| 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 to to make sure has 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 contact | regarding 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¶