Touhy request from an alleged victim's attorneys to SDNY prosecutors, Oct. 2020

Florida Office¶

Bradley J. Edwards *◊†¶

Seth M. Lehrman *†¶

Brittany N. Henderson *צ

Matthew D. Weissing *†¶

New York Office¶

J. Stanley Pottinger ‡¶

† Admitted in California¶

◊ Admitted in District of Columbia¶

• Admitted in Florida

‡ Admitted in New York¶

| Board Certified Civil Trial Lawyer¶

October 15, 2020¶

VIA E-MAIL AND FEDEX¶

The Honorable Geoffrey S. Berman¶

United States Attorney for the Southern District of New York¶

Re: Request for Tangible and Documentary Evidence (Touhy Request) Priscilla Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07772¶

Dear Mr. Kochevar:¶

In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein’s many victims, Priscilla Doe. $ ^{1} $ See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings.¶

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We specifically seek copies of the following documents that we believe are currently in the possession of the Government:¶

1. Photographs of Priscilla Doe;

2. Videos of Priscilla Doe;

3. Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and Priscilla Doe;

4. Any and all records of purchases of gifts or anything of value purchased for or sent to Priscilla Doe;

5. Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to Priscilla Doe;

6. Any and all records of payments made to medical providers on behalf of Priscilla Doe;

7. Any and all records of payments made to attorneys on behalf of Priscilla Doe;

8. Any and all records of payments made to accountants on behalf of Priscilla Doe;

9. Any and all documents referencing Priscilla Doe residing at 301 East 66th Street, New York;

10. Any and all documents including Priscilla Doe’s true name;

11. Any and all lists including Priscilla Doe’s true name; and

12. Any and all other documentary materials relating in any way to Priscilla Doe.

Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted:¶

(a) (1) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose;¶

(a) (2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the requested non-privileged documentary evidence directly concerns the allegations in Doe’s civil case.¶

Due to the establishment of the Epstein Victim Compensation Program that is currently underway, Priscilla Doe seeks this information on an expedited basis in order to properly and completely present her claim for consideration, and if necessary, to continue to proceed by way of formal litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. Furthermore, this request does not¶

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seek information that is classified or that would reveal the source or identity of any informant. To that effect, Priscilla Doe specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. Priscilla Doe simply requests information in the Government’s possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain the justice that she deserves. To the extent that the requested materials can be made available to Priscilla Doe on an expedited basis, it would be greatly appreciated.¶

Please contact us at your earliest convenience to discuss the identity of Priscilla Doe in more detail, at which time we are fully prepared to answer any questions that you may have.¶

Very truly yours,¶

EDWARDS POTTINGER LLC¶

Bradley Edwards¶

Brittany Henderson¶

EFTA00091299¶