EFTA00029728.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: ' 
To: ' 
Cc: "Martin G. Weinberg" 
"Wein arten Reid" 
r< 
Subject: Re: U.S. v. Epstein call 
Date: Sun, 25 Aug 2019 19:04:28 +0000 
Marty, 
Following up on our conversation last week, are you able to share with us your thoughts on whether the defense 
intends to address the Court beyond noting that there is no objection to the dismissal? 
Separately, if you could please let us know the status of the return of discovery materials, we would appreciate it. 
We are hopping to be able to tell the Court on Tuesday that this issue is resolved. 
Thanks, 
Sent from my iPhone 
On Aug 22, 2019, at 12:09 PM, 
Marty, 
)< 
> wrote: 
I got your voicemail from this morning regarding follow-up on civil forfeiture—we have a meeting at 12:30 that I expect 
will go approximately 15 minutes and will plan to give you (or Mike, to conference you in) a call after that, so 
approximately around 12:45 — 1:00. 
Separately, based on the expected nolle order, and in connection with the protective order in this case, in advance of the 
hearing on Tuesday can you please either return to the Government all discovery you received in this case and certify 
that any copies have been security destroyed or deleted, or, alternatively, simply certify that all discovery received has 
been security destroyed or deleted? (As to the second option, that is to say that you do not need to make additional 
copies of electronic materials to formally "return" them to us if it is more efficient to simply delete and destroy the 
existing electronic copies you have.) We want to be able to advise the Court on Tuesday that there are no outstanding 
discovery obligations on either side based in connection with the protective order. 
Thank you, 
Assistant U.S. Attorney 
Southern District of New York 
EFTA00029728
Open in the interactive archive →