Case File
efta-efta00039008DOJ Data Set 8CorrespondenceEFTA00039008
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Unknown
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DOJ Data Set 8
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efta-efta00039008
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From: "McDonnell, Hilary"
To:
Cc: "Weiner, Daniel H."
, "Weinstein, Marc A."
Subject: [EXTERNAL EMAIL] - RE: Epstein Estate
Date: Thu, 20 Apr 2023 19:51:27 +0000
Importance: Normal
Hi
It was nice speaking with you today. This email confirms our meeting on Monday, April 24 at 4:00 PM at Hughes
Hubbard. Our address is One Battery Park Plaza, New York, NY 10004.
Please let me know if anyone else will be joining you, so I can give their names to reception.
Best,
Hilary
Hilary McDonnell I Associate
She/Her
Hughes Hubbard & Reed LLP
One Batten/ Park Plan, 15th floor I New York I NY 10004-1482
Office
Cell
I bio
This message contains confidential information and 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. Email 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 not 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.
From:
Sent: Wednesday, April 19, 2023 7:42 PM
To: Ruzumna, Daniel (x2034)
Cc: Weiner, Daniel H. it
).; Weinstein, Marc A.
McDonnell, Hilary
(x2847) c>;
Lau, Sean (x2742) <
>
Subject: Re: Epstein Estate
; Norris, Tara
CAUTION: This email was sent by someone outside of the Firm.
Yes that works for me.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
From: Ruzumna, Daniel (x2034) <
Sent: Wednesday, April 19, 2023 7:35:24 PM
EFTA00039008
To:
Cc: Weiner, Daniel H. <
:,; Weinstein, Marc A.
4a;
McDonnell, Hilary
; Norris, Tam
(x2847)>;
Lau, Sean (x2742) <
>
Subject: [EXTERNAL EMAIL] - Re: Epstein Estate
are you free for a call at 3:00 p.m. tomorrow (Thursday)?
Sent from my iPad
On Apr 19, 2023, at 3:46 PM,
Caution: External Email!
Mr. Ruzumna,
> wrote:
Thank you for reaching out regarding the potential discovery of CSAM. I have some questions and I'd like to
chat by phone to discuss in further detail about next steps. Could you let me know a time that would work for
you? I'm available the rest of today and pretty open tomorrow. My cell,
, is the best way to
reach me.
Thanks and I look forward to speaking with you.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From: Ruzumna, Daniel (x2034)
Sent: Wednesday, April 19, 2023 3:22 PM
To:
Cc: Weiner, Daniel H. <
:,; Weinstein, Marc A.
in;
McDonnell, Hilary
(x2847)>;
Lau, Sean (x2742)
Subject: [EXTERNAL EMAIL] - Epstein Estate
; Norris, Tara
Dear Special Agent Eni
As you have apparently heard from AUSA
=I
we represent one of the two co-executors of the
Estate of Jeffrey Epstein. Hughes Hubbard & Reed represents the other. Recently, we have been responding to
requests/demands for documents in connection with a settlement that the Estate entered into with the
Government of the U.S. Virgin Islands and in response to subpoenas issued in litigations pending before the
U.S. District Court for the Southern District of New York. The Estate is not a party to the SDNY litigation.
As part of the Estate's document production obligations, we are reviewing approximately 1,100 videos that
EFTA00039009
were pulled from Epstein's emails and other files. Because of the potential existence of child pornography in
those videos, we worked out a protocol with the parties to whom we owed document production obligations,
and that protocol gave our reviewers protection and comfort in undertaking the review. The protocol was
submitted to the SDNY Court (Judge Jed Rakoff), who signed the "Order regarding Review of
Videomaterials." (Attached).
During the review yesterday, our co-counsel at Hughes Hubbard came across a video that may contain child
pornography. Apparently the relevant video was shared with Epstein by an individual who was convicted of a
child pornography-type offense and iliad
one or two topless women. In an abundance of caution, we
halted the review and reached out to
. Co-counsel at Hughes Hubbard (Dan Weiner and Hilary
McDonnell) can correct any misstatements in my description of the review since I heard the account
secondhand.
We would appreciate any guidance that you may have. We have been careful not to download videos to the
respective law firms' servers, but the videos were processed (without review) by a document collection vendor.
Thanks and we look forward to hearing from you.
Best,
Daniel Ruzumna
Daniel S. Ruzumna
Patterson Belknap Webb & Tyler LLP
1133 Avenue of the Americas
New York, New York 10036
Phone:
Fax:
Privileged/Confidential Information may be contained in this message. If you are not
the addressee indicated in this message (or responsible for delivery of the message to
such person), you may not copy or deliver this message to anyone. In such case, you
should destroy this message and kindly notify the sender by reply email. Please advise
immediately if you or your employer do not consent to receiving email messages of this
kind.
Privileged/Confidential Information may be contained in this message. If you are not
the addressee indicated in this message (or responsible for delivery of the message to
such person), you may not copy or deliver this message to anyone. In such case, you
should destroy this message and kindly notify the sender by reply email. Please advise
immediately if you or your employer do not consent to receiving email messages of this
kind.
EFTA00039010
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