court filing: Case#: 18-cr-00290-RMB Document#: 82 Filed: 07/18/19 Page 21 of 33

KIRKLAND & ELLIS LLP

ROTHSTEIN, DONATELLI, HUGHES, DAHLSTROM, SCHOENBURG & BIENVENU, LLP

Letter: 25-1

The letter, dated August 19, 2010, from the New Mexico Department of Public Safety, informs Jeffery E. Epstein that he is not required to register as a sex offender in New Mexico under state law for his 2008 Florida conviction, but may be required to register under federal law.

KIRKLAND & ELLIS LLP

425 FEDERAL SUPPLEMENT, 3d SERIES

306 425 FEDERAL SUPPLEMENT, 3d SERIES t In short, the issue now before the Court has arisen only because Donziger unjustifi- ably has refused to comply with his discov- ery obligations. Had he done so — i.e., had he produced responsive documents as to which there was no colorable claim of priv- ilege, submitted a privilege log as to re- sponsive documents as to which there was such a colorable claim, and submitted any disputes for judicial resolution - there would be no need to examine his ESI. But he has not. And the Court thus must take appropriate action. His arguments to the contrary are meritless. Conclusion For the foregoing reasons, the Court has entered the protocol for imaging and forensic examination of Donziger's elec- tronic devices and media. SO ORDERED. the six months between being served with the document requests and the Court's eventual ruling, on October I8, 2018, that Donziger had waived any applicable privi- lege. Third, Donziger disregards the

July 27, 2010