EFTA00027113.pdf

131 KB

Extraction Summary

4
People
6
Organizations
2
Locations
3
Events
1
Relationships
5
Quotes

Document Information

Type: Email chain / litigation hold notice
File Size: 131 KB
Summary

This document is an email chain from the U.S. Attorney's Office for the Southern District of New York (SDNY) dated August 12-14, 2019, initiating a formal litigation hold following Jeffrey Epstein's death. The correspondence directs staff to preserve all records related to Epstein, his suicide, his conditions of confinement at the MCC, and an earlier reported incident involving physical injuries. The emails reference a potential 'wrongful death case' indicated by Epstein's lawyers and provide specific instructions regarding the preservation of emails, hard-copy notes, and text messages.

People (4)

Name Role Context
Jeffrey Epstein Subject of Investigation/Deceased
Deceased at MCC; subject of document preservation regarding his death and earlier injuries.
Redacted Sender (Page 2) Deputy Chief, Civil Division, and Litigation Hold Coordinator
Issued the formal litigation hold notice at the U.S. Attorney's Office, S.D.N.Y.
Redacted Sender (Page 3) Associate U.S. Attorney
Issued initial instructions to preserve documents relating to Epstein suicide and conditions of confinement.
Epstein's Lawyers Legal Counsel
Made a preservation request on behalf of the family, indicating a potential wrongful death case.

Organizations (6)

Name Type Context
U.S. Attorney's Office, S.D.N.Y.
Southern District of New York; agency issuing the hold.
MCC
Metropolitan Correctional Center; location of Epstein's death.
OIG
Office of Inspector General; mentioned in subject line.
FBI
Federal Bureau of Investigation; mentioned in subject line.
EOUSA
Executive Office for United States Attorneys; provided the litigation hold form.
Civil Division
Department within SDNY.

Timeline (3 events)

2019-08-10
Epstein's death at MCC (implied date, referenced as past event)
MCC
2019-08-12
Institution of formal litigation hold
SDNY
SDNY Staff
Unknown (prior to death)
Earlier reported incident in which Epstein suffered physical injuries
MCC

Locations (2)

Location Context
Address of the U.S. Attorney's Office, S.D.N.Y.
MCC
Facility where Epstein died.

Relationships (1)

Epstein's lawyers made a preservation request on behalf of the family indicating a wrongful death case.

Key Quotes (5)

"Epstein's lawyers have made on behalf of the family, which indicates a potential wrongful death case"
Source
EFTA00027113.pdf
Quote #1
"preserve whatever you have about Mr. Epstein, not limited to his death and to the earlier reported incident in which he suffered physical injuries"
Source
EFTA00027113.pdf
Quote #2
"The USAO number for the portion of the case that I worked on is 2018R01618"
Source
EFTA00027113.pdf
Quote #3
"Please forward this to everyone who might have any documents relating to the Epstein suicide"
Source
EFTA00027113.pdf
Quote #4
"Most particularly, please check to see if you have texted anything pertinent."
Source
EFTA00027113.pdf
Quote #5

Full Extracted Text

Complete text extracted from the document (4,425 characters)

From: [REDACTED]
To: [REDACTED]
Subject: RE: Epstein OIG/FBI--Document Preservation
Date: Wed, 14 Aug 2019 20:35:46 +0000
Belatedly, thanks.
From: [REDACTED]
Sent: Tuesday, August 13, 2019 12:12 PM
To: [REDACTED]
Subject: RE: Epstein OIG/FBI--Document Preservation
[REDACTED]
Attached please find my completed form. The USAO number for the portion of the case that I worked on is 2018R01618.
Throughout my participation in this case, I have, as a practice, saved all Epstein-related emails that I received in my email archive in a folder entitled “Epstein”. Any emails that I sent regarding the case would be in the sent items folder in my email. I have not sent or received any substantive text messages regarding the case (any texts with other team members are purely logistical—e.g., setting up a time to meet or for a call).
Please let me know if you need anything else.
Thanks,
[REDACTED]
From: [REDACTED]
Sent: Monday, August 12, 2019 5:13 PM
[REDACTED]
Subject: RE: Epstein OIG/FBI--Document Preservation
Dear all,
As [REDACTED] explained, we are instituting a formal litigation hold in connection with Mr. Epstein’s death at MCC. You have been identified as having done work on or supervised the Epstein matter, and thus as possibly having responsive records. Please note and preserve whatever you have about Mr. Epstein, not limited to his death and to the earlier reported incident in which he suffered physical injuries. In addition, to the extent possible, please avoid altering any relevant records. If you need to use existing documents, please save what you’re working off of as a new document so that the version that now exists remains preserved and available.
EFTA00027113
I attach a formal litigation hold notice, which as required is on an EOUSA-provided form. Please review the notice, fill out the form to indicate whether and where you have responsive records, and sign and return it to me. In particular, be sure to let me know by USAO number if possible what records and share directories we have that are likely to include relevant information.
I prefer scanned and emailed return of the forms, but you can also use interoffice mail if you prefer.
Please let me know if you think other USAO personnel may have relevant documents or evidence.
And please let me know if you have questions or want to discuss.
Finally, I am copying [REDACTED] to inform him of the new litigation hold, and to ask him to ensure that all responsive information on our electronic record systems is preserved, including by suspending the routine maintenance email deletions for recipients of this email.
Many thanks,
[REDACTED]
Deputy Chief, Civil Division, and Litigation Hold Coordinator
U.S. Attorney’s Office, S.D.N.Y.
[REDACTED]
New York, NY 10007
[REDACTED]
From: [REDACTED]
Sent: Monday, August 12, 2019 4:46 PM
[REDACTED]
Subject: RE: Epstein OIG/FBI--Document Preservation
FYI, as a result of a preservation request Epstein’s lawyers have made on behalf of the family, which indicates a potential wrongful death case, you will shortly be receiving a formal litigation hold request from [REDACTED] our litigation hold coordinator.
From: [REDACTED]
Sent: Monday, August 12, 2019 11:43 AM
[REDACTED]
EFTA00027114
[REDACTED]
Subject: FW: Epstein OIG/FBI--Document Preservation
All – Please see below and follow [REDACTED] instructions. Additionally, if you believe there are others at SDNY to whom this email should be sent, please let me know immediately.
Thanks,
[REDACTED]
From: [REDACTED]
Sent: Monday, August 12, 2019 11:35 AM
[REDACTED]
Subject: Epstein OIG/FBI--Document Preservation
Please forward this to everyone who might have any documents relating to the Epstein suicide, and cc me:
Please make sure to preserve any documents you may have relating to Epstein’s conditions of confinement.
• Your emails will be adequately preserved, for present purposes, by the regular three-year backup. But let me know if you have any or not.
• If you have any hard-copy notes, please scan them and send them to me. If you have none, let me know that too.
• Most particularly, please check to see if you have texted anything pertinent. If so let me know, one way or the other. If you do have anything, we’ll figure out how to preserve that.
[REDACTED]
Associate U.S. Attorney
United States Attorney’s Office
Southern District of New York
[REDACTED]
New York, NY 10007
[REDACTED]
EFTA00027115

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