Epstein Secrets

ple, the Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of

e 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the Government has informed defense counsel, the Government has no inten

D. Additional Considerations All of the factors outlined in 28 C.F.R. § 16.26 governing the production and disclosure of information pursuant to a Touhy demand weigh in favor of production and disclosure in this matter. Epstein was a notorious pedophile who was indicted for sexually abusing and traff

e's litigation and corroborative of her claims. Specifically, we understand that our client has had repeated interactions with the U.S. Attorney's Office for the Southern District of New York (the "Office") and with the Federal Bureau of Investigation ("FBI") over the course of the past fifteen years. Doe was first contacted by the FBI a

cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice has received both FOIA and Touhy requests in connection with this investigation, requests to which the Department has a legal obligation to respond appropriately. The Government res

e 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the Government has informed defense counsel, the Government has no inten

_Epstein_Letter to_MCC-c2.pdf; 8.20.19_Epstein_Letter to_FBI-c2.pdf : could you kindly assign an AUSA to be the point of contact on Epstein-related Touhy requests? We can then discuss what the appropriate response may be. Thanks, as always, for your help on these issues. From: (USANYS) Sent: Tuesda

of contact. From: Sent: Tuesday, August 20, 2019 11:47 AM To: (USANYS) < Cc: >; Subject: FW: United States v. Jeffrey Epstein, 19-CRIM-00490 (S. D. N.Y.) and M, (USANYS) We received the attached document requests from Epstein's lawyers. Based on our previous conversations about this, it sounds lik

cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice has received both FOIA and Touhy requests in connection with this investigation, requests to which the Department has a legal obligation to respond appropriately. The Government res

e 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the Government has informed defense counsel, the Government has no inten

ple, the Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of

e 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the Government has informed defense counsel, the Government has no inten

ple, the Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of

e 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the Government has informed defense counsel, the Government has no inten

ert testimony. The Government has moved to preclude the defense from offering such evidence, including by calling the case agents identified in its Touhy notice. (See Gov't Motions in Limine Section III). Accordingly, if the defense plans to call case agents for such testimony—which the Court should p

reating, and speaking to prostitutes was sufficiently reliable. Id. at 263- 64; see also, e.g., Letter, United States v. Kelly, No. 19 Cr. 286 (AMD) (E.D.N.Y. July 23, 2021) (Dkt. No. 134); United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at •6 (S.D.N.Y. May 13, 2021) (permitting expert tes

cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice has received both FOIA and Touhy requests in connection with this investigation, requests to which the Department has a legal obligation to respond appropriately. The Government res

e 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the Government has informed defense counsel, the Government has no inten