From: '
To: "Ruzumna, Daniel (x2034)"
Cc: "Weiner, Daniel H." , "Weinstein, Marc A."
"McDonnell, Hilary"
, "Norris, Tara (x2847)" >, "Lau,
Sean (x2742)"
Subject: Re: Epstein Estate
Date: Wed, 19 Apr 2023 23:42:11 +0000
Importance: Normal
Yes that works for me.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
From: Ruzumna, Daniel (x2034)
Sent: Wednesday, April 19, 2023 7:35:24 PM
To:
Cc: Weiner, Daniel H. < >; Weinstein, Marc A.
McDonnell, Hilary Norris, Tara
(x2847); Lau, Sean (x2742) < >
Subject: [EXTERNAL EMAIL] - Re: Epstein Estate
, are you free for a call at 3:00 p.m. tomorrow (Thursday)?
Sent from my iPad
On Apr 19, 2023, at 3:46 PM, > wrote:
'Caution: External Emaill
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 cell, , is the best way to
reach me.
Thanks and I look forward to speaking with you.
Special Agent
FBI New York Field Office
EFTA00039011
Child Exploitation/Human Trafficking
Desk:
From: Ruzumna, Daniel (x2034) ‹ >
Sent: Wednesday, April 19, 2023 3:22 PM
To:
Cc: Weiner, Daniel H. < >; Weinstein, Marc A.
.: >; McDonnell, Hilary < >; Norris, Tara
(x2847); Lau, Sean (x2742)
Subject: [EXTERNAL EMAIL] - Epstein Estate
Dear Special Agent
As you have apparently heard from AUSA =I, 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
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 iliad 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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should destroy this message and kindly notify the sender by reply email. Please advise
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Privileged/Confidential Information may be contained in this message. If you are not
the addressee indicated in this message (or responsible for delivery of the message to
such person), you may not copy or deliver this message to anyone. In such case, you
should destroy this message and kindly notify the sender by reply email. Please advise
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