EPSTEIN
page 9 / 524 . OCR, unverified
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00021546
##############################
### SOURCE_FILE: root__EFTA00021547.txt ###
##############################
METADATA_SOURCE: .
METADATA_FILENAME: EFTA00021547.pdf
----------------------------------------
From: "
To:"
"
Cc: inn
>
<
IMIIW,
Subject: Ex Parte Submission: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Fri, 02 Aug 2019 22:16:46 +0000
Attachments: 2019-08-02, JE_ex-parte_discovery_letter.pdf
To the Chambers of Judge Berman:
The Government respectfully submits the attached ex parte letter. The letter is respectfully requested to be filed under
seal, because it discusses victim witnesses.
Sincerely,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00021547
##############################
### SOURCE_FILE: root__EFTA00021548.txt ###
##############################
METADATA_SOURCE: .
METADATA_FILENAME: EFTA00021548.pdf
----------------------------------------
From:
To:
Subject: Automatic reply: United States of America v. Jeffrey Epstein
Date: Tue, 06 Aug 2019 11:25:07 +0000
I will be out of the office on vacation until Monday, August 12th. Although I will hav
•
, my responses may be
dela ed. For ur ent matters, please contact the other AUSA(s) on the case, or AUSA
EFTA00021548
##############################
### SOURCE_FILE: root__EFTA00021549.txt ###
##############################
METADATA_SOURCE: .
METADATA_FILENAME: EFTA00021549.pdf
----------------------------------------
From:
To: "an.11IYS
c4
Cc:
Subject: RE: motions under seal?
Date: Fri, 02 Aug 2019 16:06:34 +0000
We will take care of that error and apologize for it.
I know that the statements are not marked as sensitive by the Government but for obvious reasons we don't want to file
those publically. Thus our request. If the government won't consent then, we will serve you via email and hold off filing it
until we can get the court to rule.
Garden City, NY 11530
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
From:
(USANYS) (mallto
Sent: Frida Au ust 02 2019 11:50 AM
To:
•
Cc
Subject: RE: motions under seal?
As you know, the protective order distinguishes between all discovery and that marked "sensitive;' and it is the sensitive
discovery that cannot be publicly filed.
statements to law enforcement do not fall into the sensitive
category, so they should be publicly filed. We'd ask that, consistent with the protective order, any sensitive discovery and
references to cooperators be redacted in your public filings. Along the same lines, we noticed that you publicly filed four
documents that were marked sensitive (Exhibits A through D to your cell site motion) in violation of the protective order.
We will be asking the Court to remove them from the docket and you will need to refile.
Assistant United States Attorney
From:
Sent: Friday, August 2, 201911:33 AM
To: MM,
(USANYS)
aN
>
Cc:
EFTA00021549
--- PAGE 2 ---
Subject: RE: motions under seal?
I don't think that will satisfy our concern about revealing the statements and certainly not something we can do today or
easily. Nor do I want the extra work.
Garden City, NY 11530
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
From: =I.,
(USANYS) [mailto:
Sent: Frida Au ust 02 2019 11:26 AM
To:
,
Cc:
Subject: RE: motions under seal?
It is a little difficult to know what needs to be sealed/redacted in the abstract. Out of an abundance of caution, can you
file the documents with any reference to evidence/discovery and cooperators redacted? We can then review the
unredacted version and discuss what, if anything, can be unredacted for the public version.
Assistant United States Attorney
From:
Sent: Friday, August 2, 2019 11:03 AM
To:
Cc:
(USANYS)
Subject: motions under seal?
Our motions will be ready to go out in a few hours., One is straight forward legal argument about the cell tower data,
which we don't have a problem filing. The other motion deals with the statements to the police and by necessity we