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 employee (likely retired) who managed donor relations with Epstein/can authenticate documents
○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 toto make surehas searched all her emails for relevant communications
○ 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)
Potentially re-interview
Team will review 302 and schedule follow-up interview
will contactregarding an interview (within two weeks)
• Meet with ○ Discuss with chiefs tomorrow re: superseder timing • Interview ○ Ask agents to contact and interview him ( – within 2 weeks) - Re-interview (with counsel) - Ask agents to contact him re: appointed counsel –within two weeks) - • Interview ○ Talk to agents about an interview, not a high priority ( ) - Interview - 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 other individuals on flights w/
• Interview and other individuals on flights w/ ○ 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 mother ○ will ask agents to interview by phone EFTA00040343 - Investigate immigration records/travel records re: o will take a look and work with agents - Interview - will call Sigrid about a potential interview - Review deposition transcripts for GM (keeping in mind SOL is approaching) - will send SOL reminder • Tip-line leads that flagged will flag for agents **Sent:** Wednesday, November 11, 2020 4:25 PM Subject: RE: Agenda Here’s the task list, based on our conversation: - Relativity review of GM emails: - Relativity review of GMI 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 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. O 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 o will handle outreach to PBPD (within one month) - Potentially interview client - will review Relativity and set up interview (two weeks) - Potentially re-interview o Team will review 302 and schedule follow-up interview o ■ will contact ■ regarding an interview (within two weeks) - Meet with o Discuss with chiefs tomorrow re: superseder timing - Interview - Ask agents to contact and interview him (within 2 weeks) - Re-interview (with counsel) - Ask agents to contact him re: appointed counsel (–within two weeks) - Interview - Talk to agents about an interview, not a high priority ( - Interview - 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 other individuals on flights w/ o will talk to agents about approaching them EFTA00040344 will take a look and work with agents - Review deposition transcripts for GM (keeping in mind SOL is approaching) will send SOL reminder **Sent:** Friday, November 6, 2020 2:12 PM Thanks very much, ! This all looks right to me and makes sense. If we are pushing this past Monday, I’d ask that it be Wednesday afternoon, or anytime Thursday, please. I’ve got a lengthy grand jury presentation to make on Tuesday. 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: *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. EFTA00040345 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 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 has searched all her emails for relevant communications - Potentially interview client - Potentially re-interview - Meet with • Interview • Interview • Interview - Re-interview - Interview - 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 (with counsel) - Interview - Review deposition transcripts for GM (keeping in mind SOL is approaching) • Tip-line leads that flagged Assistant United States Attorney Southern District of New York EFTA00040346