EFTA00030341

From: To: Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. I :20-cv-00484-JGK-DCF Date: Tue, 30 Jun 2020 20:25:32 +0000 No problem! Good luck with everything. I don't think there's any hard deadline on the request because we're not in court and they didn't send a subpoena. So the main constraint is Glassman's annoyance. I wrote him a brief note back last night, although I doubt that will keep him happy for very long. I try not to provide specific timelines on stuff like this, but if we need too much more time I can try letting him know a more specific sense of timing. Thanks! From: Sent: Tuesday, June 30, 2020 1:38 PM To: Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF Hey I apologize for the delay — our entire team has been absolutely swamped for the past two weeks; we indicted Ghislaine Maxwell yesterday and now are working on arrest plans, and it's been insane. I very much hope to be able to take care of this next week, it's just been one thing after another for a little while. From: Sent: Sunday, June 28, 2020 23:06 To: Subject: Fwd: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF Hi M, Just checking in on this—do you think it will be possible to gather the materials this week? I will write Glassman back and tell him that I hope to follow up soon. Thanks, Sent from my iPhone Begin forwarded message: From: Robert Glassman Date: June 26, 2020 at 12:49:19 AM EDT To: (USANYS)" Cc:" "Nathan Werksman" >, Keilah Betts < Subject: Re: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-1GK-DCF Mr. S I am following up on my client's request. It would mean a lot for your office to do what it can to see that her request is complied with in an expedient manner. Thank you. EFTA00030341 Robert S. Glassman Panish Shea & Boyle psblaw.com On Jun 8, 2020, at 4:19 PM, (USANYS) Dear Mr. Glassman, Thank you for your letter. I will follow up. Thanks, From: Robert Glassman Sent: Monday, June 8, 2020 3:08 PM To: Cc: Betts < Subject: Request for Tangible and Documentary 1:20-cv-00484-JGK-DCF Importance: High < wrote: ; Nathan Werksman Keilah Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. Dear Mr. Please see the attached letter of today's date. A copy will also be sent via Fedex. Robert Glassman Robert Glassman, Esq. Panish Shea & Boyle LLP Los Angeles, CA 90025 Email: Web: www.psblaw.com Thank you. CONFIDENTIALITY NOTICE: This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. EFTA00030342