From: "Kate L. Doniger" <[REDACTED]>
To: "[REDACTED] (USANYS)" <[REDACTED]>
Cc: "[REDACTED]" <[REDACTED]>, Alexandra Conlon <[REDACTED]>, Roberta Kaplan <[REDACTED]>
Subject: RE: Request for Information Relating to Jeffrey Epstein
Date: Thu, 30 Apr 2020 16:44:53 +0000
Thanks, [REDACTED]. That works for us. Speak to you then.
Kate L. Doniger | Kaplan Hecker & Fink LLP
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Thursday, April 30, 2020 12:27 PM
To: Kate L. Doniger <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; Alexandra Conlon <[REDACTED]>; Roberta Kaplan <[REDACTED]>
Subject: RE: Request for Information Relating to Jeffrey Epstein
Kate,
I hope you are keeping well also. Would a call at 1:45 on Monday, 05/04, work? Please call me at [REDACTED], or I can circulate a dial-in if helpful.
Thanks,
[REDACTED]
From: Kate L. Doniger <[REDACTED]>
Sent: Thursday, April 30, 2020 11:15 AM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; Alexandra Conlon <[REDACTED]>; Roberta Kaplan <[REDACTED]>
Subject: RE: Request for Information Relating to Jeffrey Epstein
[REDACTED],
Hope you are keeping well. Thank you very much for this production. We have a few questions for you—are you available tomorrow or next week to discuss? Please let us know what would be convenient for you. Thanks again,
Kate
Kate L. Doniger | Kaplan Hecker & Fink LLP
[REDACTED]
[REDACTED]
[REDACTED]
EFTA00025349
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Tuesday, April 21, 2020 10:55 PM
To: Kate L. Doniger <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; Alexandra Conlon <[REDACTED]>; Roberta Kaplan <[REDACTED]>
Subject: (Not Virus Scanned) RE: Request for Information Relating to Jeffrey Epstein
This message has not been virus scanned because it contains encrypted or otherwise protected data. Please ensure you know who the message is coming from and that it is virus scanned by your desktop antivirus software.
Kate,
Per our conversation earlier today, please find attached a letter responding to your request for information relating to Jeffrey Epstein, as well as the set of documents identified in the letter. I will send the password for the document file separately.
Thank you,
[REDACTED]
From: Kate L. Doniger <[REDACTED]>
Sent: Wednesday, April 15, 2020 9:09 AM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; Alexandra Conlon <[REDACTED]>; Roberta Kaplan <[REDACTED]>
Subject: RE: Request for Information Relating to Jeffrey Epstein
Thanks very much, [REDACTED].
Kate L. Doniger | Kaplan Hecker & Fink LLP
[REDACTED]
[REDACTED]
[REDACTED]
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Wednesday, April 15, 2020 12:10 AM
To: Kate L. Doniger <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; Alexandra Conlon <[REDACTED]>; Roberta Kaplan <[REDACTED]>
Subject: RE: Request for Information Relating to Jeffrey Epstein
Kate,
Thank you for checking in. I hope you are keeping well also. I do not think we need any additional information from you at this time. I hope to be able to provide an update early next week.
Thanks,
[REDACTED]
From: Kate L. Doniger <[REDACTED]>
Sent: Tuesday, April 14, 2020 3:01 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; Alexandra Conlon <[REDACTED]>; Roberta Kaplan <[REDACTED]>
Subject: RE: Request for Information Relating to Jeffrey Epstein
[REDACTED],
We hope that you are keeping well in this very challenging time.
We completely understand that all things are in flux these days, but we just wanted to check in with you about our request and whether there is any other information you need from us. If it would be helpful to set up a call to discuss, we are available at your convenience.
Best,
Kate
Kate L. Doniger | Kaplan Hecker & Fink LLP
[REDACTED]
[REDACTED]
[REDACTED]
EFTA00025350
EFTA00025351
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Thursday, February 27, 2020 7:23 PM
To: Alexandra Conlon <[REDACTED]>; Roberta Kaplan <[REDACTED]>
Cc: Kate L. Doniger <[REDACTED]>; [REDACTED] <[REDACTED]>
Subject: RE: Request for Information Relating to Jeffrey Epstein
Alexandra and Robbie,
Thank you for this. I will contact you regarding the request.
Thanks,
[REDACTED]
From: Alexandra Conlon <[REDACTED]>
Sent: Tuesday, February 25, 2020 7:54 PM
To: [REDACTED] (USANYS) <[REDACTED]>; Roberta Kaplan <[REDACTED]>
Cc: Kate L. Doniger <[REDACTED]>; [REDACTED] <[REDACTED]>
Subject: RE: Request for Information Relating to Jeffrey Epstein
SENT ON BEHALF OF ROBERTA KAPLAN
AUSA [REDACTED],
Thank you for contacting us. Attached please find a Touhy letter and supporting exhibit requesting documents from the Department of Justice in connection with our pending litigation against Jeffrey Epstein's estate.
We are happy to schedule a time to talk if it would be helpful to discuss our request.
Best Regards,
Robbie
Alexandra Conlon | Kaplan Hecker & Fink LLP
[REDACTED]
[REDACTED]
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Monday, January 6, 2020 6:59 PM
To: Roberta Kaplan <[REDACTED]>
Cc: Kate L. Doniger <[REDACTED]>; Alex Conlon <[REDACTED]>
Subject: Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan,
Please find attached a letter regarding the request you discussed with AUSA [REDACTED] for certain information relating to Jeffrey Epstein. As stated in the letter, please contact me once you have had a chance to review the letter if you would like to discuss the issues therein further.
Thanks
[REDACTED]
Assistant United States Attorney
Southern District of New York
[REDACTED]
[REDACTED]
[REDACTED]
[Standard email disclaimer text regarding confidential/attorney-client privilege repeated multiple times]
EFTA00025352
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