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S. Government's investigation concerning Jeffrey E. Epstein's repeated acts of sexual abuse against our client, Jane Doe.' See United States a rel. Touhy v. Ragen, 340 U.S. 462 (1951). We believe that such evidence is currently in the possession, custody and control of the Department of Justice ("DOJ
Page: EFTA00020090 →PANISH SHEA & BOYLE, June 8, 2020 VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York c/o Assistant nited tates Attorne E-mail: Re: Request for Tangible and Documentary Evidence (Touhy Request) Jane Doe v. Indyke et al., SDNY Ca
Page: EFTA00020090 →pproval of the proper Department official in accordance with §§ 16.24 and 16.25 of this part." 28 C.F.R. § 16.22(a); see also United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for t
Page: EFTA00022146 →y v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for the Southern District of New York. The Touhy regulations provide a set of procedures for the United States Attorney to follow when considering such requests. See 28 C.F.R. §§ 16.22(b
Page: EFTA00022146 →ice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, M.' 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
Page: EFTA00023326 →itten 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, M.' See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make t
Page: EFTA00023326 →approval of the proper Department official in accordance with §§ 16.24 and 16.25 of this part." 28 C.F.R. § 16.22(a); see also United States ex reL Touhy v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for t
Page: EFTA00010331 →d a chance to review this letter if you would like to discuss the issues herein further. Sincerely, GEOFFREY S. BERMAN United States Attorney for the Southern District of New York By: Assistant United States Attorne Telephone Facsimile: E-mail: EFTA00010332
Page: EFTA00010332 →d the victims who are here today, among others, for your very hard work and dedication in this case. We also have here today the U.S. Attorney for the Southern District of New York, Geoffrey Berman, who has also been very helpful and indispensable in this matter. The news on August 10, 2019, that Jeffrey Epstein had been foun
Page: EFTA00019996 →s to what happened to him is through the media rather than through the United States Attorney's office. We've made requests informal. We have made Touhy requests. We've been told there is a pending investigation. But we trust your Honor and the judiciary, and with SOUTHERN DISTRICT REPORTERS, P.C.
Page: EFTA00020017 →Entities connected to both Touhy and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Geoffrey S. Berman
PERSONJane Doe
PERSON
Audrey Strauss
PERSON
Marc Rich
PERSON
Alison J. Nathan
PERSONthe Southern District
LOCATION
New York
LOCATION
Bradley Edwards
PERSONFBI
ORGANIZATIONRagen
PERSON
Alfredo Rodriguez
PERSONMartin Weinberg
PERSON
Bill Clinton
PERSONFederal Bureau of Prisons
ORGANIZATION
George Mitchell
PERSON