RE: Epstein Estate Touhy Requests

Please find attached correspondence for your attention. We intend to serve these requests separately on the MCC and the FBI, but are providing you with copies of all three letters as a courtesy. If you are willing to accept service for all three, we will not otherwise serve them.

Mike

Michael C. Miller

Partner

Steptoe

Steptoe & Johnson LLP

www.steptoe.com

This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you are not the intended recipient, please do not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message.

<8.20.19 Epstein Letter to SDNY-c2.pdf>

<8.20.19 Epstein Letter to MCC-c2.pdf>

<8.20.19 Epstein Letter to FBI-c2.pdf>

EFTA00078492

We received the attached document requests from Epstein's lawyers. Based on our previous conversations about this, it sounds like these should be routed to the civil division, but I wasn't sure who in particular to contact, or whether you would prefer to make the referral.

Thanks,

We continue to get document requests from Epstein's defense team related to his death. How would you like us to handle? Should we refer them to someone at Civ Div? Ignore? There is, as best I can tell, no right to anything given

EFTA00078491

that there is no "proceeding" pending related to the death but, in any event, our crim AUSAs are presumably not the appropriate point of contact.

has been assigned. Thanks.

Jeff

Thanks. Would you open a new matter on this, it may end up being substantial.

All,

I will reach out to on this, including for the letters from Steptoe.

the matter number here is 2019V01791.

Thanks,

Thanks,
In the interim, I would propose having the crim team response as follows:

"Counsel - We are in receipt of your requests which do not appear to arise under Rule 16 or any other production obligation associated with the criminal proceeding. Moreover, as you are aware, the Government has submitted a proposed order of nolle prosequi which, once entered, will terminate that proceeding. We have forwarded your correspondence to the Civil Division which will handle any further correspondence regarding these matters." We can also have the point them directly to | if that makes sense.

EFTA00078490

De-looping and

Maybe:

Your August 20, 2019, requests for disclosure under the Department of Justice's Touhy regulations will be handled by AUSA of our Civil Division, copied here. Please note that no further discovery will occur in the context of the criminal case of US v. Epstein, 19 Cr. 0490.

Separately, will we be clawing back discovery already made in the Epstein case?

We have not, but we've discussed doing so. Under the protective order, we are entitled to.

Let me know what you end up deciding. Tx.