EFTA00039001.pdf

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

From: "Ruzumna, Daniel (x2034)" 
To: 
<Ma 
Cc: "Weiner, Daniel H." 
Subject: 
Date: 
Importance: 
Attachments: 
"Lau, Sean (x2742)" 
[EXTERNAL EMAIL] - Epstein Estate 
Wed, 19 Apr 2023 19:21:55 +0000 
Normal 
22cv10904_Doc_112_Order_Re_Estate's Review_of_Videomaterials_re_CSAM.pdf 
, "Weinstein, Marc A." 
"McDonnell, Hilary" 
, "Norris, Tara (x2847)" 
Dear Special Agent =I 
As you have apparently heard from AUSA 
=I, 
we represent one of the two co-executors of the 
Estate of Jeffrey Epstein. Hughes Hubbard & Reed represents the other. Recently, we have been responding to 
requests/demands for documents in connection with a settlement that the Estate entered into with the 
Government of the U.S. Virgin Islands and in response to subpoenas issued in litigations pending before the U.S. 
District Court for the Southern District of New York. The Estate is not a party to the SDNY litigation. 
As part of the Estate's document production obligations, we are reviewing approximately 1,100 videos that were 
pulled from Epstein's emails and other files. Because of the potential existence of child pornography in those 
videos, we worked out a protocol with the parties to whom we owed document production obligations, and that 
protocol gave our reviewers protection and comfort in undertaking the review. The protocol was submitted to 
the SDNY Court (Judge Jed Rakoff), who signed the "Order regarding Review of Videomaterials." (Attached). 
During the review yesterday, our co-counsel at Hughes Hubbard came across a video that may contain child 
pornography. Apparently the relevant video was shared with Epstein by an individual who was convicted of a 
child pornography-type offense and it .ac
 one or two topless women. In an abundance of caution, we 
halted the review and reached out to 
. Co-counsel at Hughes Hubbard (Dan Weiner and Hilary 
McDonnell) can correct any misstatements in my description of the review since I heard the account 
secondhand. 
We would appreciate any guida…
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