury Room
DATE AND TIME:
September 11, 2007
1:00 pm*
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
*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.
CLERK
(BY) DEPUTY CLERK
This subpoena is issued upon application
of the United States of America -
DATE:
August 16, 2007
*If not applicable, enter "none."
Name, Address and Phone Number of Assistant U.S. Attorney
Assistant U.S. Attorney
500 So. Australian Avenue, Suite 400
West Palm Beach, FL. 33401-6235
Tell
Fax
To be used in lieu of AO110
FORM ORD-227
JAN.86
EFTA00187010

N HIA aW
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CONNECTION TEL
SUBADDRESS
CONNECTION ID
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USAGE T
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RESULT
0344
08/16 17:05
02'43
10
OK
U.S. Department of Justice
United States Altorney
Southern District of Florida
A. Marie Villafaña
500 S. Australian Ave, 4th Floor
Vest Palm Beach, Florida 33401
FACSIMILE COVER SHEET
TO:
DATE:
FAX NO. (
PHONE NO._
Gerald Lefcourt, Esq.
August 16, 2007.
#OF PAGES:
RE:
10
NES, LLC
FROM:
PHONE NO.
Assistant U.S. Attorney
COMMENTS:
EFTA00187011

U.S. Departme-* of Justice
United States Attorney
Southern District of Florida
A. Marie Villafaña
500 S. Australian Ave, 4th Floor
Wer Palm Reach Elorida 33401
FACSIMILE COVER SHEET
TO:
DATE:
FAX NO.
PHONE NO.
FROM:
PHONE NO.
COMMENTS:
Gerald Lefcourt, Esq.
August 16, 2007
# OF PAGES: 10
RE:
NES, LLC
EFTA00187012

U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
Want Dalm Roach RI
22401
August 16, 2007
VIA FACSIMILE
Gerald Lefcourt, Esq.
Gerald P. Lefcourt, P.C.
148 East 78th Street
New York, NY 10021
Re: Subpoena to Custodian of Records, NES, LLC
Dear Mr. Lefcourt:
I write in response to your letter of July 18, 2007 regarding the grand jury subpoena issued
to the Custodian of Records for NES, LL.C. I have attached an identical subpoena containing a return
date of September 11, 2007, and subpoenas for two NES employees, Eric Gany and Harry Beller.
If you will not be representing Messrs. Gany and Beller, please let me know.
First, as I mentioned in my earlier correspondence, a properly executed declaration from the
Custodian of Records is needed, and, if no documents responsive to a particular request exist, the
Custodian should certify that under penalty of perjury.
Second, you write that NES has no documents responsive to Requests 1 through 5. I know
that NES has several credit card accounts for the benefit of the persons who manage Mr. Epstein's
properties, including Janusz Banasiak and Alfredo Rodriguez. I also know that NES regularly
receives money from an account that is used to pay expenses at 358 El Brillo Way and also wires
money to that same account. Those wire transfers fall within the time period called for by the
subpoena and number in the hundreds of thousands of dollars. INES does not maintain records of
its banking activities, then I would like to see a copy of its document retention policy, so I have
added that to the Attachment to the Subpoena.
Third, Mr. Menchel's comment to you about potential money laundering charges related only
to a resolution of the case. In other words, if the sex offense case is resolved, the Office would close
its investigation into other areas as well. The matter has not been, and it does not appear that it will
be, resolved so the money laundering investigation continues, and Request Number 6 will not be
withdrawn. The request is not overbroad and is stated with particularity, so please comply with the
request by the new deadline.
EFTA00187013

GERALD LEFCOURT, ESQ.
AUGUST 16, 2007
PAGE 2 OF 2
With respect to paragraph 7, the information provided regarding the pilots came from the
corporate records of Hyperion and JEGE, Inc., not NES. However, I have provided a shorter list in
the new subpoena attachment.
I also have enclosed another certification for the Custodian of Records' signature.
Thank you again for your assistance.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
Assistant United States Attorney
CC:
FBI (with enclosures)
EFTA00187014