EFTA00025495.pdf

181 KB

Extraction Summary

5
People
3
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Email chain
File Size: 181 KB
Summary

This document is an email chain between the law firm Kaplan Hecker & Fink LLP (representing a party suing Jeffrey Epstein's estate) and the US Attorney's Office for the Southern District of New York (USANYS). Spanning from January to April 2020, the correspondence details the law firm's submission of a 'Touhy letter' to the DOJ to request information relevant to their litigation against the Epstein estate. The chain concludes with the US Attorney's office providing a response letter and a set of encrypted documents to the law firm.

People (5)

Name Role Context
Kate L. Doniger Attorney
Kaplan Hecker & Fink LLP; communicating with US Attorney's office regarding information request.
Roberta Kaplan Attorney
Kaplan Hecker & Fink LLP; referred to as 'Robbie'; lead on the request.
Alexandra Conlon Attorney/Staff
Kaplan Hecker & Fink LLP; sent Touhy letter on behalf of Roberta Kaplan.
[Redacted] Assistant United States Attorney (AUSA)
USANYS (Southern District of New York); handling the government response to the information request.
Jeffrey Epstein Subject
Subject of the information request and pending litigation against his estate.

Organizations (3)

Name Type Context
Kaplan Hecker & Fink LLP
Law firm representing the party requesting information.
USANYS
United States Attorney's Office for the Southern District of New York.
Department of Justice
Federal agency from which documents are being requested.

Timeline (2 events)

2020-02-25
Submission of Touhy letter requesting documents from DOJ.
New York
2020-04-21
Production of documents from USANYS to Kaplan Hecker & Fink LLP.
Email

Locations (1)

Location Context
Jurisdiction of the US Attorney's office involved.

Relationships (2)

Kaplan Hecker & Fink LLP Adversarial/Litigation Jeffrey Epstein Estate
Mention of 'pending litigation against Jeffrey Epstein's estate'.
Kaplan Hecker & Fink LLP Information Request USANYS
Correspondence regarding 'Request for Information Relating to Jeffrey Epstein' and Touhy letter.

Key Quotes (3)

"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."
Source
EFTA00025495.pdf
Quote #1
"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."
Source
EFTA00025495.pdf
Quote #2
"I will send the password for the document file separately."
Source
EFTA00025495.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (5,162 characters)

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 15:14:39 +0000
[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]
[Redacted]
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]
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]
From: [Redacted] (USANYS) <[Redacted]>
Sent: Thursday, February 27, 2020 7:23 PM
To: Alexandra Conlon <[Redacted]>; Roberta Kaplan <[Redacted]>
Cc: Kate L. Doniger <[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]
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]
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify the sender immediately and destroy all copies of the message from your computer system. Thank you.

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