From: To: "Martin G. Weinberg" Cc: 'Mart Weinbe Subject: RE: Epstein - Legal Issues and Requests Date: Thu, 18 Jul 2019 02:56:37 +0000 Marty, I stand corrected regarding the timing of the recusal of SDFL from potential prosecution; I hadn't realized that (which may further show that any speculation about the genesis of our investigation being with SDFL is misguided). In any event, as we have represented to the Court, our investigation was initiated internally, and beyond that we're not prepared to make representations about internal communications or to otherwise characterize the investigation. With respect to the preservation of communications, my understanding is that the Department generally retains communications for some period of years, so while we don't believe there is any formal obligation to retain (or produce) such materials, I don't believe there would be any issue with retrieving communications should that be necessary. Regarding the privilege review, I expect that we will utilize (wall / taint individual or team to screen for privileged materials, as we do in the ordinary course where there are privilege concerns. If in addition to attorney names and law firms there are search terms, phrases, etc., that you want to identify for the review team, you should certainly feel free to do so and we can facilitate that. In the first instance I expect it will take some time to process the drives and devices to make their content reviewable on I web-based platform, so I don't believe anyone is yet reviewing those items (with the possible exception of I required preliminary screen of images for possible child pornography). In terms of the attorney and firm names, my thought was that it would be helpful for the case team to have them in case somehow some material wasn't screened, for easy recognition should we come across those names—and I've had those types of identifying information in other cases—but that certainly isn't I requirement if you