r i m" 11) Florida Office Bradley J. Edwards *Of 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 EDWARDS POTTINGER LLC 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 j Admitted in California 0 Admitted in I>istrict of Columbia • Admitted m Florida t Admitted in New York Beard (:cnified Civil Trial lau)vr Re: Request for Tangible and Documentary Evidence (Touhy Request) 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. 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. was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2000 through 2004. From the time the met when she was only thirteen years old, Epstein sexually abused and assaulted in the most horrific ways imaginable. Throughout the years of abuse, Epstein sent a number of gifts to 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 ' To protect her anon ity, our client has elected