EFTA00074876¶
¶Based on media reports today it looks like you filed the civil lawsuit? I don’t think we realized that was imminent — could we ask you to please send us a copy of the filing? I don’t yet see it on PACER.
¶Great, thanks very much. We’ll likely start with siblings and mother and then go from there. As soon as we have a sense of when it would be productive for us to return for a follow-up meeting with we’ll reach out — as I mentioned, we’re hoping that will be sometime in January, but just depending on how quickly we’re able to schedule these discussions. And as always, please don’t hesitate to let us know if anything comes up in the meantime.
[ - yes, all good to contact those folks. Thanks for checking in. ]¶
¶Robert S. Glassman
¶Panish Shea & Boyle
¶psblaw.com
¶On Dec 30, 2019, at 1:10 PM,
wrote:¶
¶Robert,
¶Following up on our most recent meeting with you and we wanted to confirm that it’s alright for us to begin reaching out this week to the contacts she identified for us — in particular, we would initially expect to contact , and , and then ,
We also wanted to see if it we are able at this stage to contact her mother, who is potentially a key witness — I know had wanted to speak with her mother in advance of us doing that. Please let us know if it’s alright to make those calls? And separately, if you could please let us know if her brother has happened to have any contact with since we last spoke — no problem at all if not, but I think she mentioned that was a possibility so wanted to check.¶
¶Thanks very much, and hope you’re having a good holiday season.
EFTA00074877¶
¶Subject: RE: SDNY investigation
¶Totally understand, just wanted to ask. We’ll see you Monday at 11:00. And thanks for that additional info as well.
¶-----Original Message-----
¶Sent: Friday, December 13, 2019 16:14
¶Subject: Re: SDNY investigation
¶unfortunately, we can’t do earlier than 11. She just needs time to get to my office after taking care of kid stuff etc.
¶Re the mom, my understanding is that she is overseas somewhere. Pretty sure she’s not in the US. I will find out and we can chat about it on Monday.
¶Robert S. Glassman
¶Panish Shea & Boyle
¶psblaw.com
¶On Dec 12, 2019, at 1:30 PM,
wrote:¶
¶Robert,
¶We wanted to ask if it might be possible to start at 10:00 on Monday rather than 11:00? If not, we totally understand (I think you may have wanted time to meet with her before starting with us) but wanted to check.
Separately, I know left you a message earlier, but since we’re emailing about this we can just ask — we were wondering if it might be possible to tell us where mother currently lives? Not her literal address, but just city and/or state — we don’t have any intention of contacting her before we speak to you and your client in person, but just for our longer-term logistical planning, we’re wondering where we would be headed if and when an interview of her were to be appropriate.¶
EFTA00074878¶
¶Subject: RE: SDNY investigation
¶Confirmed, thanks — we’ll see you then. And just on substance, I think we mentioned these topics when we spoke on the phone earlier, but just to refresh, I expect we’ll want to talk through some additional specifics on travel, we’ll talk more about other steps we’ll be looking to take in our investigation for corroboration and what the appropriate timing and format of that would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent is comfortable with that at this stage. And we’ll also likely refresh on some other topics as well, but just to flag some of the more immediate areas we’ll expect to cover. Let us know if it’s useful to chat again before Monday, otherwise we’ll see you then.
¶Subject: RE: SDNY investigation
¶Web: www.psblaw.com
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¶-----Original Message-----
¶From: ) [mailto:>
¶Sent: Wednesday, December 11, 2019 8:26 AM
¶To: Robert Glassman <
EFTA00074879¶
¶Subject: RE: SDNY investigation
¶Robert,
¶That’s great, thanks very much. Do you have a preference on timing? Anytime that morning starting at 10:00 a.m. or later would be fine for us, or we could also start early afternoon if that’s easier—whatever you and prefer. And our hope is that we’d be able to cover everything on Monday, but we’ll also be available on Tuesday if that ends up being useful as well.
¶Monday morning works at my office. Tuesday may also work too if you need more time. But confirm for Monday.
¶Robert S. Glassman
¶Panish Shea & Boyle
¶psblaw.com
¶On Dec 10, 2019, at 9:35 AM,
wrote:¶
¶Robert,
¶Following up on our call, in terms of logistics, we can come to California to meet with anytime this coming Sunday, Monday, or Tuesday, if any of those work? Also, if it’s at all possible to either set aside a significant amount of time on one day or—possibly preferably—a few hours on two consecutive days (and if so, we could do the second meeting on Wednesday if that’s helpful), that will allow us to review relevant case notes, do quick research, or anything else that would provide for helpful follow-up where we’d just need a little time between discussion sessions. And as always, happy to discuss via phone if that’s helpful.
EFTA00074880¶
¶Following up on our discussion a couple weeks ago, would it make sense to have a quick call later this week or early next to check in on current status? We also have one additional data point we’d like to convey as well, at your convenience.
EFTA00074881¶
EFTA00074882¶