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From: (USANYS)" ctl To: '1 1, (USANYS)" <1 Cc: Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Sat, 17 Oct 2020 21:40:23 +0000 Attachments: 2020-10-1 5 ouhy_Request.pdf; 2020-10- 15 Touhy_Request.pdf; 2020-10-15 Touhy_Request.pdf; 2020-10- 14 Touh Request.pdf; 2020-10-15 Touhy_Request.pdf; 2020-10- 15 Touhy_Request.pdf All, FYI, this week, sent us six Epstein-related Touhy requests (attached) under pseudonyms. The Crim team does not know who these victims are. I am going to write back to stating that we cannot process these under pseudonyms, and he should re-submit with names. I assume he will ask to call me and tell me the names over the phone. I am going to tell him that we cannot accept that and need complete Touhy requests with names, in writing. Please let me know if you have any concerns with this approach. Thanks, From: S (USANYS) Sent: Wednesday, September 9,2020 3:56 PM To: (USANYS) Cc: cMa ; (USANYS) Subject: RE: Jeffrey Epstein-Relat
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EFTA Document EFTA02016959
EFTA00014068
EFTA02414102
reached in this case, and other information in the possession of the victims, it is also possible that
reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: a) involvement in and/or awareness of any aspect of the Government's criminal investigation and/or possible prosecution/non-prosecution of Epstein; b) Attorney liklimenvolvement in and/or awareness of the Government's interest."( witness, subject, or target of the Epstein investigation, including Sarah Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, Haley Robson, Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs and telephone billing statements) made by or received by m Jeffrey Epstein, the Florida Science
EFTA02351991
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe for review. The Court has carefully considered the Motions and is otherwise fully advised in the premises. I. Background The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From betw
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