U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Siren New York. New York 10007 August 3, 2020 By Electronic Mail Robert Glassman, Esq. Panish Shea & Boyle LLP 11111 Santa Monica Boulevard, Suite 700 Los An eles CA 90025 Re: Request for Information Relating to Jeffrey Epstein Dear Mr. Glassman: I write in response to your letter dated June 8, 2020, seeking documents from the Department of Justice ("DOJ") related to Jeffrey Epstein and plaintiff Jane Doe in Jane Doe v. Indyke et at, No. 20-cv-484 (S.D.N.Y.). Because your request seeks information from Department of Justice (the "Department") employees acquired during and as part of their performance of their official duties, your request is governed by certain Department regulations—commonly referred to as Told°, regulations—which, inter alia, prohibit any Department employee from disclosing such information "without prior approval 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 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 Southern District of New York. The applicable Touhy regulations direct the Department to consider inter alia, "[w]hether ... disclosure is appropriate under the rules of procedure governing the case or matter in which the demand arose." 28 C.F.R. § 16.26(a)(1). The Department understands that there is an initial pretrial conference scheduled for August 5, 2020, in Doe v. Indyke and that the parties in that matter have already exchanged discovery demands and responses. See Scheduling Order dated July 21, 2020, ECF No. 57, Doe v. Indyke et aL, No. 20-cv-484 (S.D.N.Y.). In light of the potential for formal discovery demands to issue in connection with Doe v. hidyke, the Department has determined that disclosures in response t