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From: To: • Subject: FW: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. I :20-cv-00484-JGK-DCF Date: Tue, 09 Jun 2020 03:51:05 +0000 Importance: High Attachments: 6 8
Page: EFTA00020088 →gh Dear Mr. Please see the attached letter of today's date. A copy will also be sent via Fedex. Thank you. Robert Glassman Robert Glassman, Esq. Panish Shea & Boyle LLP Email: Web: www.psblaw.com CONFIDENTIALITY NOTICE: This e-mail may contain confidential and privileged material for the sole use of the intended
Page: EFTA00020088 →victim, we don't want to unnecessarily impede her litigation. In the first instance, though, because her attorney does not have experience with the Touhy process, I think it would make sense, subject to input from you and John, to send her attorney basically the same letter you sent Robbie back in Jan
e back in January, to get the ball rolling? Let us know what you think. To the extent that makes sense, his contact info is: Robert Glassman, Esq. Panish Shea & Boyle LLP 11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025 Email: [email protected] Please let us know if any questions or issues? And thank
couple emails below, they consist mostly of FedEx invoices, plus another few docs, that EFTA00084175 need to be redacted for production based on a Touhy request. Would you be able to help out with that? If you could please send the redacted versions to us and to (copied here), we'll do a final revie
you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes
frey_Epstein.pdf; Atigust_2020_Document_Production_to_Glassman_re_Touhy_Request.pdf Mr. Glassman, Please find attached a letter responding to your Touhy request. Thank you, From: (USANYS) Sent: Tuesday, June 30, 2020 12:33 AM To: Robert Glassman (ta Cc: Betts < E > Subject: Re: Request for Tang
Page: EFTA00014450 →you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes
Page: EFTA00014451 →more specific sense of timing. Thanks! From: Sent: Tuesday, June 30, 2020 1:38 PM To: Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF Hey I apologize for the delay — our entire team has been absolutely swampe
Page: EFTA00030341 →you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes
Page: EFTA00030342 →Entities connected to both Touhy and Panish Shea & Boyle LLP

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONJane Doe
PERSONNathan Werksman
PERSONSouthern District
LOCATIONRobert S. Glassman
PERSONRobert Glassman
PERSONDarren Indyke
PERSON
FedEx
ORGANIZATION
Kaplan
PERSONGlassman
PERSONPanish Shea
PERSONBetts
PERSONKeilah
PERSON