EDWARDS

Florida Office

Cr 1) '.1.d Florida Office Bradley J. Edwards *Ol Seth M. Lehrman 't Brittany N. Henderson *0 Matthew D. Weissing EDWARDS POTTINGER LLC October 21, 2020 FOIA PRIVACY EXEMPTION VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorney 86 Chambers Street, Third Floor New York. New York 10007 Dear New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in I>istrict of Columbia • Admitted m Florida t Admitted in New York Beard (:crtified Civil Trial lau)rr Re: Re tuest for Tangible and Documentary Evidence (Touhy Request) Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07773 Victim: In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relatin

r i m" 11)

r i m" 11) Florida Office Bradley J. Edwards *Of Seth M. Lehrman 't Brittany N. Henderson *0 Matthew D. Weissing *I VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York c/o Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 Dear EDWARDS POTTINGER LLC 425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Telephone (954)524-2820 Fax (954)524-2822 October 15, 2020 New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in I>istrict of Columbia • Admitted m Florida t Admitted in New York Beard (:cnified Civil Trial lau)vr Re: Request for Tangible and Documentary Evidence (Touhy Request) In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of

Cr.1.4

im" Cr.1.4 Florida Office Bradley J. Edwards *0f Seth M. Lehrman "t Brittany N. Henderson *0 Matthew D. Weissing VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorne EDWARDS POTTINGER LLC October 15, 2020 New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida j Admitted in New York Beard Cenified Civil Trial LAWSVf Re: Request for Tangible and Documentary Evidence (Touhy Request) Dear Mr. Kochevar: In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, Jane Doe.' See United States ex rel. Touhy v. Rage::, 340 U.S. 462 (1951). We ma

Florida Office

lr" Cr4 Florida Office Bradley J. Edwards "Oi Seth M. Lehrman "t Brittany N. Henderson "0 Matthew D. Weissing "I EDWARDS POTTINGER LLC October 21, 2020 FOIA PRIVACY EXEMPTION VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in I>ittiict of Columbia • Admitted m Florida t Admitted in New York Beard (:ctinicd Civil Trial lau)rr Re: Re uest for Tangible and Documentary Evidence (Touhy Request) v. Darren K. Ind ike et al., SDNY Case No. 1:19-cv-07771 Victim: Dear Mr. In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating t

COHEN & GRESSER LLP

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com October 13, 2020 BY EMAIL. , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of

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