| From: Louise Scott ci
yl "cl
To:
Cc:
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Date: Tue, 07 Jul 2020 14:50:39 +0000
Inline-Images: image0bcff8.PNG; image3f6570.PNG |
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| Hi |
| Many thanks for confirming. |
| Can this call please take place via BlueJeans? It is a video conferencing application that we are using and I will send
through an invite which will enable you to connect to the meeting. |
| Could I just confirm the attendees please —
and yousrselfqa ? |
| Kyle Philips another partner of the firm will also be in attendance for the call. |
| I look forward to hearing. |
| Kind regards
Louise |
| Louise Scott
Executive Assistant
D:
Click here for information relating
to Covid-19 business impacts
C.',Fieldfisher
Logo
b |
| |
| From:
Sent: Tuesday, July 7, 2020 3:01 PM
To: Louise Scott
Cc: Jill Greenfield
>
°c
Subject: Re: Epstein investigation l[FFW-DOCS.FID60033751 |
Louise,
Thanks very much, that time works for us. What is the best number to reach Jill at that time— or is there a conference line she would prefer to use?
Thanks,
Sent from my iPhone
| On Jul 7, 2020, at 7:57 AM, Louise Scott ffi
wrote: |
|------------------------------------------------------------------------------------------------|
| Dear |
| Many thanks for your email. |
| Jill would be free to speak on Thursday at 2pm (UK time) — would this be suitable for you all? |
| Kind regards
Louise |
| Louise Scott
Executive Assistant |
| Click here for information relating to Covid-19 business impacts |
| Fieldfisher Logo |
|
Sent: Monday, July 6, 2020 11:50 PM |
| To: Jill Greenfield |
| Cc: Louise Scott
> |
| >
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375] |
Hi Jill,
I hope you're doing well. We continue to be interested in speaking with your client in connection with our investigation, and we think it would be helpful to check in and discuss how best to proceed in light of the pandemic. Are you available for a call this week? We are generally available, so if you could please let us know what times would work for you for a call, that would be great.
Thanks very much,
Assistant United States Attorney Southern District of New York
| From:
I < | | > | |
|-----------------------------------------|---|---|---|
| Sent: Wednesday, March 11, 2020 9:46 PM | | | |
| To: Jill Greenfield | | | |
| Cc: Louise Scott | > | | > |
### ) c > Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Following up on the below, given the development of the virus pandemic over the past week, any foreign travel for us is completely shut down. We certainly will plan to come to the U.K. whenever we are permitted, but in the interim this makes it even more valuable to get even a summary of what your client would expect to convey to us. Would it be possible to set up a call for later this week or sometime next week? And profound apologies for the inconvenience in changing plans, we certainly don't want to cause additional stress or anxiety to your client, the circumstances are just completely beyond our control.
## thank you,
| From: | |
|----------------------------------------------------------|--|
| Sent: Thursday, March 05, 2020 13:13 | |
| To: Jill Greenfield | |
| Cc: Louise Scott | |
| ) | |
| Subject: RE: Epstein investigation [FFW-DOCS.FID6003375] | |
Just to clarify, would it be possible for you to provide us even a very general or high-level summary of what she has told you? We ordinarily don't go into interviews completely blind when witnesses have counsel — and the Weinstein investigation had a great number of problems that we have been able to avoid. And separately, we'll of course keep you updated on our approval process as well.
thanks again,
IM•
| From: Jill Greenfield | | |
|----------------------------------------------------------|--|--|
| Sent: Thursday, March 05, 2020 04:20 | | |
| To: | | |
| Cc: Louise Scott
) | |
|----------------------------------------------------------|--|
| Sent: Wednesday, March 4, 2020 5:04 PM | |
| To: Jill Greenfield .ic
> | |
| Cc: Louise Scott | |
| | |
| Subject: RE: Epstein investigation [FFW-DOCS.FID6003375] | |
That's great, thank you for letting us know, and we'll check on that right away and get back to you as soon as possible. The only wrinkle, which unfortunately is completely beyond our control, is that there is now some talk of government international travel being prevented due to the coronavirus situation, but we'll talk to the relevant people here immediately.
One thing that would be extremely helpful for us in the near-term, including in terms of getting approvals here — and we talked about this on the phone as well — would be to get an attorney proffer about your understanding of generally what information you expect your client will convey on the subjects we've spoken about? We completely understand that it's best to have her tell her story directly to us, but in terms of our preparation it's often very useful for both us and the witness for us to have had a conversation with counsel in the first instance. Would it be possible to set up a call to have that discussion? We could do as soon as tomorrow or Friday, or also next week.
Thanks very much,
| From: Jill Greenfield | | | |
|----------------------------------------------------------|----|--|--|
| Sent: Wednesday, March 04, 2020 11:46 | | | |
| To: | | | |
| Cc: Louise Scott < | >; | | |
| ) <
> | | | |
| Subject: RE: Epstein investigation [FFW-DOCS.FID6003375] | | | |
Hi
There is the possibility of a meeting on the 19th March if you are able to come to London. Could you let me know please?
