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for the preservation of any and all documents, records, reports, videos, pictures, physical evidence,
electronic communication data, tape recordings, logs, notes, papers, emails and any and all other forms
of information that would be in the possession of the MCC, its Warden, their legal counsel, the USMS,
the FBI, the Inspector General, the USAO for the SDNY or any other federal or relevant state or city
agency that relate to Jeffrey Epstein's imprisonment/detention since July 6, 2019 and that relate
particularly but not exclusively to the July 23, 2019 occurrence which was investigated as an attempted
suicide by the MCC and the events relating to his death on August 10, 2019. The request encompasses
but is not limited to any videos of the 9th floor area in the proximity of his cell during the evening of
August 9 through the time Mr. Epstein was taken out of his cell for the last time on August 10, 2019, or
videos of the cell itself during that time period, records of the identities of (i.e. MCC employees or
independent contractors or anyone else) who were on duty from midnight through 8 AM on August 10,
2019 or otherwise had access to the 9th floor unit where Mr. Epstein was incarcerated during this time
period, records of any observations of Mr. Epstein on August 10, 2019, any and all photographs of
Mr. Epstein or his cell taken on August 10, 2019, any and all electronic or tape recordings or records of
any internal communications within the MCC or any external communciations by MCC staff on August 9
and August 10, 2019, records of any mental health interviews or assessements of Mr. Epstein at
anytime during his detention, records of any decision to put him on or take Mr Epstein off suicide
watch, photos of his cell taken on or before August 9 or on or after August 10, 2019, memoranda of
interviews with any prisoners who were in Mr. Epstein's SHU unit on the 9th floor on or about July 23
or on August 9-10, 2019 relating to Mr. Epstein, the same request for interview memoranda of any MCC
employee or independent contractor or any other person in the MCC midnight-8 AM August 10, 2019,
any and all medical and EMS and hospital records from July 23 and/or August 10, 2019, and the future
pathology and toxicology and medical examiner's reports. Additionally, we would request the
preservation of any note or notes found in Mr. Epstein's cell on August 10, 2019, any ligature or other
physical evidence related to his cause of death, any bedding, any medication or vitamins, any log
showing who entered or were present in the MCC for the 12 hour period before 6:30 AM on August 10,
2019, as well as a list of inmates who were in Mr. Epstein's unit during the evening of August 9 and the
morning of August 10, 2019. We would in addition to the preservation request ask for the production
of all of the above. We would receive and retain in subject any information received in response to this
request subject to the terms and conditions of our Protective Order. In short, the family requests a
preservation and production of any and all records and documents relevant to his detention,
treatment, and death. I will send an identical request to [REDACTED] (as well as to [REDACTED]
personal counsel
Thank you for your consideration of these requests and your ongoing assistance
[REDACTED]

[REDACTED], Esq.
20 Park Plaza
Suite 1000
Boston, MA 02116
(617) 227-[REDACTED] - Office
(617) 901-[REDACTED] - Cell

[REDACTED] Esq.
20 Park Plaza
Suite 1000
Boston, MA 02116
(617) 227 [REDACTED] Office
(617) 901 [REDACTED] Cell
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