EFTA00022144.pdf

72.7 KB

Extraction Summary

3
People
3
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Email thread
File Size: 72.7 KB
Summary

This document is an email thread from December 30-31, 2019, between Assistant U.S. Attorneys in the Southern District of New York. They discuss establishing a protocol (specifically Touhy Requests) for handling document requests from civil plaintiffs suing Jeffrey Epstein and his estate. The emails specifically mention a narrow request from attorney Robbie Kaplan and reference a status conference scheduled for January 10, 2020.

People (3)

Name Role Context
Jeffrey Epstein Deceased Subject
Mentioned in subject line and body regarding lawsuits against his estate and his suicide.
Robbie Kaplan Plaintiff's Counsel
Lawyer at Kaplan Hecker requesting documents; described as making a 'very narrow' request.
[Redacted] Assistant U.S. Attorney (USANYS)
Senders and recipients of emails discussing protocol for handling civil requests.

Organizations (3)

Name Type Context
USANYS
U.S. Attorney's Office for the Southern District of New York (email domain/signature).
Kaplan Hecker
Law firm representing a plaintiff suing Epstein.
Civil Division
Division within the DOJ/US Attorney's office handling civil requests.

Timeline (2 events)

2019-08-10
Epstein's suicide
New York
2020-01-10
Status conference for case involving Robbie Kaplan
Unknown (Court)

Locations (1)

Location Context
Jurisdiction of the Assistant U.S. Attorney.

Relationships (2)

Robbie Kaplan Legal Adversary Jeffrey Epstein
Counsel for plaintiffs who are suing Epstein and his estate
USANYS Investigative Jeffrey Epstein
References to 'our investigation' and criminal team

Key Quotes (4)

"requests from counsel for plaintiffs who are suing Epstein and his estate"
Source
EFTA00022144.pdf
Quote #1
"instruct them to submit Touhy Requests"
Source
EFTA00022144.pdf
Quote #2
"Robbie Kaplan at Kaplan Hecker, and her request is very narrow"
Source
EFTA00022144.pdf
Quote #3
"the Civil Division AUSA who handled the requests from counsel following Epstein's suicide was [Redacted]"
Source
EFTA00022144.pdf
Quote #4

Full Extracted Text

Complete text extracted from the document (2,867 characters)

From: [Redacted] (USANYS) <[Redacted]>
To: [Redacted] (USANYS) <[Redacted]>
Cc: [Redacted] (USANYS) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>; [Redacted] <[Redacted]>
Subject: RE: RE: plaintiff counsel request for documents, Epstein case
Date: Tue, 31 Dec 2019 19:43:01 +0000
[Redacted],
Following up on our conversation from a few minutes ago, the Civil Division AUSA who handled the requests from counsel following Epstein's suicide was [Redacted]. As I mentioned, the criminal team is happy to assist any civil AUSA(s) who are the point of contact, and we do think it would make sense to have a formal division to ensure that any necessary protocol is fully established and followed in connection with requests, including this current one, which we understand to be very narrowly tailored. As also discussed, we're happy to take a look at a draft letter to counsel explaining what their formal request should include (nature and status of litigation; what the requests are; and how the requested materials are pertinent to the active litigation, etc.).
Please let us know if any additional information would be helpful, and thanks very much.
[Redacted]
From: [Redacted] (USANYS) <[Redacted]>
Sent: Tuesday, December 31, 2019 12:42
To: [Redacted] <[Redacted]>
Subject: RE: RE: plaintiff counsel request for documents, Epstein case
You in today?
From: [Redacted] <[Redacted]>
Sent: Monday, December 30, 2019 3:49 PM
To: [Redacted] (USANYS) <[Redacted]>
Cc: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: plaintiff counsel request for documents, Epstein case
[Redacted],
Following up on our brief discussion of this issue earlier this month, I wanted to see if you had any additional thoughts on how to handle requests from counsel for plaintiffs who are suing Epstein and his estate who ask us for information or materials in connection with our investigation – I think you had said we should instruct them to submit Touhy Requests, and that you would designate a Civil Division person to whom we could have them direct those requests. If that's right, could you please let us know who that person will be? So far we've just gotten the request from one plaintiff's counsel, Robbie Kaplan at Kaplan Hecker, and her request is very narrow but we want to set up the system in a way that will work if we get additional and/or more expansive requests going forward. And we would like to let her know how she should proceed relatively soon because that case has a status conference on January 10 and I think they'd like to make the request before then.
Please let us know if any other information would be helpful, and thanks as always.
[Redacted]
Assistant U.S. Attorney
Southern District of New York
[Redacted]
EFTA00022144
EFTA00022145

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