EFTA00066050.pdf

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 13, 2020 BY USAfx Jason E. Foy Foy & Seplowitz LLC Re: United States v. Tova Noel No. 19 Cr. 830 Dear Counsel: This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure. This letter and the materials identified herein are subject to the protective order entered in this case on December 16, 2019, and have been designated as "Protected Materials" as defined in the order where noted below. Accordingly, the materials and information 'dentified herein shall not be disclosed to any third party or referenced publicly except as set forth in the protective order. Description Bates Numbers Classification Pursuant to Protective Order Emails from MCC employee email SDNY_00008724 — Confidential accounts' SDNY_00013257 FBI interview and investigation SDNY_00013258 — Confidential memoranda SDNY_00013324 Records of evidence seizures and SDNY_00013325 — Confidential submissions SDNY_00013424 1 The Bureau of Prisons ("BOP") provided to the Government the contents of 24 email accounts used by MCC employees, including an account used by each of the defendants. The list of email custodians is available upon request. In total, the Government was provided with approximately 45,000 emails and attachments within those accounts, which appear to have been copied on or around August 19, 2019. In a prior discovery production, the Government produced the entirety of the account used by your client to you. Through the manual review of emails in some (but not all) of the accounts, as well as the use of keyword searches across all accounts, the Government has identified the documents that it is producing now. The Government used the keywords "Epstein," "suicide," "institutional count," "rounds," "30 minute," and "count slip." While we believe the remaining materials are not discoverable under Rule 16, if you believe additional searches should be run, please let us know and we will consider your request. 06.20.2018 EFTA00066050  Page 2 SDNY_00013425 — Confidential Intake documents and receipts SDNY_00013429 Documents produced to the Government SDNY_00013430 — Confidential by the BOP as part of FOIA litigation SDNY_00017751 BOP memorandum re: Psychological SDNY_00017752 — Confidential Reconstruction of Jeffrey Epstein dated SDNY_00017767 September 17, 2019 MCC Watch Call for August 9, 2019 and SDNY_00017768 — Confidential August 10, 2019 SDNY_00017771 Anonymized index SDNY_00017772 Attorney's Eyes Only Additionally, the Government is producing he following materials only to your client: Description Bates Numbers Classification Pursuant to Protective Order SDNY_TN_00020858 — Background search results SDNYJN_00020910 BOP PIV Card, Sponsorship, and SDNY_TN_00020911 Adjudication Very truly yours, AUDREY STRAUSS Acting United States Attorney for the Southern District of New York By: Is/ Assistant United States Attorneys 06.20.2018 EFTA00066051