KAPLAN HECKER & FINK LLP VIA E-MAIL United States Attorney Southern District of New York Geoffrey S. Berman do Assistant United States Attorney 350 FIFTH AVENUE I SUITE 7110 NEW YORK, NEW YORK 10118 TEL (212) 763-0883 I FAX (212) 564-0883 WWW.KAPLANHECKER.COM DIRECT DIAL 212.763.0884 DIRECT EMAIL rkaplan©kaplanhecker.com February 25, 2020 Re: Touhy Request for Information Relating to Jeffrey Epstein Dear U.S. Attorney Berman: We write on behalf of a plaintiff, proceeding as Jane Doe, in a lawsuit against the estate of Jeffrey Epstein that is pending in the Southern District of New York captioned as Doe v. Indyke et at, No. 19-cv-8673-KPF (S.D.N.Y.).' As you instructed in your letter of January 6, 2020, and pursuant to 28 C.F.R. § 16.22, we are submitting this written demand to obtain records from the Department of Justice (the "Department") that were acquired or compiled by Department employees in the performance of their official duties. A. The Nature of the Litigation Our client, Jane Doe, alleges that Jeffrey Epstein repeatedly sexually abused her in his Upper East side mansion beginning around 2002, when Doe was only fourteen years old, until approximately 2005. See Complaint in Doe v. Indyke et al., No. 19-cv-8673-KPF (S.D.N.Y.), Doc. No. 1 (Sept. 18, 2019). Because Doe was a child at the time of her abuse, which took place more than 15 years ago, Doe is largely without documentary evidence of Epstein's crimes against her. However, we believe that in the course of your Office's criminal investigation and prosecution of Epstein's sex trafficking conspiracy, as described in the indictment in United States of America v. Jeffrey Epstein, 19-cr-490-RMB (the "Indictment"), your office collected 1. Jane Doe's identity is known by the prosecutors who represented the Government in United States of America v. Jeffrey Epstein, 19-cr-490-RMB. We are available to discuss her identity with you. EFTA00103491