EFTA00016132.pdf

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Source set: data-set-8
Extracted text

MARTIN G. WEINBERG, P.C. 
ATTORNEY AT LAW 
EMAII ADDRESSES 
BOSTON, MASSACHUSETTS 02116 
FAX 
NI
CY 
July 26, 2019 
Electronic Mail 
Assistant United States Attorneys 
U.S. Attorney's Office for the 
Southern District of New York 
New York, New York 10007 
Re: 
United States v. Jeffrey Epstein, No. I 9-cr-00490 
Defendant's First Request for Discovery 
Dear 
We represent Jeffrey Epstein in the above-referenced matter. We write to request the 
preservation and production of several important categories of documents. 
The following request and future requests' encompass not only documents and 
information in your office's possession, custody, or control, but also documents that the 
government has the legal right or practical ability to obtain. Such information includes, but is 
not limited to, information in the possession, custody, and control of any agency of the United 
States involved in any way in regulating or investigating the activities alleged in the Indictment 
or related transactions, including but not limited to the Department of Justice (including but not 
limited to the Child Exploitation and Obscenity Section, other offices of "Main Justice," the 
Federal Bureau of Investigation and all United States Attorney's Offices), the Securities and 
Exchange Commission, and the Department of Homeland Security. In addition, such 
information includes information in the possession, custody, and control of any local, state, or 
I All of these requests are/will be continuing in nature, requiring supplementation in accordance with, (MCI aka, 
Rule 16(c) of the Federal Rules of Criminal Procedure. 
EFTA00016132


foreign law enforcement entities involved in any way in regulating or investigating the activities 
alleged in the Indictment or related transactions.2
Whether or not you to intend to comply with this (or future) requests for discovery, we 
respectfully request that you: (I) preserve all documents3, conununications° and/or tangible 
objects related to, conce…
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