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Florida t Admitted in New York Hoard Ccitified Civil Trial LAWFT Re: Request for Tangible and Documentary Evidence (Touhy Request) Katlyn Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07771 Dear Mr. Kochevar: In follow up to our previous communications, please accept this as our formal written reque
Evidence (Touhy Request) Katlyn Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07771 Dear Mr. Ko
cumentary Evidence (Touhy Request) Katlyn Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07771 Dea
cumentary Evidence (Touhy Request) Katlyn Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07771 Dear
ek copies of the following documents that we believe are currently in the possession of the Government: I) Photographs of Katlyn Doe; 2) Videos of Katlyn Doe; 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and Katlyn Doe; 4) Any and all reco
to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work for Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertili
stein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertility treatments for Indyke and his wife. Neither man has a public social media account, and both shun press interviews. But both could soon be questioned as part of a lawsuit
r Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney
litigator, more like a fixer," Edwards noted at another point. "Indyke had one client: Jeffrey Epstein." Edwards represents a client referred to as Katlyn Doe, who alleges in a lawsuit that Epstein forced her to marry one of his non-citizen female recruiters— nuptials arranged, she says, through Epstein's
. Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer. Ki In a 2003 Vanity
ce of J. Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer. Ki In a 2003
for $4.95 million by an anonymous limited liability company, with an address that matches the office of J. Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer. Ki In a 2003 Vanity Fair expose, Epstein refers to Maxwell as "my best friend" Dia Epstein was a longtime acquaintance
d her complaint to include over 20 corporate entities associated with Epstein and named the additional individuals Lesley Groff and as enablersJIM Katlyn Doe, et at v. Epstein's estate (2019) https://en.wilapedia.orgAviki/Jeffrey_Epsteln 13/60 EFTA00261994 .)7k- rot ce: c..,,coe5L -re R,c, et) Nice
. Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer. ka In a 2003 Vanity
ce of J. Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer. ka In a 2003
for $4.95 million by an anonymous limited liability company, with an address that matches the office of J. Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer. ka In a 2003 Vanity Fair expose, Epstein refers to Maxwell as "my best friend".13-21 Epstein was a longtime acquaintanc
her complaint to include over 20 corporate entities associated with Epstein and named the additional individuals Lesley Groff and as enablers.L1Za Katlyn Doe, et at v. Epstein's estate (2019) httpsfien.wikipedia.orgAsnki/Jeffrey_Epstein 13160 EFTA00263119 . 5/22/22, 1:31 PM Jeffrey Epstein. Wikipedia
r US$4.95 million by an anonymous limited liability company, with an address that matches the office of J. Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer.E0 In April 2016, the property was sold for US$15 Following her personal and professional involvement with Epstein, Maxw
Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer.E0 In April 2016, the
e of J. Epstein & Co. Representing the buyer was Darren Indyke, Epstein's longtime lawyer.E0 In April 201
lude over 20 corporate entities associated with Epstein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers [1701. Katlyn Doe, et at v. Epstein's estate (2019) https://en.wicipedia.orgMiki/Jeffrey_Epstein 13/60 EFTA00264470 Mfr eINE.C.0 - ePSITEt - DIRECTcY TARGETING
to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work for Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertili
stein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertility treatments for Indyke and his wife. Neither man has a public social media account, and both shun press interviews. But both could soon be questioned as part of a lawsuit
r Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney
litigator, more like a fixer," Edwards noted at another point. "Indyke had one client: Jeffrey Epstein." Edwards represents a client referred to as Katlyn Doe, who alleges in a lawsuit that Epstein forced her to marry one of his non-citizen female recruiters— nuptials arranged, she says, through Epstein's
iability and accountability." (Id., at 18.) The New York Times reports that this lawsuit "seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr. Epstein's vast wealth into a victim's compensatory fund."' Particularly in light of these recent developments, plaintiffs deserve to k
ms Epstein Trafficked Girls in Caribbean Until 2018, NEW YORK TIMES, Jan. 15, 2020. 2 VE v. Nine East 71st Street et al., No. 19-cv-07625 (MN) (DF); Katlyn Doe v. lndyke et at, No. I 9-cv-0777I (PKC) (DF); .Doe v. Indyke et at, No. I 9-cv-07772 (ALC) (DF); IMIDoe v. Indyke et at, No. I9-cv- 07773 (ER) (DE)
tim. EFTA00261766 Targeted victim - married to Darren McDiarmid - 4 children - Residing in Port Pine T
her complaint to include over 20 co orate entities associated with Epstein and named the additional individuals Lesley Groff and as enablers [1701 Katlyn Doe, et at v. Epstein's estate (2019) EFTA00261789 5/22/22, 1:31 PM JeflYeyEps - Wklpeclie WIKIPEDIA SEXC.FIC -TORCACTI - late OLD C_H1L1:1)42eN
Melbourne with her father since the age of 12 / Darren McDiarmid / ex husband Question I asked suspicio
r 2019, amended her complaint to include over 20 at sociated with Epstein and named the additional individuals Lesley Groff and sas enablers.11791 Katlyn Doe, et al. v. Epstein% estate (2019) some-fron wannadia nmhviki/Jaffrev Epstein 13160 EFTA00263700 5/19T22, 4:19 epstaN - Mt9X ,A) (Riskin° Maxtv
Melbourne with her father since the age of 12 / Darren McDiarmid / et husband Question I asked suspicio
her complaint to include over 20 corporate entities associated with Epstein and named the additional individuals Lesley Groff and as enablers 5170] Katlyn Doe, et at v. Epstein's estate (2019) httos://en.wikioedia.oraMiki/Jeffrev Epstein 13/60 EFTA00263779 5/19122, 4:19 PM .4 M k'$\' - Ihistaine Maxw
Entities connected to both Darren Indyke and Katlyn Doe

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Richard Kahn
PERSON
Marc Rich
PERSON
Bella Klein
PERSONLeon Black
PERSON
Woody Allen
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONJanusz Banasiak
PERSON
Teterboro
LOCATION
George Mitchell
PERSON
U.S. Virgin Islands
LOCATION
United States
LOCATION
Joe Biden
PERSON
FedEx
ORGANIZATION
Ehud Barak
PERSON