ry 6, 2020, DOJ's response to 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 United States Attorney has authorized DOJ to provide certain documents responsive to your

f 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 ex reL Told°, 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

nment's investigation concerning Jeffrey E. Epstein's repeated acts of sexual abuse against our client, Jane Doe.' See United States a 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 of Justice ("DOJ") and ar

f 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 ex rel. Touhy v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for the Southe

y of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, M.' See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to

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 ex rel. Touhy v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for the Southe

of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, VE.1 See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to

Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, Jane Doe 2.' See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to

't of Justice, 312 F.3d 70 (2d Cir. 2002) 13 U.S. Dep 't of State v. Washington Post Co., 456 U.S. 595 (1982) 17 United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) 16 United States v. Schwimmer, 892 F.2d 237 (2d Cir. 1989) 14 W. Journalism Ctr. v. Office of Indep. Counsel, 926 F. Supp

't of Justice, 312 F.3d 70 (2d Cir. 2002) 13 U.S. Dep 't of State v. Washington Post Co., 456 U.S. 595 (1982) 17 United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) 16 United States v. Schwimmer, 892 F.2d 237 (2d Cir. 1989) 14 W. Journalism Ctr. v. Office of Indep. Counsel, 926 F. Supp

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 ex rel. Touhy v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for the Southe

ent of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. 301; United States ex rel. Touhy v. EFTA00078017 Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or gove

ned by Department of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or gove

ned by Department of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or gove

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

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

ned by Department of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or gove

way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to

ned by Department of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or gove

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 ex reL Touhy v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for the Southe