-John From: Kochevar, Steven (USANYS) < Sent: Thursday, April 16, 2020 7:07 PM To: McEnany, John (USANYS) < (USANYS) (USANYS) Cc: Subject: RE: Jeffrey Epstein-Related Touhy Requests All, <->; Please find attached a letter responding to the Touhy request for documents related to Jeffrey Epstein submitted by a victim who is a plaintiff in a civil suit against Epstein's estate. I am also attaching the documents to be produced in response to the request. Please let me know if you have any edits or concerns. If not, I plan to contact requester's counsel next week, let them know about the production, and send them the letter and the documents. I'm also attaching their request letter here. (Alex, Alison, and Maurene are signed off on the letter and gathered the documents.) Thanks, Steven From: < Sent: Friday, January 3, 2020 8:49 PM To: Kochevar, Steven (USANYS) Cc: McEnany, John (USANYS) O; ) >; Subject: RE: Jeffrey Epstein-Related Touhy Requests Steven, (USANYS) (USANYS) Thanks very much for drafting this, and I think generally it looks great. My only small thought would near the end, in the penultimate paragraph, where I'd suggest replacing the first two sentences with (something like): "My understanding is that you may intend to make a formal written request pursuant to the above-described regulations. [If you choose to submit . . .I" I say that only because the current language makes it sound like they were supposed to submit something in writing, or that they otherwise erred, when in fact what they actually asked for was just an explanation of the appropriate form in which to make a formal request—which they can do consistent with the regulations set forth in the letter. Does that sound alright? And of course on any of these I also entirely defer to John. thanks again, Alex. From: Kochevar, Steven (USANYS) < Sent: Friday, January 03, 2020 12:55 To: Cc: McEnany, John (USANYS) O; ) >; 41a Subject: RE: Jeffrey Epstein-Related Touhy Requests All, (USANYS) (USANYS) EFTA00104405

Please find attached an initial letter to Kaplan Hecker re: the request for information related to Epstein. Please let me know if you have any edits or concerns. Once I have sign-off, I'll send to Robbie Kaplan (by mail and at rkaplanPkaplanhecker.com or let me know if I should use a different address). Alex, assuming there are not huge changes to be made here, I think the letter/email could just go out as the next contact with Robbie on this, but I leave it up to you if/how you want to separately give her notice that it's on the way. Thanks, Steven From: Kochevar, Steven (USANYS) Sent: Thursday, January 2, 2020 7:16 PM To: Cc: McEnany, John (USANYS) (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests Alex, All sounds good to me—thanks for the call and note. I'll circulate a draft of the initial letter. Thanks, Steven From: < Sent: Thursday, January 2, 2020 7:10 PM To: Kochevar, Steven (USANYS) < Cc: McEnany, John (USANYS) ; ) (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests Steven, (USANYS) (USANYS) Thanks for talking with me this evening about this, we appreciate it. To briefly memorialize our discussion, and to loop in everybody on the case on the criminal side, you'll be the point person for requests from civil plaintiffs / victims in connection with Epstein lawsuits, and we'll work with you on those requests given our knowledge of the relevant facts and materials. In terms of this first question from the plaintiff, which was essentially presented as a question of how they should go about making a request for certain materials possibly in the possession of the Government, we'll plan to take a look at the letter you draft that will essentially set forth the requirements for making a Touhy request (e.g., similar to, or including, the kind of information in John's example below), and separately sometime early next week I'll let plaintiff's counsel (Robbie Kaplan at Kaplan & Hecker) know that they can expect to hear from someone in our Civil Division, within approximately a week or so (of when that conversation occurs), and that we anticipate that communication will include the relevant requirements of making such a request. Please let me know if I'm forgetting anything, thanks again, and talk soon. Alex. EFTA00104406