Date: Fri, 16 Oct 2020 20:33:09 +0000¶
Hi¶
Do you recall where you left things with this firm about¶
Thanks.¶
Sent from my iPhone¶
Begin forwarded message:¶
Colleen,¶
Per our discussion — the protective order is attached, as are the Court’s opinion on this as well as the Government’s strong argument on these issues.¶
thanks.¶
To:¶
| Subject : Re: Follow-up |
|---|
| I am available tomorrow after 1pm (PST). Are your proposed times in PST or EST? Colleen |
| On Thu, Aug 20, 2020 at 9:55 AM |
| wrote: Colleen, I don’t, I’m sorry — I’m unfortunately totally booked today. I could talk at 12:30 or 1:00 tomorrow, or sometime early next week, if that’s better for you? thanks, From: Colleen Sent: Thursda To: Cc: Teri Gibbs IMN I Subject: Re: Follow-up l y.,ave time to speak today around 1pm (PST)? Please let me know. Colleen Wed Au 19 2020 at 6:35 PM wrote: |
| I Colleen, |
| lilting up on the below — please let us know? Thanks very much. |
| From: Sent: Tuesday, To: Colleen Cc: Teri Gibbs ect: ow-up Colleen, |
| We are happy to speak with you — we had only followed up because we were under the impression she was interested in speaking with us. We certainly can discuss issues of witness safety and confidentiality, but we also are not looking to pressure anyone, at all. Please let us know if it makes sense to chat, and if so, what time ranges would work for you later this week or next. |
| From: Colleen Sen To: Cc: |
| ject: e: o ow-up |
| Do you have any time to speak this week? My client is deeply concerned about her personal safety and wishes to maintain her anonymity. |
| Best, |
| Colleen |
| On Thu. Au= 6. 2020 at 10:26 AM wrote: Colleen, |
We wanted to follow up on this from last month. Please let us know? (And obviously we’re past late July now, but we could look at dates and times for an interview this month.) thanks,¶
| From: |
|---|
| Sent: Wednesday, Jul 08 2020 17:30 |
| To: Colleen |
| Cc: Ten Gibbs |
| u Jec o ow-up |
| Colleen, |
| Thanks very much for being in touch, and we would like to speak with Ms. As a threshold |
| question, would it be possible for you to share with us the documents from and email correspondence with |
| Maxwell referenced in your email below? And is there a good date or dates later in July that would work for a |
| phone or videoconference interview? |
| again, |
| From: Colleen • 06 1.11 |
| Sent: Monday, Jul To: |
| Cc: Teri Gibbs |
| ow-up |
| We wanted to follow up on ourprior email and offer to speak with our client |
| As stated earlier, Ms. worked for Ms. Maxwell (and, by extension, Jeffrey |
| Epstein). |
| I confirmed with our client that she is willing to speak with you and wants to fully cooperate with the |
| criminal investigation/action pending against Ms. Maxwell. She could be a valuable witness for you. |
| Please let us know if you would like to speak with our client. We are happy to facilitate this |
| conversation. |
| Best, |
| Colleen |
| On Wed, Jan 29, 2020 at 12:57 PM |
| r wrote: |
| Received, thanks very much. |
| From: Teri Gibbs |
| Sent: Tuesday, Janua 28, 2020 19:08 |
| To: |
| Sulfite: Follow-up |
| Hi |
| as in her possession documents As we discussed last week, our client, |
| from and email correspondence with Ghislaine Maxwell. Thus far, we have received authorization |
| to share the list of office numbers Ms. used during her employment with Ghislaine |
| Maxwell from 2003-2007. Please see attached. |
| Please let us know if you have any questions. |
| Best, |
| Teri |
| rt Wed Jan 22 2020 at 1:48 PM |
| wrote: |
| Will do, speak with you then. Thanks. |
| From: Teri Gibbs Sent: W an 22 2020 16:44 | |
|---|---|
| To: | |
| Colleen | |
| u jec : e: o ow-up | |
| Great. Tomorrow at 12PM PST/3PM EST works. Please call our conference line at | |
| Best, | |
| Teri | |
| On We | Jan 22, |
| wrote: | |
| Teri, I can give you a call at 3:00 p.m. tomorrow (Thursday). Please let me know what number is best to reach you at, and I’ll plan to call you then. | |
| Ns’ | |
| From: Teri Gibbs Sent: Tuesda 21.2020 20:15 | |
| To: | |
| Cc: | |
| Subject: Re ow-up Wonderful,M. I am available tomorrow through Friday from 1PM-3PM EST. Please let me | |
| know what time works best for you. | |
| Best, | |
| Teri | |
| On Tue Jan 21, 2020 at 5:06 PM wrote: | |
| Teri, | |
| We would be happy to set up a call to speak with you and receive the new information—please let us know a few times this week that would work for you. | |
| From: Teri Gibbs | |
| Sen • • To: | |
| Cc: ; Colleen | |
| Su Re: Follow-up | |
| Hi I am following up regarding our cli nt and We | |
| have more information from Ms. that may be important to your investigation. Please let us know if you would like to speak with us over the phone or set up interviews | |
| with either of them. | |
| Best regards, Teri | |
| On Mon, Jan 6, 2020 at 1:12 PM Teri Gibbs > wrote: | |
| Great. Please call our conference line at . You should receive an invitation |
in a few moments from UberConference. You will not need a sign-in pin. Looking forward to our call on Wednesday at 12:30PM PST. Best,¶
• Wednesday (1/8) between 10-11AM PST and 12-2PM PST Please let me know if any of these times work for you. Best regards,¶
Teri¶
On Fri, Dec 20 2019 at 9:55 AM¶
rote:¶
Teri,¶
Thanks for being in touch. In the first instance, before we would request an interview directly, it would be helpful for us to get a full attorney proffer from you about what the client’s information is, what you expect she would convey in an interview, any relevant documentary or other corroborating materials, etc. That way we can make sure we’re not re-victimizing any individual unnecessarily, and be efficient with any necessary follow-up interview of the individual him- or herself. Please let us know when a good time would be for an attorney proffer? And we can figure out scheduling. thanks very much,¶
We have a client who witnessed Prince interactions with= I would like to set up a phone or video interview with the appropriate¶
party to allow our client to make a statement. Please let me know how to proceed. Best regards, Teri Gibbs¶
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Colleen M. M, Esq.¶
To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office.¶
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited.¶
Colleen M. M, Esq.¶
To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office.¶
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited.¶
Colleen M. , Esq.¶
To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office.¶
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited.¶
Colleen M. M, Esq.¶
To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office.¶
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited.¶
Colleen M. M, Esq.¶
To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office.¶
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited.¶
<2020-07-31, GM, signed protective order (docketed).pdf>¶
<2020-07-31, GM, memorandum & order granting government motion.pdf>¶
<2020-07-28, government letter re protective order (docketed).pdf>¶