EFTA00091398.pdf

Crl" Florida Office Bradley J. Edwards *01 Seth M. Lehrman 't Brittany N. Henderson *0 Matthew D. Weissing *I EDWARDS POTTINGER LLC 425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Telephone (954)524-2820 Fax (954)524-2822 October 21, 2020 FOIA PRIVACY EXEMPTION 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 Office J. Stanley Pottinger j Admitted in California 0 Admitted in District of <:olumbia • Admitted m Florida t Admitted in New York Board (:cnified f:ival Trial LAW \ Vf Re: Request for Tangible and Documentary Evidence (Touhy Request) Priscilla Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07772 Victim: 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, See United States ex rel. Touhy v. Rages, 340 U.S. 462 (1951). We make this w suant 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. EFTA00091398 Page 2 We specifically seek copies of the following documents that we believe are currently in the possession of the Government: I) 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 beha • • • 9) all documents referencing Priscilla Doe residing at 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 EFTA00091399 Page 3 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 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 EFTA00091400