Cr 1O 'ILe 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 New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida t Admitted in New York I Heard Certified Civil Trial lawFr Re: Request for Tangible and Documentary Evidence (Touhy Request) VE v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07625 Victim: Deai 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, VE.1 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. VE VE was sexually assaulted by prolific pedophile, Jeffrey Epstein, on two occasions in 2000, when she was only 15 years old, record of which we believe is currently in the Government's possession as a result of the investigation that was conducted into Epstein's criminal activity relating to the sexual abuse of minor children. Given the highly relevant nature of this tangible evidence to VE's I To protect her anonymity, our client, has elected to proceed as a VE. As such, we have referred to her herein using the pseudonym under which she has filed her lawsuit. EFTA00068887