EFTA00016132

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MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW EMAII ADDRESSES BOSTON, MASSACHUSETTS 02116 FAX NICY July 26, 2019 Electronic Mail Assistant United States Attorneys U.S. Attorney's Office for the Southern District of New York New York, New York 10007 Re: United States v. Jeffrey Epstein, No. I 9-cr-00490 Defendant's First Request for Discovery Dear We represent Jeffrey Epstein in the above -referenced matter. We write to request the preservation and production of several important categories of documents. The following request and future requests' encompass not only documents and information in your office's 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, and 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 Child Exploitation and Obscenity Section, other offices of "Main Justice," the Federal Bureau of Investigation and all United States Attorney's Offices), the Securities and Exchange Commission, and the Department of Homeland Security. In addition, such information includes information in the possession, custody, and control of any local, state, or I All of these requests are/will b