lr" Crd EDWARDS POTTING ER LLC Florida Office Bradley J. Edwards "Ot 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 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 Admitted in California 0 Admitted in District of Columbia • Admitted in Florida t Admitted in Nat York I Hoard Certified Civil Trial Lawyer Re: Re uest for Tangible and Documentary Evidence (Touhy Request) V. Darren K. I ndyke, et al., SDNY Case No. 1:19-cv-07773 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, See United States ex rel. Touhy v. Rages, 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. was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2002 through 2010. From the time met when she was only seventeen years old, Epstein sexually abused and assaulted in the most horrific ways imaginable. Throughout the years of abuse, Epstein paid for medical treatments, provided legal counsel, purchased a number of commercial flights, ' To protect her anonymity, our client has elected to proceed as a As such, we have referred to her herein using the pseudonym under which she has filed her lawsuit. To the extent t