EFTA00087059.pdf

rn r EDWARDS POTTING ER LLC Florida Office Bradley J. Edwards *Of Seth M. Lehrman 't Brittany N. Henderson *0 Matthew D. Weissing *I VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York do Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 Dear 425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Telephone (954)524-2820 Fax (954)524-2822 October 15, 2020 New York Office J. Stanley Pottinger Admitted in California 0 Admitted in District of Columbia • Admitted in florid t Admitted in New York I Herald Certified f:iva Trial Latqtr Re: Re uest for Tangible and Documentary Evidence (Touhy Request) v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07771 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, . See United States ex rel. Touhy v. Roger:, 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. was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2007 through 2014. From the time the met when she was only seventeen years old, Epstein sexually abused and assaulted in the most horrific ways imaginable. Throughout the years of abuse, Epstein paid for medical treatments, provided legal counsel, purchased a number of commercial flights, ' To protect her anonymity, our client has elected to proceed as a As such, we have referred to her herein using the pseudonym under which she has filed her lawsuit. To the extent that her identity is not already known by the prosecutors in the Southern District of New York, please contact us at your earliest convenience to discuss her true identity. EFTA00087059 Page 2 provided housing, and purchased a number of items of value for , record of which we believe is currently in the Government's possession as a result of the investigation that was conducted into Epstein's criminal activity relating to the sexual abuse of minor children. Given the highly relevant nature of this tangible evidence to currently pending litigation, we request production of documentary evidence relating to in order to enable her to prove her claims from both a liability and damages standpoint. We specifically seek copies of the following documents that we believe are currently in the possession of the Government: I) Photographs of 2) Videos of 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and M=; 4) Any and all records of purchases of gifts or anything of value purchased for or sent to 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 6) Any and all records of payments made to medical providers on behalf of 7) Any and all records of payments made to attorneys on behalf of 8) Any and all records of payments made to accountants on behalf of 9) Any and all documents referencing residing at - 10) Any and all documents including true name; 11) Any and all lists including true name; and 12) Any and all other documentary materials relating in any way to 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, 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 seek information that is classified or that would reveal the source or identity of any informant. To EFTA00087060 Page 3 that effect, specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. 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 'ustice that she deserves. To the extent that the requested materials can be made available to on an expedited basis, it would be greatly appreciated. Please contact us at your earliest convenience to discuss the identity of 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 EFTA00087061