Robert,¶
Wanted to follow up on the below in case it was still useful to chat — some combination of the team will be around next week if you want to have a call.¶
Separately, we’re continuing to move forward with the investigation, including interviews with family members, and we wanted to see if we might be able to put something on the calendar to come talk with again once we’ve completed those steps. Would it work for you and her to meet anytime noon or later on February 19? Or if not the 19th, any availability on the 20th or 21st?¶
Robert,¶
Apologies for the belated reply, it’s been a crazy week for us, but we’d be happy to talk. We should be generally available tomorrow (Friday) until about 2 p.m. our time, or also early next week if that’s easier.¶
thanks,¶
Thanks I ended up seeing these too.¶
Our judge is John Koeltl and the magistrate is Barbara Moses.¶
EFTA00082459¶
Moskowitz already reached out to us.¶
Is there a good time to chat?¶
Robert S. Glassman¶
Panish Shea & Boyle¶
psblaw.com¶
On Jan 20, 2020, at 1:11 PM,
¶
Robert,
¶
Thanks very much for sending the complaint, we appreciate it. We’ll try to keep an eye on the docket, but if you wouldn’t mind letting us know when a judge is assigned, that would also be helpful. In terms of media, it was covered in the Daily News on Friday, here:
¶
https://www.nydailynews.com/new-york/ny-epstein-trump-victim-suit-20200118-
¶
m6sqsa2h7venpf5uewjrkvigo4-story.html¶
And then picked up by the Post and other outlets on Saturday:
¶
¶
https://www.the-sun.com/news/274369/jeffrey-epstein-first-victim-kids-underwear/
¶
¶
, sorry for not giving you a heads up on this. That was not my intent. Just been really busy with a couple of other big matters going on now. Please see attached. What media is picking it up? I don’t see anything.
¶
Robert Glassman, Esq.
¶
Panish Shea & Boyle LLP
¶
Web: www.psblaw.com
¶
CONFIDENTIALITY NOTICE:
¶
This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any
¶
EFTA00082460¶
review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.¶
If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case.
¶
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
¶
EFTA00082461¶
Panish Shea & Boyle
¶
psblaw.com
¶
¶On Dec 30, 2019, at 1:10 PM,
¶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 Howie Simon, Dr. Cabe, and John Larkin. 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.
¶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-----
¶From: Robert Glassman <
¶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
EFTA00082462¶
¶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.
¶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.
EFTA00082463¶
¶CONFIDENTIALITY NOTICE:
¶This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
¶If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case.
¶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,
EFTA00082464¶
¶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.
¶Thanks Robert — we’ll call you in 5-10 minutes, just gathering everybody up in the same place. Thanks very much.
¶Yes. Call me on my cell today.