| From:                                          | (USANYS)"                                                                                                                                                                                                   |
|------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| To: "                                          | y                                                                                                                                                                                                           |
| Cc: '                                          | USANYS)"<br>11<br>11                                                                                                                                                                                        |
|                                                | Subject: Re: draft response to Epstein defense preservation requests                                                                                                                                        |
|                                                | Date: Fri, 09 Aug 2019 17:25:34 +0000                                                                                                                                                                       |
| Okay, thanks.                                  | when he's back on Monday.<br>is signed off but we may have to chat briefly with                                                                                                                             |
| Sent from my iPhone                            |                                                                                                                                                                                                             |
| On Aug 9, 2019, at 1:21 PM,                    | > wrote:<br>) <                                                                                                                                                                                             |
|                                                | I'm totally available to update it this afternoon if there are edits today, but realistically I don't think the defense can<br>make much more hay about having gotten a response on the 9th versus the 12th |
| From:                                          | (USANYS)<br>C                                                                                                                                                                                               |
| Sent: Friday, August 09, 2019 13:20<br>To:     |                                                                                                                                                                                                             |
| Cc:                                            | (USANYS)                                                                                                                                                                                                    |
|                                                | Subject: Re: draft response to Epstein defense preservation requests                                                                                                                                        |
|                                                | If we don't get this out until Monday is that a problem?                                                                                                                                                    |
| Sent from my iPhone                            |                                                                                                                                                                                                             |
| On Aug 8, 2019, at 5:56 PM,                    | wrote:<br>C                                                                                                                                                                                                 |
| can go to                                      | No problem, thanks, and the edits were all straightforward. Updated version attached, everything incorporated, and<br>— I'm out of commission the next couple hours but back after that.                    |
| thanks,                                        |                                                                                                                                                                                                             |
| From:                                          | (USANYS)                                                                                                                                                                                                    |
| Sent: Thursday, August 08, 2019 16:36<br>To:   | (USANYS)                                                                                                                                                                                                    |
| Cc:                                            | ) ca;<br>Subject: RE: draft response to Epstein defense preservation requests                                                                                                                               |
| to give                                        | Sorry for the delay. Combined edits from both of us, attached. Can you take a look and clean up — we would then like<br>at least the option of weighing in before we send to defense counsel.               |
| From:                                          |                                                                                                                                                                                                             |
| Sent: Thursday, August 8, 2019 11:44 AM<br>To: | (USANYS)<br>(USANYS)                                                                                                                                                                                        |

### Cc: Subject: RE: draft response to Epstein defense preservation requests

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.



Subject: RE: draft response to Epstein defense preservation requests

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 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

<2019-08-08, JE, letter to defense re preservation requests.docx>