Epstein Secrets

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 Justice

Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan

e procedure is mandatory and governs state and federal proceedings and has been upheld in the United States Supreme Court. See U.S. ex rel, Touhv v. Ragen, 340 U.S. 462 (1951). To obtain FBI investigative information, the party making the request must provide to this office an affidavit, or statement

676 • • AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida To: Records Custodian Fedeal Bureau Invests ato C/O rth Miami Beach, FL 33169 O Testimony: YOU ARE COMMANDED to appear at the time, da

fficial's testimony cannot be authorized without first complying with their employing agency's Touhy regulations. See United States ex reL Touhy v. Ragen , 340 U.S. 462, 468 (1951); 5 U.S.C. § 301. The regulations related to the Federal Bureau of Investigation can be found at 28 C.F.R. §§ 16.21, et se

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: January 22, 2010 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq

ment's investigation concerning Jeffrey E. Epstein's repeated acts of sexual abuse against our client, Jane Doe.' See United States ex 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 ofJustice ("DOJ") and are

, 10, 15, and 17 EFTA_00007020 EFTA00158521 June 8, 2020 VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York c/a Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 E-mail Re: Request for Tangible and

val 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 a reL To* v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Audrey Strauss, the Acting United States Attorney for the Sou

7 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000705 I EFTA00158530 U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Strew New York Neu• York 10007 August 3, 2020 B Electronic Mail aim Re: Request for Information Relating to Jeffrey Ep

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 Justice

Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan

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 Justice

Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan

aL, No. 20-cv-484 (S.D.N.Y.). Your request is governed by federal regulations, referred to as "Touhy regulations." See United States a reL Touhy v. Ragen, 340 U.S. 462 (1951). Pursuant to these regulations, the Acting United States Attorney has authorized DOJ to provide certain documents responsive t

U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 July 2020 By Electronic Mail Robert Glassman, Esq. Re: Request for Information Relati