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Correspondence · April 27, 2021

Prosecutors' emails coordinating court schedule in the Epstein FOIA litigation, April 2021

Email chain among prosecutors coordinating with the Times' counsel on court filings and ex parte submissions pending deferred-prosecution decisions affecting the Epstein FOIA.Machine-written summary

Subject: RE: Noel Status

Date: Tue, 27 Apr 2021 18:15:55 +0000

Yes – I’m free until 3. At my desk.

Could I give you a call on this? We think there’s an issue we didn’t discuss yesterday that could require some work from the Noel team this week.

Sounds fine to me and I think there is a good chance that by Friday we will have formally begun discussions with defense counsel, which you could note in the ex parte submission.

Sent from my iPhone

On Apr 26, 2021, at 8:35 PM,

Thanks for the call earlier today. I checked in with , and we think the best course here, instead of formally seeking an extension on Wednesday, is to submit a schedule to the Court on Friday (per the Court’s current order) that says we’ll submit everything for in camera review by May 14 (which we said we would do anyway if the DP doesn’t happen), but explain where things stand more specifically in an ex parte submission to the Court on the same day, flagging that we may seek a new schedule soon if Noel resolves. I’ll check in with the Times on Wednesday to get their sign off without telling them anything substantive (if they have a very adverse reaction we can go back to seeking a formal extension on Wednesday, but we think they’ll stay calm), and then we can let PAE know where things stand on the DP on Friday instead of Wednesday.

Let me know if you have any concerns or would like to discuss. Otherwise, I’ll check in on Wednesday to see where things stand.

EFTA00093512

Sorry to bug on this, but I think we’ll need to provide an update and/or seek more time from the Court by Wednesday at latest in the Epstein FOIA if we do not think there will be a determination on the Noel DP today or tomorrow, and I’ll have to check in with the Times in some form before we do that. Is it possible to provide any sense of the timing, or an update on where things stand in Noel?

Probably – but I will have a better sense tomorrow and will get back you you.

Hi all,

Would it be possible to provide an update on the status of the deferred prosecution agreements in Noel? Do we anticipate having a determination on those in the next few days? We may need to update the Court and/or check in with the Times about timing in the Epstein FOIA depending on where things stand on the DP front.

Thanks,

Assistant United States Attorney

Prosecutors' emails coordinating court schedule in the Epstein FOIA litigation, April 2021

Emails and letters

Email chain among prosecutors coordinating with the Times' counsel on court filings and ex parte submissions pending deferred-prosecution decisions affecting the Epstein FOIA.

DOJ Epstein Files, Data Set 9 · April 27, 2021

Subject: RE: Noel Status Date: Tue, 27 Apr 2021 18:15:55 +0000 Yes – I’m free until 3. At my desk. Could I give you a call on this? We think there’s an issue we didn’t discuss yesterday that could require some work from the Noel team this week. Sounds fine to me and I think there is a good chance that by Friday we will have formally begun discussions with defense counsel, which you could note in the ex parte submission. Sent from my iPhone On Apr 26, 2021, at 8:35 PM, Thanks for the call earlier today. I checked in with , and we think the best course here, instead of formally seeking an extens…