Subject: RE: 2019.8.15 - SDNY Production Index.xlsx¶
Date: Wed, 21 Aug 2019 20:52:14 +0000¶
Monday afternoon, Tuesday afternoon, and all day Thursday are good for me that week, thanks.¶
I could do anytime on M/T/Th of that week – y’all?¶
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx¶
I’m so sorry for the inconvenience but those dates are not good on our end.¶
The following week is relatively clear. Might September 9^{th} work? Or other dates that week?¶
Best,¶
Parvin¶
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx¶
Parvin,¶
That makes good sense, thanks. Because of the scheduling issues I mentioned, we’d like to set it for a time in early September, if we can – is there a time during the afternoon of September 5 or the morning of September 6 that would work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the following week.¶
thank you,¶
EFTA00089217¶
Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from Legal) deliver a presentation that provides an overview of Epstein’s relationship with the bank, the different accounts affiliated with Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we have provided so you can more readily identify whatever information you are most interested in. Following the proffer, if there are particular accounts or transactions of interest, we can identify the person within who can best answer questions on those areas and that person would then meet with you.¶
In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.)¶
Best,¶
Parvin¶
Parvin,¶
Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with personnel, etc? And approximately how long should we be planning to block out?¶
The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most sense on your ends.¶
EFTA00089218¶
We have time this week (Thursday or Friday afternoon) and next week (Monday – Wednesday), and we have time in September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends.¶
Best Parvin¶
EXTERNAL Email¶
Parvin,¶
We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think we’d like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and trials in the next couple weeks, but we could do early September if that works on your end. Thoughts?¶
thanks,¶
Please find attached an index to our productions to date. This is a work in progress – we will update it as we gather and produce additional documents.¶
Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m.¶
Best,¶
Parvin¶
Parvin Daphne Moyne¶
AKIN GUMP STRAUSS HAUER & FELD LLP¶
EFTA00089219¶
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EFTA00089220¶