EFTA00028149

Document Text

From: Martin Weinberg -4 To:" "I Subject: Re: Epstein - Legal Issues and Requests Date: Thu, 18 Jul 2019 11:41:15 +0000 maybe we can find a few minutes after today's hearing to discuss further Thanks Marty Sent from my iPhone On Jul 17, 2019, at 10:56 PM, Marty, ) wrote: 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 a 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 th