May 1, 2015

May 1, 2015 Via Certified Mail Dennis J. Argall FOIPA Public Liaison Officer Federal Bureau of Investigation Record/Information Dissemination Section Winchester, VA 22602-4483 RE: Request No 1203982-001 (Jeffrey Epstein) Dear Mr. Argall: In November of 2012 I applied under the FOIA for relevant FBI files relating to Jeffrey Epstein. The FBI declined to produce any such files. On April 25, 2013, following an administrative appeal that resulted in a finding that 5 U.S.C. § 552(b)(7)(A) was inapplicable as a basis to withhold all records of past investigations, the FBI reopened the above-numbered FOIA request and stated that it had started its processing and searching for responsive records. On June 24, 2013, on Mr. Epstein's behalf, the FBI was informed that we would pay the costs of copying. On August 8, 2014, I was informed that the FBI had sent the first batch of processed pages to its Miami field office to authorize their release and on August 18, 2014, you informed me that the FBI had processed the first 500 pages, that 372 pages would be released, and that each successive 500 page batch would be processed on an average of every 60 days. On August 29, 2014, you informed me that you were in error on August 18, 2014 and that the Miami FBI had not approved the initial release. On September 16, 2014, you informed me that the Miami FBI had sent the first batch of processed documents to the United States Attorney's Office. We spoke again on October 16, 2014 when you informed me that the interim release had not yet cleared and on October 21, 2014, you informed me that the delay was due to the FBI's decision to conduct a second review to determine the necessity of further redactions, a review that you predicted would take another 30 to 60 days. Finally, on December 16, 2014, the first batch of redacted reports were received with the expectation that every 60 (or maximum 90 days) there would be further productions i.e. we had a right to expect that no later than March 16, 2015 there would be a futher production. When we spoke again, you said the production was schedule for EFTA01144411 April. We spoke today and you said that the analysis was complete by FBI FOIA but it was in review in South Florida and that you could not even promise that the review would result in the production in May. To have received just 372 pages of a 12,000 or so page file in the two year period after the FBI was directed to process the FOR request (and 2 'A years from the FOIA request in November 2012), and we are approaching the 5'h month after the intial production without a second batch. At 500 pages each 5 months (rather than 2 or 3), the 12,000 page production will, at the current pace, not be complete for 10 years (24 500 page productions taking 5 months for each production) i.e. until December 2024. I think you would agree that the past and projected delays are not consistent at all with the purposes of FOIA or the expectation of citizens seeking redacted productions. I would request (a) that you provide me with a definite date when the processing and review of the second batch of documents will be concluded and then released to me on Mr. Epstein's behalf, and (b) that you agree to expedite the processing of successive batches of 500 pages so that the pattern of past delays do not result in an overall delay of the FOIA required production. I make these requests without waiving Mr. Epstein's rights to pursue other remedies to assure that the FBI has made timely responses to his FOIA requests. Yours truly, Martin G. Weinberg cc: David Hardy, Section Chief EFTA01144412