Akin Gump¶
STRAUSS HAUER & FELD LLP¶
PARVIN DAPHNE MOYNE¶
212.872.1076/fax: 212.872.1002¶
July 30, 2019¶
CONFIDENTIAL PURSUANT TO FED. R. CRIM. P. 6(e)¶
VIA ELECTRONIC DELIVERY¶
Assistant U.S. Attorney¶
U.S. Attorney’s Office¶
Southern District of New York¶
1 Saint Andrew’s Plaza¶
New York, NY 10007¶
Re: July 11, 2019 Subpoena to Deutsche Bank¶
Dear Mr. Rossmiller:¶
On behalf of our client, Deutsche Bank AG, New York Branch and its affiliates (“Deutsche Bank” or the “Bank”), we write in further response to the grand jury subpoena dated July 11, 2019 (the “Subpoena”). This letter and the enclosed document production represent the fourth submission in our client’s rolling response to the Subpoena.¶
Enclosed with this letter is an encrypted file labeled DB-SDNY-PROD004 containing documents and electronic communications responsive to items 2, 4, 5, 17, 18, 24, 26 and 27 of the Subpoena. Specifically, the enclosed documents—labeled DB-SDNY-0001289 through 0001710—include account opening documentation for certain accounts associated with Jeffrey Epstein. The decryption password for the production will be provided by separate email. As we have discussed, we continue to collect relevant information related to the Subpoena, and expect to make an additional production later this week.¶
Because we are producing these materials pursuant to a grand jury subpoena, it is our understanding that this production will be treated as confidential consistent with Federal Rule of Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and information, should you receive any request for disclosure of such information, pursuant to the Freedom of Information Act or otherwise, we ask to be notified in a timely fashion and given the opportunity to object to such disclosure. Further, should you determine to disclose any materials to any third party, we ask to be given reasonable advance notice in order to allow us to pursue any¶
EFTA00096339¶
July 30, 2019¶
Page 2¶
available remedies. In such event, we request that you contact the undersigned by email or telephone rather than rely on regular mail or facsimile transmission to provide such notice. Please advise us if you object to or disagree with the foregoing requests.¶
For the avoidance of doubt, no response or document provided in response to the Subpoena shall be construed as a waiver of any applicable privilege or doctrine available to Deutsche Bank under state or federal law. If it were found that production of any of the enclosed materials constitutes disclosure of otherwise privileged matters, such disclosure would be inadvertent. By the production of such documents, Deutsche Bank does not intend to waive and has not waived the attorney-client privilege or any other protections.¶
Please do not hesitate to contact us at or if you have any questions. We look forward to continuing to work with you in a cooperative manner.¶
Sincerely,¶
Parvin D. Moyne¶
James J. Benjamin, Jr.¶
Enclosures¶
EFTA00096340¶