Cr1r1r) Florida Office Bradley J. Edwards *Ol Seth M. Lehrman *1- 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 Dear] New York Office J. Stanley Porringer j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida t Admitted in New York I Heard Certified Civil Trial I.suwr Re: Request for Tangible and Documentary Evidence (Touhy Request) 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 relating to the sexual abuse of one of Jeffrey Epstein's many victims, Jane Doe 2.' See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings. Jane Doe 2 Jane Doe 2 was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2000 through 2004. From the time they met when she was only thirteen years old, Epstein sexually abused and assaulted Jane Doe 2 in the most horrific ways imaginable. Throughout the years of abuse, Epstein sent a number of gifts to Jane Doe 2, record of which we believe is currently in the Government's ' To protect her anonymity, our client, Jane Doe 2. As such, we have referred to her herein as Jane Doe 2. has elected to proceed as a EFTA00068881