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efta-efta00095325DOJ Data Set 9Other

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DOJ Data Set 9
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EFTA 00095325
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From: ' To: Cc: ' (USANYS)" Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Fri, 18 Sep 2020 23:14:15 +0000 Hi Thanks very much for following up. I haven't communicated with MI recently, but I'm cc'ing who I think may have had a call with him a few days ago. From: (USANYS) Sent: Friday, September 18, 2020 6:52 PM To: Subject: RE: Jeffrey Epstein-Related Touhy Requests Checking in on this—I called and left a voicemail for him to call me back, but haven't heard anything back from him for several days. Have you communicated with him at all recently? I can try to call him again next week? Please let me know if I should be aware of anything on that front. Thanks, From: Sent: Thursday, September 10, 2020 2:13 PM To: (USANYS) Cc: (USANYS) ( USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests ; S =(usANYs)< I> (USANYS) < >; Thanks all. We do not have any specifics for the request to address. And we do not believe that it is possible for us to

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From: ' To: Cc: ' (USANYS)" Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Fri, 18 Sep 2020 23:14:15 +0000 Hi Thanks very much for following up. I haven't communicated with MI recently, but I'm cc'ing who I think may have had a call with him a few days ago. From: (USANYS) Sent: Friday, September 18, 2020 6:52 PM To: Subject: RE: Jeffrey Epstein-Related Touhy Requests Checking in on this—I called and left a voicemail for him to call me back, but haven't heard anything back from him for several days. Have you communicated with him at all recently? I can try to call him again next week? Please let me know if I should be aware of anything on that front. Thanks, From: Sent: Thursday, September 10, 2020 2:13 PM To: (USANYS) Cc: (USANYS) ( USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests ; S =(usANYs)< I> (USANYS) < >; Thanks all. We do not have any specifics for the request to address. And we do not believe that it is possible for us to accept this request under pseudonyms. Thanks, From: (USANYS) Sent: Wednesday, September 9, 2020 7:00 PM To: S (USANYS) Cc: >; (USANYS) >; (USANYS) c ) Subject: RE: Jeffrey Epstein-Related Touhy Requests (USANYS) Thanks, =. Sounds good. Once I hear from the Maxwell team re: any specifics for the request to address, I'll give I= a call and tell him to submit a written request. EFTA00095325 Thanks, From: S (USANYS) Sent: Wednesday, September 9, 2020 3:56 PM To: (USANYS) Cc: >; Subject: RE: Jeffrey Epstein-Related Touhy Requests (USANYS) < >; (USANYS) (USANYS) ; This string is a mile long so I'm going to truncate it. I think at this point we need to ask to make a formal Touhy request, with specifics of what he wants, in connection with what proceeding, and naming names, so that we can know exactly what he wants and evaluate it. Criminals, anything in particular you would like ' Touhy request to address? You will have to consider (i) whether disclosing anything under the Touhy request would have an impact on your case; (ii) whether it would have any impact on any of your witnesses (e.g., sharing info with a wit as affecting the wit's credibility; sharing info with the wit for the wit's civil case as a disclosable benefit); and (iii) keep in mind that responding to the request is likely to involve a great deal of your time. EFTA00095326

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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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