Michael C. Miller New York. NY 10036 main anewsteptce.com By Electronic Mail Assistant United States Attorneys U.S. Attorney's Office for the Southern District of New York New York, New York 10007 Dear Steptoe STEPTOE S .161411SON II August 1, 2019 Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for Particulars Discovery and Brady Material We arc writing on behalf of Jeffrey Epstein regarding discovery in this case. In order to preserve Mr. Epstein's rights, arid to request additional information, we respectfully submit this formal request for discovery in this case pursuant to the Fourth, Filth and Sixth Amendments to the United States Constitution, Rules 12, 16, and 26.2 of the Federal Rules of Criminal Procedure, and the additional authority set forth below. This request encompasses not only documents and information in your possession, custody, or control, but also documents that the government has the legal right or practical ability to obtain. Such information includes but is not limited to information in the possession, custody, or control of any agency of the United States involved in any way in regulating or investigating the activities alleged in the Indictment or related transactions, including but not limited to the Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), and the Department of Homeland Security. In addition, such information includes information in EFTA00016136