EFTA00020773.pdf
65.3 KB
Extraction Summary
5
People
2
Organizations
2
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Email
File Size:
65.3 KB
Summary
An email from an Assistant U.S. Attorney (SDNY) to Marc Weinstein and Andrew Tomback regarding the investigation into the Epstein estate. The email outlines protocols for producing evidence found at the New York residence, specifically photographs and discs, and raises the issue of whether the estate will waive attorney-client privilege for the purpose of the United States v. Maxwell case.
People (5)
| Name | Role | Context |
|---|---|---|
| Marc A. Weinstein | Recipient |
Addressed as 'Marc', likely representing the estate or related parties.
|
| Andrew Tomback | Recipient |
Addressed as 'Andy', likely representing the estate or related parties.
|
| Jeffrey Epstein | Deceased Subject |
Mentioned regarding his estate and attorney-client privilege.
|
| Ghislaine Maxwell | Defendant |
Mentioned in case reference 'United States v. Maxwell'.
|
| Redacted Sender | Assistant U.S. Attorney |
Sender of the email from SDNY.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Southern District of New York (SDNY) |
Sender's organization.
|
|
| U.S. Government |
Referred to as 'the Government' seeking position on privilege.
|
Timeline (1 events)
2020-07-16
Conversation between SDNY and recipients regarding estate materials.
Phone call (implied)
Locations (2)
| Location | Context |
|---|---|
|
Property where materials (photographs) were identified.
|
|
|
Jurisdiction of the sender.
|
Relationships (2)
Weinstein is addressed regarding the Epstein estate and privilege waivers.
Tomback is addressed regarding the Epstein estate and privilege waivers.
Key Quotes (3)
"we agree that your plan with respect to the materials you have identified in the New York residence makes sense, i.e., to have the photographs scanned and then produced to us in electronic format."Source
EFTA00020773.pdf
Quote #1
"Regarding loose, unlabeled discs, we are not requesting their production at this time."Source
EFTA00020773.pdf
Quote #2
"seek a formal position on whether the estate intends to waive, on behalf of Jeffrey Epstein, any attorney-client privilege for purposes of discovery review and production in connection with United States v. Maxwell, 20 Cr. 330 (AJN)."Source
EFTA00020773.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,851 characters)
From: [Redacted]" <[Redacted]>
To: "Weinstein, Marc A." <[Redacted]>, Andrew Tomback
<[Redacted]>
Cc: "[Redacted])" <[Redacted]>, "[Redacted])"
<[Redacted]>
Subject: RE: SDNY investigation, re: estate
Date: Fri, 17 Jul 2020 22:26:45 +0000
To: "Weinstein, Marc A." <[Redacted]>, Andrew Tomback
<[Redacted]>
Cc: "[Redacted])" <[Redacted]>, "[Redacted])"
<[Redacted]>
Subject: RE: SDNY investigation, re: estate
Date: Fri, 17 Jul 2020 22:26:45 +0000
Marc, Andy,
Following up on our conversation yesterday, we wanted to briefly confirm a few things we discussed and also respond to
your question. To reiterate, we agree that your plan with respect to the materials you have identified in the New York
residence makes sense, i.e., to have the photographs scanned and then produced to us in electronic format. To the extent
we need any originals of materials initially produced electronically in that fashion, we will of course follow up.
Additionally, and related, to the extent there are materials that are more conducive to being produced in their original
format, such as the photo book you mentioned specifically, we can receive those in hard copy. As a general matter, I think
those would only be materials that cannot be individually scanned or copied without removing them from some relevant
contextual placement or arrangement; that said, if you or your vendor believes individual items require a judgment call,
please feel free to check in with us on any specific questions.
your question. To reiterate, we agree that your plan with respect to the materials you have identified in the New York
residence makes sense, i.e., to have the photographs scanned and then produced to us in electronic format. To the extent
we need any originals of materials initially produced electronically in that fashion, we will of course follow up.
Additionally, and related, to the extent there are materials that are more conducive to being produced in their original
format, such as the photo book you mentioned specifically, we can receive those in hard copy. As a general matter, I think
those would only be materials that cannot be individually scanned or copied without removing them from some relevant
contextual placement or arrangement; that said, if you or your vendor believes individual items require a judgment call,
please feel free to check in with us on any specific questions.
Regarding loose, unlabeled discs, we are not requesting their production at this time. If there are discs that are labeled in
some way that indicates or suggests they contain photos in particular, please let us know, as we likely would request
production of those items. For discs that do not fit that description, we assume those will be retained by the estate in any
event, but please let us know if that is incorrect, or if at some subsequent point that status is expected to change.
some way that indicates or suggests they contain photos in particular, please let us know, as we likely would request
production of those items. For discs that do not fit that description, we assume those will be retained by the estate in any
event, but please let us know if that is incorrect, or if at some subsequent point that status is expected to change.
Finally, I know we raised the issue of privilege for the first time on our call, so I just want to reiterate that the Government
is in no way requesting any waiver, but rather advising you and your clients that we may at some point in the coming
weeks seek a formal position on whether the estate intends to waive, on behalf of Jeffrey Epstein, any attorney-client
privilege for purposes of discovery review and production in connection with United States v. Maxwell, 20 Cr. 330 (AJN).
Prior to the Government seeking and obtaining the estate’s position on such a question, we will assume that the privilege
remains applicable and in effect, and we will proceed with our usual practices in review and production of discovery in
that case, including producing materials obtained in connection with the Epstein investigation following any necessary
taint / privilege review.
is in no way requesting any waiver, but rather advising you and your clients that we may at some point in the coming
weeks seek a formal position on whether the estate intends to waive, on behalf of Jeffrey Epstein, any attorney-client
privilege for purposes of discovery review and production in connection with United States v. Maxwell, 20 Cr. 330 (AJN).
Prior to the Government seeking and obtaining the estate’s position on such a question, we will assume that the privilege
remains applicable and in effect, and we will proceed with our usual practices in review and production of discovery in
that case, including producing materials obtained in connection with the Epstein investigation following any necessary
taint / privilege review.
Thank you again for speaking with us, and we will continue to be in touch with any other relevant issues or questions.
best,
[Redacted]
[Redacted]
[Redacted]
Assistant U.S. Attorney
Southern District of New York
EFTA00020773
Assistant U.S. Attorney
Southern District of New York
EFTA00020773
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