Datasets:
EDWARDS POTTINGER LLC Florida Office Bradley J. Edwards *0t Seth M. Lehrman "+ Brittany N. Henderson *0 Matthew D. Weissing *f 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 New York Office J. Stanley Pottinger ‡ • ramire imitat in Callois • Admittal in Florida 1 and Cried Gird Trial ayer Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 Re: Request for Tangible and Documentary Evidence (Touhy Request) Dear 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, C.S.. R. et seg, Should you Find here to be any date is why neu request please not 2% ' To protect her anonymity, our client, have referred to her herein as has elected to proceed as a As such, we EFTA00089728
Page 2 We specifically seek copies of the following documents that we believe are currently in the possession of the Government:
- Photographs of
- Videos of
- Arovides oratoreys dence between Jeffrey Epascin, his agens employes, medical
- Any and all records of purchases of gifts or anything of value purchased for or sent to
- 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
- Any and all records of payments made to medical providers on behalf of
- Any and all documents including true name;
- Any and all lists including true name; and
- 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 civil case. Due to the establishment of the Epstein Victim Compensation Program that is currently underway, seeks this information in order to properly submit her claim for consideration, and if necessary, 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 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 EFTA00089729
Page 3 finally obtain the justice 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 L which time we are fully prepared to answer any questions that you may have. in more detail, at Very truly yours, EDWARDS POTTINGER LLC BEe Bradley Edwards Brittany Henderson EFTA00089730