From: Kochevar, Steven (USANYS) < Sent: Friday, May 22, 2020 17:16 To: McEnany, John (USANYS) < (USANYS) Cc: (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests <a> ) <->; Understood. Thanks, John. David Jones thought this approach was reasonable, but I'll check with Sarah too. Overall, I don't think we have a ton of precedent for referring folks to another USAO on a Touhy, and certainly not to a third USAO in the referral context. Some information that might be useful in this that I don't have a complete understanding of—are the materials from the S.D. Fla. investigation available to us? As in, have we ever seen or used them? If not, is there a particular reason for that? We may be in the odd situation of technically having some purview over those materials by virtue of the Touhy regs, but without access to them. But please let me know if I'm overlooking some dimension of our cooperation (if any) with the other USAOs. Thanks, Steven From: McEnany, John (USANYS) Sent: Friday, May 22, 2020 4:34 PM To: Kochevar, Steven (USANYS) Cc: (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests (USANYS) ; <->; I have some hesitation on just referring them to NDGa for the SDFla investigative stuff. First, under Touhv section 16.22(b), the responsible USA is the USA for the district "where the issuing authority" is located. They actually have an action filed in this district, no? Like it or not, we may be stuck with dealing with their requests for does from the Florida investigation. Stephen, you might want to consult wiser Touhy heads in civ div, like Sarah for instance. Also, it is possible that Touhv does not fall within the scope of SDFla's recusal. I can't see NDGA racing to embrace doing Touhys on this. From: Kochevar, Steven (USANYS) < Sent: Wednesday, May 20, 2020 7:24 PM To: McEnany, John (USANYS) < (USANYS) Cc: (USANYS) ) Subject: RE: Jeffrey Epstein-Related Touhy Requests All, <->; Closing the loop on this: we produced documents responsive to an Epstein victim's Touhy request about a month ago. The requesters got back to us (by phone) with a fairly lengthy list of follow-up questions about what we produced and additional/related demands. We don't have much responsive to many of their follow-ups, or do not think it would be appropriate to produce additional material they're seeking—for example, materials that are part of the ongoing investigation. Alex and I intend to have a call with requester's counsel to explain to them that we will not be producing anything further at this time. At this point, we don't plan to send them anything else in writing. EFTA00104585

One small wrinkle: they have asked us for materials from S.D. Fla.'s investigation (which we don't have) and asked whether they need to submit a separate request to that office. We intend to tell them that N.D. Ga. has stepped into the shoes of S.D. Fla. For Epstein purposes, that they can submit a request there (or to S.D. Fla.) for the materials they're seeking, and possibly provide them with a contact at N.D. Ga. if they ask. Please let us know if you have any concerns. We hope that this will be the last step on this request. Thanks, Steven From: McEnany, John (USANYS) Sent: Monday, April 20, 2020 5:52 PM To: Kochevar, Steven (USANYS) < (USANYS) (USANYS) < Cc: >; <->; 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 problem disclosing it to her again. So I don't have a problem with you sending this out. Thanks for your work on this, Steven. -John From: Kochevar, Steven (USANYS) < Sent: Thursday, April 16, 2020 7:07 PM To: McEnany, John (USANYS) < >; (USANYS) < Cc: (USANYS) <a. ) < Subject: RE: Jeffrey Epstein-Related Touhy Requests All, >;I <->; 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) ca; ) <->; 1 >; (USANYS) (USANYS) EFTA00104586

Subject: RE: Jeffrey Epstein-Related Touhy Requests Steven, 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) ) Subject: RE: Jeffrey Epstein-Related Touhy Requests All, (USANYS) (USANYS) 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)<S , 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. (USANYS) Thanks, Steven EFTA00104587