EFTA00014576.pdf

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pdf

Source set

data-set-8

Original source

Extracted text

MARTIN G. WEINBERG, P.C. 
ATTORNEY AT LAW 
EMAIL ADDRESSES: 
August 1, 2019 
By Electronic Mail 
Assistant United States Attorneys 
U.S. Attorney's Office for the 
Southern District of New York 
One St. Andrew's Plaza 
New York, New York 10007 
Re: 
United States v. Jeffrey Epstein, No. 19-cr-00490 
Supplement to Defendant's First Request for Discovery 
De 
We write to supplement our first request for discovery that was electronically mailed to you 
on July 26, 2019 that sought the preservation and production of documents relating to the NPA 
and issues arising from the NPA. We wanted to particularize certain requests that were 
applicable to the United States Attorney's Office (hereinafter "USAO") for Southern District of 
Florida and the FBI Office that were working with them as follows: 
To request that AUSA 
who was the lead prosecutor investigating Mr. 
Epstein in 2006-8 produce or in the alternative agree to preserve any and all documents, 
communications whether emails from any and all email accounts from which she was sending or 
receiving relevant emails, texts, letters, papers, voice messages, tapes or any other information 
that: 
I. Relate to any investigation and any interviews conducted by the USAO for the 
Southern District of Florida and/or the USAO for the Southern District of New York 
and FBI agents from either or both offices in 2008 in and around New York City, 
includin but not limited to an interview of a 
with 
, any other potential witness, 
and/or communications 
and any other 
EFTA00014576


representative of any USAO for the Southern District of New York between January I 
— June 30 2008. This request includes any communications prior to or during AUSA 
March 2008 trip to New York and any communications that resulted from 
the trip. 
2. Relate to her communications with her victim witnesses either directly or through 
their counsel wherein she discussed their right to confer with a USAO other than the 
Southern District of Florida. 
3. Re…

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