EFTA00101163.pdf

Akin Gump STRAUSS HAUER & FELD LLP PARVIN DAPHNE MOYNE 212.872.1076/1ax: 212.872.1002 pmoyneeakingumo.com July 19, 2019 CONFIDENTIAL PURSUANT TO FED. R. CRIM. P. 6(e) VIA ELECTRONIC DELIVERY Assistant U.S. Attorney U.S. Attorney's Office Southern District of New York 1 Saint Andrew's Plaza New York, NY 10007 Re: July 11, 2019 Subpoena to Deutsche Bank Dear Mr. Rossmiller: On behalf of our client, Deutsche Bank AG, New York Branch and its affiliates ("Deutsche Bank" or the "Bank"), we write in further response to the grand jury subpoena dated July 11, 2019 (the "Subpoena"). As discussed, this letter and the enclosed document production represent the third submission in our client's rolling response to the Subpoena. Enclosed with this letter is an encrypted file labeled DB-SDNY-PROD003 containing documents and electronic communications responsive to items 1 through 5, 7, 17, IS, 23, 24 and 27 of the Subpoena. Specifically: • Included at DB-SDNY-0000479 through 0000504 are additional KYC records related to Epstein-affiliated accounts; and • Included at DB-SDNY-0000505 through 0001288 are documents related to Epstein- affiliated accounts, including account opening documentation, signature cards, ID copies, transaction records, and ISDA agreements. In ►ight of the time sensitive nature of your request, we are providing these materials in PDF format. As we have discussed, we would intend to follow up with a more formal submission of these and other preliminary materials submitted in response to the Subpoena. The decryption password for the production will be provided by email. EFTA00101163 July 19, 2019 Page 2 Because we are producing these materials pursuant to a grand jury subpoena, it is our understanding that this production will be treated as confidential consistent with Federal Rule of Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and information, should you receive any request for disclosure of such information, pursuant to the Freedom of Information Act or otherwise, we ask to be notified in a timely fashion and given the opportunity to object to such disclosure. Further, should you determine to disclose any materials to any third party, we ask to be given reasonable advance notice in order to allow us to pursue any available remedies. In such event, we request that you contact the undersigned by email or telephone rather than rely on regular mail or facsimile transmission to provide such notice. Please advise us if you object to or disagree with the foregoing requests. For the avoidance of doubt, no response or document provided in response to the Subpoena shall be construed as a waiver of any applicable privilege or doctrine available to Deutsche Bank under state or federal law. If it were found that production of any of the enclosed materials constitutes disclosure of otherwise privileged matters, such disclosure would be inadvertent. By the production of such documents, Deutsche Bank does not intend to waive and has not waived the attorney-client privilege or any other protections. Please do not hesitate to contact us at if you have any questions. We look forward to continuing to work with you in a cooperative manner. Parvin D. Moyne James J. Benjamin, Jr. Enclosures EFTA00101164