Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF¶
Date: Fri, 24 Jul 2020 23:12:26 +0000¶
Thanks very much, and this generally looks fine to me. Might it be possible to add the following before the “Please contact me” sentence:¶
And the materials that emailed at 3:06 this afternoon all look good to me, so everything should be ready to go once the letter is approved. If you wouldn’t mind letting us know when you send everything out, that would be great.¶
Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF¶
Thanks for adding on this for the redactions, . Please find attached the letter to go out with the docs. (Note that my supervisor is still looking at it.) Please let me know if you have any edits or concerns. I think last time we ran everything past before it went out to the door. I planned to do that again, once the packet is ready to go. Thanks.¶
Subject: FW: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF¶
We have a redaction project we need help with, please – could you please take a look at the attachments included in the attached email? As described a couple emails below, they consist mostly of FedEx invoices, plus another few docs, that¶
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need to be redacted for production based on a Touhy request. Would you be able to help out with that?¶
If you could please send the redacted versions to us and to （copied here), we’ll do a final review for production and then be all set.¶
Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF¶
Thanks, . I should be able to turn a letter on this quickly. I think if it would be easy to have a paralegal do the redactions, that would be helpful and probably speed things up (it doesn’t matter which side that happens on). Let me know if that would work, or I can also ask a paralegal on my side.¶
Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF¶
This is obviously now very belated, but as previewed earlier today, I’ve completed a review of our materials for documents responsive to this Touhy request. Unfortunately, and as discussed, many of the documents we have that would be otherwise responsive were obtained pursuant to grand jury subpoenas we issued. Based on your discussion with I am not conveying those materials to you for review. What we’re left with are the following, which are attached:¶
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4 documents relating to FedEx invoices, obtained from the FOIA office in connection with its review of the Florida investigation file (note that there are actually 12 such documents in all, but the remainder are duplicative; please let us know if we should produce all 12 anyway, otherwise I’ve just given you the 4);
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2 documents obtained through electronic search warrants; and
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1 document, a photo, obtained through a physical search of Epstein’s residence.
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Given the small volume, if we can get it out quickly that would be fantastic, and please let us know if it would be helpful to have a paralegal do the redactions (not sure if you have to do that on your side, or if we can assist).¶
Please let us know if any questions at all, and thanks as always.¶
Subject: FW: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF¶
Importance: High¶
Hi all,¶
Will you be able to gather the responsive documents for Glassman’s request, as with the request from Kaplan? Except for Item 8, this request seems fairly contained—and they have expressly cabined their request to not seek documents that would interfere with ongoing proceedings. Please let me know if we need to discuss. Otherwise, I’ll draft a letter once we have the docs gathered (happy to do redactions again if helpful).¶
Thanks,¶
Subject: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF¶
Please see the attached letter of today’s date. A copy will also be sent via Fedex. Thank you.¶
Robert Glassman¶
Robert Glassman, Esq.¶
Panish Shea & Boyle LLP¶
11111 Santa Monica Boulevard, Suite 700¶
Los Angeles, CA 90025¶
Web: www.psblaw.com¶
CONFIDENTIALITY NOTICE:¶
This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution¶
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or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.¶
If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case.¶
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This looks great, thanks and thanks especially for conforming it to what we posted in the Epstein case last year. I just made a few very small changes, and we should be good to go. Let’s please post the following:¶
July 16, 2019 update:¶
On July 14, 2019, an arraignment, initial conference, and bail hearing was held in the case of United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). The defendant entered a plea of not guilty to the Superseding Indictment. The court announced its ruling that the defendant will be incarcerated pending trial. The Court scheduled discovery and motion deadlines for counsel as well as a trial date of July 12, 2021, before the Honorable Alison J. Nathan, United States District Judge for the Southern District of New York, Thurgood Marshall United States Courthouse, 40 Foley Square, New York, New York, in Courtroom 906. No next conference was scheduled at this appearance.¶
Separately, currently on the home page we have a box for the Epstein case, that’s a link to the updates and also information on where to call with information. Could we please change that to the Maxwell case? So exact same language, just change the case heading to the one for Maxwell, above, and switch “Jeffrey Epstein” to “Ghislaine Maxwell” – so that if people just go to our main website, they can easily see where the updates are. Thank you!!¶
Should we be updating to the page to reflect yesterday’s hearing and order? Let me know if this works:¶
July 14, 2019 update:¶
On July 14, 2019, the initial conference, arraignment, and bail hearing were held in the case of United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). The defendant entered a plea of not guilty to the Superseding Indictment. The court announced its ruling that the defendant will be incarcerated pending trial. The Court scheduled discovery and motion deadlines for counsel as well as trial date for July 12, 2021, before the Honorable Alison J. Nathan, United States District Judge for the Southern District of New York, Thurgood Marshall United States Courthouse, 40 Foley Square, New York, New York, in Courtroom 906.¶
Sent from my iPad¶
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