Subject: RE: draft response to Epstein defense preservation requests Date: Thu, 08 Aug 2019 16:08:06 +0000¶
No worries — there’s been a ton of stuff going on in the meantime!!¶
Sorry — back to you shortly.¶
Wanted to bump this from Tuesday, especially since I know you guys are out tomorrow — hopefully we can send it out today? Happy to incorporate any edits etc. Thanks.¶
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,¶
Assistant U.S. Attorney Southern District of New York¶