{"efta_number": "EFTA00015838", "page_count": 2, "url": "https://epstein-data.com/EFTA00015838", "pdf_url": "https://epstein-data.com/pdf/EFTA00015838.pdf", "pages": [{"efta_number": "EFTA00015838", "page_number": 0, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of New York \nThe Si!lo J. Mollo Building \nOne Saint Andrew's Plaza \nNew York, New York 10007 \nJuly 23, 2020 \nVIA EMAIL \nMarc A. Weinstein, Esq. \nHughes Hubbard & Reed LLP \nOne Battery Park Plaza, 17th Floor \nNew York, NY 10004 \nAndrew E. Tomback, Esq. \nWhite & Case LLP \n1221 Avenue of the Americas \nNew York, NY 10020 \nRe: \nIn re SDNY Investigation \nDear Marc and Andrew: \nThe Government writes with regard to several matters relevant to the estate of Jeffrey \nEpstein, which we understand to be under the authority of your clients, Darren K. Indyke and \nRichard D. Kahn, as co-executors of the estate and co-trustees of the 1953 Trust Agreement. \nFirst, the 1953 Trust Agreement, produced on or about November 1, 2019, contains a \nprovision, at Section 2.5(B), that, among other things, and in sum and substance, states that to \nprovide for the continued maintenance and operations of the assets of the Trust Estate, the Trustees \nshall ensure that all employees of certain entities shall continue to be employed for a period of two \nyears following the death of Jeffrey Epstein. It further provides that, \"however, the Trustees shall \nhave the right [to] terminate the employment or the engagement of any such employees or service \nproviders if and at such times as the Trustees determine in their discretion that there is cause for \nsuch termination.\" Such cause includes, among other things, \"insubordination, breach of duty, \n[and] disloyalty.\" We request that the Trustees confirm their understanding that whatever the \nscope of that provision may be, it is not intended to and will not be used to suggest that any current \nor former employee who chooses to meet with or provide information to law enforcement as part \nof any ongoing investigation will be retaliated against in any way, or will lose any employment \nbenefit, or any other benefit, inheritance, or bequest, under the Trust Agreement. We also ask you \nto confirm that this provision has not been invoked for any such reason to date. \nSecond, as you are aware, Ghislaine Maxwell has been charged with crimes relating to the \nsexual abuse of minor girls and perjury in United States v. Maxwell, 20 Cr. 330 (AJN). Should \nshe be convicted, she will be subject to the mandatory victim restitution provisions associated with \ncertain of the criminal charges against her. Accordingly, we request that your clients confirm \nwhether they have, to date, made any distribution to Maxwell and, if not, further confirm that they \nEFTA00015838\n", "char_count": 2572}, {"efta_number": "EFTA00015838", "page_number": 1, "text_content": "July 23, 2020 \nPage 2 \nwill notify the Government in advance of any disbursement to her during the pendency of the \ncriminal case. \nFinally, in connection with the prosecution of Ms. Maxwell, the Government expects to \nproduce certain discovery materials to the defense, including certain materials obtained or seized \nin connection with the case against Jeffrey Epstein (the \"Seized Materials\"). These materials will \nbe produced subject to a Court-ordered protective order. In connection with the Government's \nanticipated production of the Seized Materials in the pending case, please advise whether the co-\nexecutors—in their capacity as representatives of the estate—take a position on whether, generally \nand at this time, any items within the Seized Materials remain subject to a potential claim of \nattorney-client privilege, or, in the alternative, whether the estate is prepared to waive any claim \nof privilege with respect to the Seized Materials, for purposes of the review and production of \ndiscovery in the charged case. \nVery truly yours, \nAU REY STRAUSS \nAc ng United States Attorney \nBy: \nAssistant United States Attorneys \nSouthern District of New York \nTel: \nEFTA00015839\n", "char_count": 1193}]}