EFTA00024004.pdf

126 KB

Extraction Summary

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

Document Information

Type: Email chain / litigation hold notice
File Size: 126 KB
Summary

This document is an internal email chain from the U.S. Attorney's Office for the Southern District of New York (SDNY) dated August 12-15, 2019. It issues a formal litigation hold following Jeffrey Epstein's death at the Metropolitan Correctional Center (MCC), citing a preservation request from Epstein's lawyers regarding a potential wrongful death case. Staff are instructed to preserve all records, including emails, hard-copy notes, and text messages, related to Epstein's suicide, conditions of confinement, and a prior injury incident.

People (4)

Name Role Context
Jeffrey Epstein Subject
Deceased; subject of litigation hold regarding his death at MCC.
[Redacted] Deputy Chief, Civil Division, and Litigation Hold Coordinator
Sender of the formal litigation hold instructions (Aug 12, 5:13 PM).
[Redacted] Associate U.S. Attorney
Sender of the initial preservation instruction regarding suicide and conditions of confinement (Aug 12, 11:35 AM).
Epstein's Lawyers Legal Counsel
Made a preservation request on behalf of the family indicating a potential wrongful death case.

Organizations (5)

Name Type Context
U.S. Attorney's Office, S.D.N.Y.
Southern District of New York; Employer of the email senders.
MCC
Metropolitan Correctional Center; Location of Epstein's death.
EOUSA
Executive Office for United States Attorneys; Provided the litigation hold form.
OIG
Office of Inspector General; Mentioned in email subject line.
FBI
Federal Bureau of Investigation; Mentioned in email subject line.

Timeline (3 events)

2019-08-12
Issuance of formal litigation hold regarding Jeffrey Epstein.
New York
U.S. Attorney's Office S.D.N.Y.
Prior to 2019-08-12
Death of Jeffrey Epstein (Suicide mentioned).
MCC
Prior to 2019-08-12
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
Metropolitan Correctional Center; Place of death.

Relationships (1)

Jeffrey Epstein Legal Subject/Prosecution SDNY Staff
Staff identified as having done work on or supervised the Epstein matter.

Key Quotes (5)

"Epstein's lawyers have made on behalf of the family, which indicates a potential wrongful death case"
Source
EFTA00024004.pdf
Quote #1
"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."
Source
EFTA00024004.pdf
Quote #2
"Most particularly, please check to see if you have texted anything pertinent. If so let me know, one way or the other."
Source
EFTA00024004.pdf
Quote #3
"Please forward this to everyone who might have any documents relating to the Epstein suicide"
Source
EFTA00024004.pdf
Quote #4
"we are instituting a formal litigation hold in connection with Mr. Epstein's death at MCC."
Source
EFTA00024004.pdf
Quote #5

Full Extracted Text

Complete text extracted from the document (3,965 characters)

From: [REDACTED]
To: [REDACTED]
Cc: [REDACTED]
Subject: RE: Epstein OIG/FBI--Document Preservation
Date: Thu, 15 Aug 2019 21:33:52 +0000
Attachments: Jeffrey_Epstein_lit_hold_notice_form_08_12_2019.pdf
Dear all,
I'm sorry to pester but I think I haven't heard from you on this. Please complete and fill out the attached form by COB tomorrow, and return to me.
It takes very little time. And failing to take care of this can really come back to bite us.
Many thanks,
[REDACTED]
PS apologies if you provided this and I overlooked it.
From: [REDACTED]
Sent: Monday, August 12, 2019 5:13 PM
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.
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
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
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
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]

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