EFTA00027234.pdf

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pdf

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data-set-8

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U.S. Department of Justice 
United States Attorney 
Southern District of New York 
life Silvio J. Mollo Building 
New York, New York 10007 
August 8, 2019 
VIA EMAIL 
Martin G. Weinberg, Esq. 
Martin G. Weinber P.C. 
Boston, MA 02116 
Reid Weingarten, Esq. 
Michael Miller, Esq. 
Ste toe & Johnson LLP 
New York, NY 10036 
Re: 
United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) 
Dear Mr. Weinberg: 
The Government writes in response to your letters dated July 26, 2019, requesting 
preservation and production of seven general categories of documents (the "July Letter"), and 
August 1, 2019, requesting preservation and production in connection with a particular individual 
(the "August Letter") (collectively, the "Letters"). 
Without conceding any obligation to preserve any of the categories of documents identified 
in the Letters (let alone any obligation to produce responsive documents to the extent any exist), 
we will take reasonable steps to ensure the preservation of any documents we believe may be 
responsive to the various categories identified in the Letters to the extent such documents are 
already within the possession, custody, or control of the U.S. Attorney's Office for the Southern 
District of New York (this "Office"). Other than documents within the possession, custody, or 
control of this Office, we will not be requesting or directing that any other office or agency, local, 
state, federal, or foreign, including any other office or component of the U.S. Department of 
Justice, or any other nonparty to this case, including but not limited to victims or their counsel 
(collectively, and without limitation, the "Non-Party Entities and Individuals"), to institute such 
preservation. Such agencies, departments, entities, and individuals are not parties to this litigation, 
are not a part of the prosecution team as that term has been defined under well-established Second 
Circuit law, and are beyond the scope of this Office's disclosure obligations in this ca…

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