RE: Epstein Estate

Dear Special Agent

As you have apparently heard from AUSA , we represent one of the two co-executors of the Estate of Jeffrey Epstein. Hughes Hubbard & Reed represents the other. Recently, we have been responding to

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requests/demands for documents in connection with a settlement that the Estate entered into with the Government of the U.S. Virgin Islands and in response to subpoenas issued in litigations pending before the U.S. District Court for the Southern District of New York. The Estate is not a party to the SDNY litigation.

As part of the Estate's document production obligations, we are reviewing approximately 1,100 videos that were pulled from Epstein's emails and other files. Because of the potential existence of child pornography in those videos, we worked out a protocol with the parties to whom we owed document production obligations, and that protocol gave our reviewers protection and comfort in undertaking the review. The protocol was submitted to the SDNY Court (Judge Jed Rakoff), who signed the "Order regarding Review of Videomaterials." (Attached).

During the review yesterday, our co-counsel at Hughes Hubbard came across a video that may contain child pornography. Apparently the relevant video was shared with Epstein by an individual who was convicted of a child pornography-type offense and it ac ll one or two topless women. In an abundance of caution, we halted the review and reached out to Co-counsel at Hughes Hubbard (Dan Weiner and Hilary McDonnell) can correct any misstatements in my description of the review since I heard the account secondhand.

We would appreciate any guidance that you may have. We have been careful not to download videos to the respective law firms' servers, but the videos were processed (without review) by a document collection vendor.

Thanks and we look forward to hearing from you.

Best,
Daniel Ruzumna
Daniel S. Ruzumna
Patterson Belknap Webb & Tyler LLP
1133 Avenue of the Americas
New York, New York 10036

Phone

Fax:

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Mr. Ruzumna,

Thank you for reaching out regarding the potential discovery of CSAM. I have some questions and I'd like to chat by phone to discuss in further detail about next steps. Could you let me know a time that would work for you? I'm available the rest of today and pretty open tomorrow. My cells is the best way to reach me.

Thanks and I look forward to speaking with you.

Special Agent [Redacted]
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk: [Redacted]

=are you free for a call at 3:00 p.m. tomorrow (Thursday)?

Sent from my iPad

Yes that works for me.

Special Agent

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FBI New York Field Office

Child Exploitation/Human Trafficking

Hi

It was nice speaking with you today. This email confirms our meeting on Monday, April 24 at 4:00 PM at Hughes Hubbard. Our address is One Battery Park Plaza, New York, NY 10004.

Please let me know if anyone else will be joining you, so I can give their names to reception.

Best,
Hilary

Hilary McDonnell | Associate
She/Her

Hughes Hubbard & Reed LLP
One Battery Park Plaza 15th floor | New York NY 10004-1482
Office
m❘ bio

:, message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message. which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

Hilary,
It was nice speaking with you as well. My partner, Detective will be joining me.

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We will see you on Monday.

Thanks.

Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk

I hope you are well. We have completed our review of videos from the Epstein Estate and flagged some additional videos that could be potential CSAM. I know that you are visiting Patterson Belknap next Tuesday. Are you available to come Hughes Hubbard's office again next Wednesday or Thursday?

Thanks very much,
Hilary

Hilary McDonnell | Associate
She/Her

Hughes Hubbard & Reed LLP

One Battery Park Plaza, 15th floor | New York | NY 10004-1482

This message contains confidential information and is intended only (or the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. Email transmission cannot be guaranteed to be secure or error-free as information could be intercepted. corrupted, lost. destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message. which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.