Mict,el C. M '114 Avenue of the Amolcas New YryN NY IOW VA'AV steppe ...OW August 1, 2019 By Electronic Mail orneys U.S. Attorney's Office for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Steptoe STEPTOE S .1(11.01CON I I Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for Particulars Discovery and Brady Material Dear Ms. Comey, Ms. Moe, and Mr. Rossmiller: We arc writing on behalf of Jeffrey Epstein regarding discovery in this case. In order to preserve Mr. Epstein's rights, and to request additional information, we respectfully submit this formal request for discovery in this case pursuant to the Fourth, Fifth 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 EFTA00096232