From: To:' r r < Cc: ' „cl Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Tue, 04 Aug 2020 20:28:04 +0000 [=. Is the 3500 folder just the Witnesses & Cooperators folders, or is there another spot? Sorry if I'm missing / forgetting something. From: Sent: Sunday, August 02, 2020 14:49 To: Subject: Fwd: Jeffrey Epstein-Related Touhy Requests With this in mind, could you please save the Touhy correspondence in the 3500 folder? Thanks. Sent from my iPhone Begin forwarded message: From: "McEnany, John (USANYS)" Date: Au ust 2 2020 at 2:30:39 PM EDT To: ' c= 2 )" Cc: "Jones, David (USANYS)" (USANYS)" >, "Kochevar, Steven (USANYS)" Subject: RE: Jeffrey Epstein-Related Touhy Requests Determinations under Touhy are somewhat discretionary and to the extent our Office exercised discretion to give the W something the W wanted, that could be construed as a benefit. Here, it's a benefit to her civil case. You can see how that might be developed on cross. From: Sent: Sunday, August 2, 2020 1:49 PM To: McEnany, John (USANYS) S.; Cc: Jones, David (USANYS) (USANYS) Kochevar, Steven (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests John, Curious about that view — it's not a benefit conferred upon her, in the sense that this avenue to obtain documents is available to literally any person. And the witness herself makes no statements whatsoever in the communications, nor are we providing anything that we aren't also providing to the defense in discovery. Is your view that the fact of production of materials is Giglio? Or that the substance of her attorney's request and the government's responsive letter is Giglio? Just want to make sure we understand the theory. thanks, Alex. EFTA00088120