From: "I la ," a >
To: alYS)" <MIMMIE>, ' (USANYS)"
Cc ‹ > SI"
Subject: RE: draft response to Epstein defense preservation requests
Date: The, 06 Aug 2019 19:01:17 +0000
Attachments: 2019-08-05,_JE,_letter to_defense_re_preservation_requests.docx; 2019-07-
26,JE,_defense_letter requesting_preservation_and_production.pdf; 2019-08-
01,JE,_defense_supplemental_letter_requesting_preservation_and_production.pdf
This has been in the works for a little while, due to various other things that have come up in the interim, but we didn't
want it to get lost given the discovery motion schedule. The attached is based on our conversations with M, including
his email with suggested language for the prefatory language, and responds to the two attached defense letters. Happy to
discuss anytime and to incorporate comments and suggestions.
thanks,
M
Assistant U.S. Attorney
Southern District of New York
EFTA00016595