EFTA00015937.pdf

Type: pdf
Source set: data-set-8

Extracted text

Akin Gump
STRAUSS HAUER & FELD LLP
November 19, 2019
CONFIDENTIAL PURSUANT TO FED. R. CRIM. P. 6(e)
VIA ELECTRONIC DELIVERY
Assistant U.S. Attorney
U.S. Attorney's Office
Southern District of New York
New York, NY 10007
Re: July 11, 2019 Subpoena to Deutsche Bank
Dea
On behalf of our client, Deutsche Bank AG, New York Branch and its affiliates ("Deutsche
Bank" or the "Bank"), we write in further response to the grand jury subpoena dated July 11, 2019
(the "Subpoena"). This letter and the enclosed document production represent the eleventh
submission in our client's rolling response to the Subpoena.
Enclosed with this letter is an encrypted file labeled DB-SDNY-PROD011 containing
documents responsive to items I, 4, 7, 9, 12, 19, 20, and 27 of the Subpoena. As described in the
enclosed production index, labeled Appendix A, today's production contains the following
categories of documents responsive to the Subpoena:
•
DB-SDNY-0028783 to 0031309:
Bank records and electronic
communications related to the following topics:
o The Bank's decision to onboard the Epstein Relationship
(designated as "Onboarding" in Appendix A);
o In-person meetings between Bank personnel, Jeffrey Epstein, and/or
his associates (designated as "Meetings" in Appendix A);
o The transfer of Jeffrey Epstein's assets from JP Morgan to Deutsche
Bank from 2013 through 2014 (designated as "Transfer" in
Appendix A);
EFTA00015937

November 19, 2019
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o The Bank's policies and procedures related to its Americas
Reputational Risk Committee from 2013 to 2018 (designated as
"ARRC" in Appendix A);
o Certain revenue-sharing accounts opened by the Bank in connection
with the Epstein relationship (designated as "Revenue Sharing
Accounts" in Appendix A).
•
DB-SDNY-0031310 to 0031643: Bank records related to wire transfers
from Jeffrey E stein's charitable entity, Gratitude America, Ltd., to the
Foundation (designated as `4
" in
Appendix A).
•
DB-SDNY-0031644 to 003…

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