EFTA00104910.pdf

From: "Weinstein. Marc A." To: Cc: "Tomback, Andrew" Subject: Grand Jury subpoena response Date: Fri, 01 Nov 2019 21:15:23 +0000 Attachments: 1953_Trust_executed.pdf; 2019- 2_Amended_and_Restated_Jeffrey_E._Epstein_2019_Trust.pdf; 2019- 1 Jeffrey_E._Epstein_2019_Trust_.pdf This responds to the October 18, 2019 grand jury subpoenas to the executors of the estate of Jeffrey Epstein. Each subpoena requests the following: I. The 1953 Trust agreement and any trust documents referenced or referred to within The 1953 Trust (the "Trust Documents"); 2. Any drafts or notes of the Trust Documents; and 3. Any communications relating to the Trust Documents. Attached in response to request 1 are "The 1953 Trust" (dated August 8, 2019), the "Amended and Restated Jeffrey E. Epstein 2019 Trust" (dated February 4, 2019) and the "Jeffrey E. Epstein 2019 Trust" (dated January 18, 2019) (the latter two of which are referenced in the 1953 Trust), bearing bates numbers GJ_00001 through GJ_00102. As discussed on our call, with respect to requests 2 and 3, we believe that most, if not all, of the communications relating to the formation of the Trust Documents are privileged. In addition, the scope of requests 2 and 3 is quite broad, and the government, rather than the Executors, is in possession and control of some of the potential sources of such information (i.e., Mr. Epstein's computers). We therefore agreed to defer production of any non- privileged documents responsive to those requests and further agreed to revisit what (if anything) the government further sought with respect to requests 2 and 3 until after the government has reviewed the Trust Documents. Regards, Marc Marc A. Weinstein I Partner Co-Chatr, While Collar Defense Hughes Hubbard & Reed LLP One Battery Park Plaza, 17th floor !New York. NY 10004-1482 Office +1 (212) 837-64601 Cell +1 (646) 537-57501 Fax +1 (212) 299-6460 This message contains confidential information arid is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e- mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does riot accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version. EFTA00104910