EFTA00028149.pdf

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

From: Martin Weinberg -4 
To:" 
"I 
Subject: Re: Epstein - Legal Issues and Requests 
Date: Thu, 18 Jul 2019 11:41:15 +0000 
maybe we can find a few minutes after today's hearing to discuss further 
Thanks 
Marty 
Sent from my iPhone 
On Jul 17, 2019, at 10:56 PM, 
Marty, 
) 
wrote: 
I stand corrected regarding the timing of the recusal of SDFL from potential prosecution; I hadn't realized that (which 
may further show that any speculation about the genesis of our investigation being with SDFL is misguided). In any 
event, as we have represented to the Court, our investigation was initiated internally, and beyond that we're not 
prepared to make representations about internal communications or to otherwise characterize the investigation. With 
respect to the preservation of communications, my understanding is that the Department generally retains 
communications for some period of years, so while we don't believe there is any formal obligation to retain (or produce) 
such materials, I don't believe there would be any issue with retrieving communications should that be necessary. 
Regarding the privilege review, I expect that we will utilize a wall / taint individual or team to screen for privileged 
materials, as we do in the ordinary course where there are privilege concerns. If in addition to attorney names and law 
firms there are search terms, phrases, etc., that you want to identify for the review team, you should certainly feel free 
to do so and we can facilitate that. In the first instance I expect it will take some time to process the drives and devices 
to make their content reviewable on a web-based platform, so I don't believe anyone is yet reviewing those items (with 
the possible exception of a required preliminary screen of images for possible child pornography). In terms of the 
attorney and firm names, my thought was that it would be helpful for the case team to have them in case somehow 
some material wasn't screened, for easy recognition should we…
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