EFTA00020773.pdf

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

From: IS" 
'c
IMIE> 
To: "Weinstein, Marc A." 
, Andrew Tomback 
Cc: 
1.
Subject: RE: SDNY investigation, re: estate 
Date: Fri, 17 Jul 2020 22:26:45 +0000 
Marc, Andy, 
Following up on our conversation yesterday, we wanted to briefly confirm a few things we discussed and also respond to 
your question. To reiterate, we agree that your plan with respect to the materials you have identified in the New York 
residence makes sense, i.e., to have the photographs scanned and then produced to us in electronic format. To the extent 
we need any originals of materials initially produced electronically in that fashion, we will of course follow up. 
Additionally, and related, to the extent there are materials that are more conducive to being produced in their original 
format, such as the photo book you mentioned specifically, we can receive those in hard copy. As a general matter, I think 
those would only be materials that cannot be individually scanned or copied without removing them from some relevant 
contextual placement or arrangement; that said, if you or your vendor believes individual items require a judgment call, 
please feel free to check in with us on any specific questions. 
Regarding loose, unlabeled discs, we are not requesting their production at this time. If there are discs that are labeled in 
some way that indicates or suggests they contain photos in particular, please let us know, as we likely would request 
production of those items. For discs that do not fit that description, we assume those will be retained by the estate in any 
event, but please let us know if that is incorrect, or if at some subsequent point that status is expected to change. 
Finally, I know we raised the issue of privilege for the first time on our call, so I just want to reiterate that the Government 
is in no way requesting any waiver, but rather advising you and your clients that we may at some point in the coming 
weeks seek a formal position on whether the estate intends to …
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