December 2. 2015 Via Federal Express Joe Wearmouth Legal Counsel's Office for the Department of Homeland Security Customs and Border Protection 9434 Viscount Blvd. Suite 200 El Paso, TX 79925 RE: Seizure and Search of Computer of Jeffrey Epstein Detention Notice and Custody Receipt No. 986291 Dear Mr. Wearmouth: This letter is authored to set forth the chronology of my efforts to seek the return of Jeffrey Epstein's computer which was seized, manually searched, and then detained for a further forensic search by the Customs Border Service at Albuquerque, New Mexico on November 24, 2015. On that date, Mr. Epstein flew from the U.S. Virgin Islands to Albuquerque in the early afternoon. Mr. Epstein's laptop computer was manually searched upon his entry. Mr. Epstein was informed that there was a file on the laptop that the Customs Border agents could not open. Mr. Epstein offered to try to open it himself. His offer was refused. Over his objection, the laptop was seized rather than being returned to him. When, at my direction, he asked what reasonable suspicion existed to warrant the seizure following the initial search, the Customs agents advised him that the seizure did not require reasonable suspicion and was part of their border search. Later that day, at 4:09 pm, I emailed Port Director Tracy S. Thorpe saying: Mr. Thorpe: I am sending you this email to memorialize our conversation of a few minutes ago and to respectfully object to any further search of my client Jeffrey Epstein's computer. You informed me that the computer was being sent to a centralized lab where the principal objective would be to search for child pornography. I want to clearly through this email reinforce Mr. Epstein's own objection to the seizure and retention of his computer by objecting to any further search of any kind for any EFTA00583991