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ANYS)" )is „cl F.,. el - - - Cc: "I Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Mon, 20 Apr 2020 21:53:59 +0000 USANYS Yes, the Jane Doe is From: (USANYS) Sent: Monday, April 20, 2020 17:52 To: (USANYS) (USANYS) ic ); , for sure — thanks and good point. •c > Cc: (USANYS) 1.S
ment of Investigation of the City of New York, 856 F.2d at 483; Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are
C c: I II It I/ II It Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Mon, 20 Apr 2020 21:51:57 +0000 I take it we fully know that Jane Doe is I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a problem disclos
ment of Investigation of the City of New York, 856 F.2d at 483; Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are
To: Kochevar, Steven (USANYS) 4 Cc: (USANYS) ) (USANYS) dc ); Subject: RE: Jeffrey Epstein-Related Touhy Requests 1 take it we fully know that Jane Doe is Maria Lacerda? I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a
ment of Investigation of the City of New York, 856 F.2d at 483; Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are
PM To: Kochevar, Steven (USANYS) (USANYS) •ca; Cc: (USANYS) > Subject: RE: Jeffrey Epstein-Related Touhy Requests I take it we fully know that Jane Doe is Maria Lacerda? I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a
ment of Investigation of the City of New York, 856 F.2d at 483; Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are
ated Touhy Requests I take it we fully know that Jane Doe isa? I had a little pause on handing out the GJ
ment of Investigation of the City of New York, 856 F.2d at 483; Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are
020 5:52 PM To: (USANYS) (USANYS) dc ); (USANYS) Cc: < M> < Subject: RE: Jeffrey Epstein-Related Touhy Requests I take it we fully know that Jane Doe is I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a problem disclos
ment of Investigation of the City of New York, 856 F.2d at 483; Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are
Entities connected to both Jane Doe and Kinoy v. Mitchell

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSON
Department of Justice
ORGANIZATION
New York
LOCATION
Alfredo Rodriguez
PERSON
George Mitchell
PERSON
Touhy
PERSONRagen
PERSONCivil Division
ORGANIZATION
Robbie Kaplan
PERSONDepartment of Investigation of the City of New York
ORGANIZATIONJacoby
PERSONPeople v. Carbonaro
PERSONBoron Oil Co.
ORGANIZATIONKaplan & Hecker
ORGANIZATIONTuite
PERSONthe City of New York
LOCATIONBache Halsey Stuart Shields, Inc.
ORGANIZATION