From: To: Subject: RE: Agenda Date: Mon, 07 Dec 2020 16:40:11 +0000 Hi all—checking in on this, I've highlighted tasks that are completed or in motion. Let me know if I've missed anything. None of this is time-sensitive, I'm mostly just checking in to stay organized, so no rush on anything. - Relativity review of GM emails: - o Team will split a batch review as a shared project, which will commence after we complete all Relativity review for discovery purposes. - Identify an Interlochen employee (likely retired) who managed donor relations with Epstein/can authenticate documents - o Records custodian for student files can be dealt with closer to trial. - will contact counsel to begin discussing, and to follow up on our last conversation about records. (Within two weeks) - Identify a PBPD detective who can authenticate items recovered from search of PB house - will handle outreach to PBPD (within one month) - Talk to to make sure has searched all her emails for relevant communications - o1 will handle and give a heads up they will contact her mother (within two weeks) - Potentially interview client - o will review Relativity and set up interview (two weeks) - Potentially re-interview - o Team will review 302 and schedule follow-up interview - will contact regarding an interview (within two weeks) - Meet with - 0 Discuss with chiefs tomorrow re: superseder timing - Interview - 0 Ask agents to contact and interview him (—within 2 weeks) - Re-interview (with counsel) - 0 Ask agents to contact him re: appointed counsel ( —within two weeks) - Interview - 0 Talk to agents about an interview, not a high priority - Interview Jo Jo Fontanella - will contact his attorney re in person interview - Re-interview - will contact his attorney re in person interview in January - will review emails in Relativity - Interview and and other individuals on flights w/ - o1 will talk to agents about approaching them - Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including (within one month) - Interview o1 mother will ask agents to interview by phone - Investigate immigration records/travel records re: | will take a look and work with agents | |----------------------------------------------------------------------------------------------------------------------------------------------| | • Interview I. | | will call Sigrid about a potential interview | | • Review deposition transcripts for GM (keeping in mind
is approaching) | | will send
reminder
o1 | | • Tip-line leads that
flagged | | will flag for agents
o1 | | From: | | Sent: Wednesday, November 11, 20204:25 PM | | To: | | Subject: RE: Agenda | | Here's the task list, based on our conversation: | | • Relativity review of GM emails: | | o Team will split a batch review as a shared project, which will commence after we complete all Relativity
review for discovery purposes. | | • Identify an Interlochen employee (likely retired) who managed donor relations with Epstein/can authenticate
documents | | o Records custodian for student files can be dealt with closer to trial. | | will contact counsel to begin discussing, and to follow up on our last conversation about records.
•
(Within two weeks) | | • Identify a PBPD detective who can authenticate items recovered from search of PB house | | will handle outreach to PBPD (within one month) | | to make sure. has searched all her emails for relevant communications
• Talk to | | will handle and give a heads up they will contact her mother (within two weeks)
• | | • Potentially interview
client | | will review Relativity and set up interview (two weeks)
o | | • Potentially re-interview
o Team will review 302 and schedule follow-up interview | | will contact
•
regarding an interview (within two weeks) | | • Meet with | | o Discuss with chiefs tomorrow re: superseder timing | | • Interview | | o Ask agents to contact and interview him (
— within 2 weeks) | | (with counsel)
• Re-interview | | o Ask agents to contact him re: appointed counsel (_—within two weeks) | | • Interview _
— | | o Talk to agents about an interview, not a high priority ( | | • Interview Jo Jo Fontanella | | will contact his attorney re in person interview | | • Re-interview | | will contact his attorney re in person interview in January
will review emails in Relativity | | and other individuals on flights w/
• Interview
and
will talk to agents about approaching them
• | | • Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including | | (within one month) | | | | | | | | mother
• Interview | | will ask agents to interview by phone
o | | • Investigate immigration records/travel records re: | |---------------------------------------------------------------------------------------------------------------------------| | will take a look and work with agents
o | | • Interview I. | | will call Sigrid about a potential interview | | • Review deposition transcripts for GM (keeping in mind IN is approaching) | | will send
•
reminder | | • Tip-line leads that
flagged | | will flag for agents
o | | From: | | Sent: Friday, November 6, 2020 2:12 PM | | To: | | Subject: RE: Agenda | | ! This all looks right to me and makes sense. If we are pushing this past Monday, I'd ask that it be
Thanks very much, | | Wednesday afternoon, or anytime Thursday, please. I've got a lengthy grand jury presentation to make on Tuesday. | | From: | | Sent: Friday, November 6, 2020 2:09 PM | To: Subject: Agenda Team, In preparation for our call (which we can reschedule to a time following the discovery deadline), I wanted to send around a list of topics to discuss for potential next steps. I'm sure I've missed some items, but this is a starting point at a least. For context, I think we currently expect to call at least the following witnesses at trial: >; - *Records custodian from Interlochen - *Records custodian from the Professional Children's School - *Court reporter(s) from GM depositions *We haven't identified/spoken to these witnesses yet, so that's on the trial prep to-do list as well. The following are some potential next steps — either individuals to interview or re-interview, records to search for/identify, and so forth. - Relativity review of GM emails - Identify an Interlochen employee (likely retired) who managed donor relations with Epstein/can authenticate documents - Identify a PBPD detective who can authenticate items recovered from search of PB house - Talk to to make sure I. has searched all her emails for relevant communications - Potentially interview client - Potentially re-interview - Meet with - Interview - Interview - Interview Jo Jo Fontanella - Re-interview - Interview and - Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including - Interview mother - Investigate immigration records/travel records re: - Re-interview IM (with counsel) - Interview. - Review deposition transcripts for GM (keeping in mind IMI is approaching) - Tip-line leads that flagged Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007