U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 23, 2020 VIA EMAIL Marc A. Weinstein, Esq. Hughes Hubbard & Reed LLP One Battery Park Plaza, 17th Floor New York, NY 10004 Andrew E. Tomback, Esq. White & Case LLP 1221 Avenue of the Americas New York, NY 10020 Re: In re SDNY Investigation Dear Marc and Andrew: The Government writes with regard to several matters relevant to the estate of Jeffrey Epstein, which we understand to be under the authority of your clients, Darren K. Indyke and Richard D. Kahn, as co-executors of the estate and co-trustees of the 1953 Trust Agreement. First, the 1953 Trust Agreement, produced on or about November 1, 2019, contains a provision, at Section 2.5(B), that, among other things, and in sum and substance, states that to provide for the continued maintenance and operations of the assets of the Trust Estate, the Trustees shall ensure that all employees of certain entities shall continue to be employed for a period of two years following the death of Jeffrey Epstein. It further provides that, "however, the Trustees shall have the right [to] terminate the employment or the engagement of any such employees or service providers if and at such times as the Trustees determine in their discretion that there is cause for such termination." Such cause includes, among other things, "insubordination, breach of duty, [and] disloyalty." We request that the Trustees confirm their understanding that whatever the scope of that provision may be, it is not intended to and will not be used to suggest that any current or former employee who chooses to meet with or provide information to law enforcement as part of any ongoing investigation will be retaliated against in any way, or will lose any employment benefit, or any other benefit, inheritance, or bequest, under the Trust Agreement. We also ask you to conf