Kind regards
Jill
Jill Greenfield Partner
D:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
kimage001.jpod
| From:
) '< | | > | |
|---------------------------------------|-------------------|---|--|
| Sent: Tuesday, March 3, 2020 11:17 PM | | | |
| To: Jill Greenfield .'z | > | | |
| Cc: Kyle Phillips < | >; Louise Scott < | | |
| | | | |
| Subject: RE: Epstein investigation | | | |
We wanted to quickly follow up since I think you and I last spoke a little over a week ago—understand if you are still discussing with your client, just wanted to check in, and we're happy to provide any additional information that might be useful, as always.
thank you,
| From: Jill Greenfield < |
|-------------------------------------------------------------------|
| Sent: Saturday, February 22, 2020 17:09 |
| To:
(USANYS) |
| Cc: Kyle Phillips <=
::.; Louise Scott < |
| >;
(USANYS) <
(USANYS) c: |
| Subject: Re: Epstein investigation |
| Thanks |
| Understood |
| I will call tomorrow |
| Regards |
| Jill Greenfield |
| Partner |
| D
M |
| |
| Personal Injury Team of the Year - Solicitors Journal Awards 2017 |
| kimage00 I .jpgd |
| Sent from my iPhone |
| On 22 Feb 2020, at 21:51,
(USANYS) <
> wrote: |
| Jill, |
No problem at all, we understand this takes time, and we appreciate you getting back to us, and we're very grateful that your client is open to speaking with us.
On your questions, we are certainly fine with the first two questions / requests — we're happy to meet with you and your client in an initial conversation, during which we can do the kind of introductions and explanations we've done with you (and that we do with all victim witnesses we meet), including answering any questions to the best of our ability, and then to take a break and have a more substantive discussion later on.
Regarding the friend, does that individual also represent her as counsel? We aren't normally able to include individuals in addition to the witness and counsel in an interview—what does sometimes work is for someone who is providing support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness wants to speak with that person, which would of course be totally fine in this instance. Or if he represents her in his capacity as an attorney then he of course could be in the interview in that role (with the only caveat that we would just want to confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not able to pay for third parties (including counsel) to travel in connection with witness interviews, though — if it's preferable, we certainly could pay for your client's travel to the U.S. for the interview, including airfare and lodging, if that makes it easier for the friend to be present? And we're happy to discuss any of this further by email or phone if that's useful — I'll be at my desk for the next several hours and most of tomorrow, at or we could also set a time to chat, whatever would be helpful.
thank you,
| From: Jill Greenfield < | |
|-----------------------------------------|------------------|
| Sent: Saturday, February 22, 2020 13:55 | |
| To:
(USANYS) | |
| Cc: Kyle Phillips | ; Louise Scott < |
| >;
(USANYS) | (USANYS) < |
| | |
Subject: RE: Epstein investigation
Hello
Apologies for the slight delay. My client is willing to help but asks the following:
- That there be a morning meeting at which introductions with a discussion as to the investigation and my clients involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist.
- In the afternoon and after a break, my client would be willing to answer questions, in so far as she can.
- That a friend of hers be allowed to be present as well. However that friend is based in the US and would need to be flown over to London. He is a US lawyer.
Perhaps you could let me know if this is possible?
Kind regards,
Jill
Jill Greenfield
Partner D: M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
| kimage001.jpod |
|-------------------------------------------|
| From:
)
(USANYS) |
| Sent: Saturday, February 15, 2020 7:08 PM |
| To: Jill Greenfield c
› |
| Cc: Kyle Phillips O;
Louise Scott |
| (USANYS)
(USANYS) |
| Subject: RE: Epstein investigation |
| Understood —thanks very much. |
| |
| From: Jill Greenfield |
| Sent: Saturday, February 15, 2020 07:22 |
| To:
(USANYS) |
| Cc: Kyle Phillips O;
Louise Scott |
| (USANYS) <
>
(USANYS) |
| Subject: Re: Epstein investigation |
Thanks
This is helpful. I've gone back to my client with this. I will be back in touch shortly.
Regards
Jill
Jill Greenfield
Partner D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
kimage003.jpgd
Sent from my iPhone
On 14 Feb 2020, at 21:43, (USANYS) < > wrote:
Jill,
Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding some of the additional follow-up questions you asked, and to describe in more detail for your client how we would expect to approach any discussion with your client if she were comfortable meeting with us.
The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the decision to meet with us but also as to any topic or question—your client would be absolutely free to determine what topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything that would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell
her, as we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is no problem at all.
In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves, explained the status of our investigation, talked about how a discussion would proceed if your client ended up being comfortable with that, and answered in person any questions she. We have done that previously, where we do the talking rather than asking questions in an initial meeting, and that would of course be without any requirement for anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are able to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or victimization she experienced. We wrote in our first email that we would primarily be interested in talking about topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as always we would be guided by her comfort level.
In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell you in advance if there came a time when we thought that might be important to address, and how we could facilitate that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure you that every one of us has now spoken with dozens of victims in this case, and every one of us has extensive experience more generally working with victims and working on cases involving sex offenses. We are proud of how we have been able to work with victims in this case especially, given all of the circumstances, and we absolutely would take the same sensitive approach with your client as we have with the many other victims in this case who have spoken with us.
Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how our process works, and answer any questions your client has in person, we would absolutely be happy to do that with no obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could just address the general subject of her employment, for example. But no obligation and no pressure. We continue to appreciate your and her willingness to even broach the possibility of a discussion, and we hope this is helpful.
thank you very much,
IM•
Assistant U.S. Attorney Southern District of New York
| From:
(USANYS) | |
|-------------------------------------------------------|--|
| Sent: Saturday, February 08, 2020 14:25 | |
| To: Jill Greenfield | |
| ; Louise Scott
Cc: Kyle Phillips | |
| (USANYS) <
>;
(USANYS)