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efta-efta00091303DOJ Data Set 9Other

Florida Office

Cr 1r" Florida Office Bradley J. Edwards *0f Seth M. Lehrman "t Brittany N. Henderson *0 Matthew D. Weissing VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorne EDWARDS POTTINGER LLC October 15, 2020 New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in District of <:olumbia • Admitted m Florida t Admitted in New York Hoard (:cnificti Civil Trial l..m)yr Re: Request for Tangible and Documentary Evidence (Touhy Request) Lisa Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07773 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, Lisa Doe.' See

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Unknown
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DOJ Data Set 9
Reference
EFTA 00091303
Pages
3
Persons
3
Integrity

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Cr 1r" Florida Office Bradley J. Edwards *0f Seth M. Lehrman "t Brittany N. Henderson *0 Matthew D. Weissing VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorne EDWARDS POTTINGER LLC October 15, 2020 New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in District of <:olumbia • Admitted m Florida t Admitted in New York Hoard (:cnificti Civil Trial l..m)yr Re: Request for Tangible and Documentary Evidence (Touhy Request) Lisa Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07773 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, Lisa Doe.' See

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EFTA Disclosure
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Cr 1r" Florida Office Bradley J. Edwards *0f Seth M. Lehrman "t Brittany N. Henderson *0 Matthew D. Weissing VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorne EDWARDS POTTINGER LLC October 15, 2020 New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in District of <:olumbia • Admitted m Florida t Admitted in New York Hoard (:cnificti Civil Trial l..m)yr Re: Request for Tangible and Documentary Evidence (Touhy Request) Lisa Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07773 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, Lisa Doe.' 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. EFTA00091303 Page 2 We specifically seek copies of the following documents that we believe are currently in the possession of the Government: I) Photographs of Lisa Doe; 2) Videos of Lisa Doe; 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and Lisa Doe; 4) Any and all records of purchases of gifts or anything of value purchased for or sent to Lisa Doe; 5) Any and all records of donations made to the Martha Graham Dance Company or Ballet Academy East on behalf of Lisa Doe; 6) 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 Lisa Doe; 7) Any and all records of payments made to medical providers on behalf of Lisa Doe; 8) Any and all records of payments made to accountants on behalf of Lisa Doe; 9) Any and all documents including Lisa Doe's true name; 10) Any and all lists including Lisa Doe's true name; and 11) Any and all other documentary materials relating in any way to Lisa 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, Lisa 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 seek information that is classified or that would reveal the source or identity of any informant. To that EFTA00091304 Page 3 effect, Lisa Doe specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. Lisa 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 Lisa Doe on an expedited basis, it would be greatly appreciated. Please contact us at your earliest convenience to discuss the identity of Lisa 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 EFTA00091305

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Case #1:19-CV-07773

Related Documents (6)

Court UnsealedLegal FilingUnknown

Court Filing Exhibit: 285-1

This court filing exhibit contains notes and summaries of [REDACTED - Survivor]' testimony and experiences with Jeffrey Epstein and Ghislaine Maxwell, detailing their sex trafficking operation and abuse of minors. The document highlights the involvement of various individuals and law enforcement agencies in the investigation and prosecution of Epstein. It provides new insights into the case and potentially significant evidence.

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DOJ Data Set 9OtherUnknown

EFTA00144597

From To EFTA00144597 Subject: [EXTERNAL EMAIL] - Sweet Dreams... Date: Tue, 26 Nov 2024 06:07:08 +0000 Importance: Normal David Boies, Sergey Brin, Alan Dershowitz, Sigrid, Paul Cassell, Brad, Brittany, Stan, Goria and all involved in aiding and abetting, obstructing justice, rape and sex trafficking, including the media... GOTTCHA! CHECKMATE MOTHERFUCKERS, OR SHOULD I SAY KIDDIE FUCKERS! Hey Sergey? It gives me so much satisfaction knowing that most of you are sleeping soundly when I'm coming for every single one of you, and I mean every single one of you, and yes, that does include "journalists" and judges! I'M COMING .... SWEET DREAMS. Sent with Proton Mail secure email. On Monday, 4 November 2024 at 19:48, Dear Alina, wrote: We have never communicated, and I've never asked anything of you, but when the elections are over, can you please help file class actions on behalf of myself and ALL the Epstein against the Daily Mail, The Guardian, and every other British ne

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DOJ Data Set 8CorrespondenceUnknown

EFTA00023053

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DOJ Data Set 9OtherUnknown

COHEN & GRESSER LLP

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com October 13, 2020 BY EMAIL. , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of

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DOJ Data Set 9OtherUnknown

EXHIBIT Q

EXHIBIT Q EFTA00097394 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X INNIErt INIMINME, Plaintiff, v. GHISLATNE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Opposition to Plaintiff's Motion to Exceed Presumptive Ten Deposition Limit, and states as follows: INTRODUCTION Despite having taken only three depositions to date, Plaintiff prematurely requests permission to exceed the presumptive ten deposition limit imposed by Fed. R. Civ. P. 30(aX2)(A)(i) and to conduct 17 separate depositions, almost twice the limit. Without legal support, Plaintiff attempts to conflate the presumptive time limita

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DOJ Data Set 9OtherUnknown

Confidential

Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x Plaintiff, -against- GHISLAINE MAXWELL, Defendant. Case No.: 15-cv-07433-RWS **CONFIDENTIAL** x Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAG NA 0 LEGAL SERVICES EFTA00083933 Confidential Page 2 1 2 APPEARANCES: 3 On Behalf of the Plaintiff: 4 BOIES SCHILLER & FLEXNER, LLP 333 Main Street 5 Armonk, New York 10504 BY: DAVID BOIES, ESQUIRE 6 7 8 BY: BOIES SCHILLER & FLEXNER,LLP Fort Lauderdale, Florida 33301 MEREDITH SCHULTZ, ESQUIRE SIGRID McCAWLEY, ESQUIRE 9 SANDRA PER

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