SDNY prosecution team task list email on trial witnesses, Dec 2020

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¶