EFTA00031090.pdf

68.1 KB

Extraction Summary

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

Document Information

Type: Email thread
File Size: 68.1 KB
Summary

This document is an email chain between officials at the US Attorney's Office for the Southern District of New York (USANYS) dated December 30-31, 2019. The discussion concerns establishing a protocol for handling document requests from plaintiffs suing the Epstein estate, specifically referencing a request from attorney Robbie Kaplan. The officials discuss implementing 'Touhy Requests' and designating a Civil Division point person to manage these inquiries ahead of a January 10 status conference.

People (4)

Name Role Context
Robbie Kaplan Plaintiff's Counsel
Attorney at Kaplan Hecker representing a plaintiff suing Epstein/estate; made a request for documents.
Jeffrey Epstein Subject
Deceased; subject of the investigation and lawsuits mentioned.
Unknown Sender (Redacted) Assistant U.S. Attorney
Author of the initial email regarding Touhy Requests; signature block on page 2 indicates AUSA title.
Unknown Recipient (Redacted) USANYS Official
Recipient of the emails; asked to designate a Civil Division person.

Organizations (3)

Name Type Context
USANYS
U.S. Attorney's Office for the Southern District of New York; employer of email participants.
Kaplan Hecker
Law firm representing a plaintiff.
Civil Division
Division within the DOJ/USANYS intended to handle the Touhy Requests.

Timeline (1 events)

2020-01-10
Status conference for the civil case suing Epstein/estate.
Court
Robbie Kaplan Plaintiffs

Locations (1)

Location Context
Jurisdiction of the U.S. Attorney's Office involved.

Relationships (2)

Robbie Kaplan Adversarial Jeffrey Epstein
Kaplan is counsel for plaintiffs who are suing Epstein and his estate
Redacted Sender Colleagues Redacted Recipient
Both work at USANYS, discussing internal procedures and meeting casually ('swing by').

Key Quotes (4)

"I think you had said we should instruct them to submit Touhy Requests"
Source
EFTA00031090.pdf
Quote #1
"So far we've just gotten the request from one plaintiff's counsel, Robbie Kaplan at Kaplan Hecker, and her request is very narrow"
Source
EFTA00031090.pdf
Quote #2
"we want to set up the system in a way that will work if we get additional and/or more expansive requests going forward"
Source
EFTA00031090.pdf
Quote #3
"We haven't gotten a formal request yet because we haven't told them what form it needs to take."
Source
EFTA00031090.pdf
Quote #4

Full Extracted Text

Complete text extracted from the document (2,375 characters)

From: [Redacted] (USANYS)" <[Redacted]>
To: [Redacted] (USANYS)" <[Redacted]>
Subject: RE: RE: plaintiff counsel request for documents, Epstein case
Date: Tue, 31 Dec 2019 19:04:37 +0000
We haven’t gotten a formal request yet because we haven’t told them what form it needs to take. But I’ll come by.
From: [Redacted] (USANYS) <[Redacted]>
Sent: Tuesday, December 31, 2019 14:04
To: [Redacted] <[Redacted]>
Subject: RE: RE: plaintiff counsel request for documents, Epstein case
Yes, and bring the request
From: [Redacted] <[Redacted]>
Sent: Tuesday, December 31, 2019 2:03 PM
To: [Redacted] (USANYS) <[Redacted]>
Subject: RE: RE: plaintiff counsel request for documents, Epstein case
I am indeed. Want me to swing by?
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] (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.
EFTA00031090
[Page 2]
[Redacted]
Assistant U.S. Attorney
Southern District of New York
[Redacted]
EFTA00031091

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