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.
| 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.
|
| 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.
|
| Location | Context |
|---|---|
|
Jurisdiction of the U.S. Attorney's Office involved.
|
"I think you had said we should instruct them to submit Touhy Requests"Source
"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
"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
"We haven't gotten a formal request yet because we haven't told them what form it needs to take."Source
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