EFTA00096992¶
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]¶
Jill,¶
That’s great, thank you for letting us know, and we’ll check on that right away and get back to you as soon as possible. The only wrinkle, which unfortunately is completely beyond our control, is that there is now some talk of government international travel being prevented due to the coronavirus situation, but we’ll talk to the relevant people here immediately.¶
One thing that would be extremely helpful for us in the near-term, including in terms of getting approvals here – and we talked about this on the phone as well – would be to get an attorney proffer about your understanding of generally what information you expect your client will convey on the subjects we’ve spoken about? We completely understand that it’s best to have her tell her story directly to us, but in terms of our preparation it’s often very useful for both us and the witness for us to have had a conversation with counsel in the first instance. Would it be possible to set up a call to have that discussion? We could do as soon as tomorrow or Friday, or also next week.¶
Thanks very much,¶
There is the possibility of a meeting on the 19th March if you are able to come to London. Could you let me know please?¶
Kind regards¶
Jill¶
Personal Injury Team of the Year - Solicitors Journal Awards 2017¶
Subject: RE: Epstein investigation¶
Jill,¶
EFTA00096993¶
We wanted to quickly follow up since I think you and I last spoke a little over a week ago—understand if you are still discussing with your client, just wanted to check in, and we’re happy to provide any additional information that might be useful, as always.¶
thank you,¶
Jill,¶
No problem at all, we understand this takes time, and we appreciate you getting back to us, and we’re very grateful that your client is open to speaking with us.¶
On your questions, we are certainly fine with the first two questions / requests – we’re happy to meet with you and your client in an initial conversation, during which we can do the kind of introductions and explanations we’ve done with you (and that we do with all victim witnesses we meet), including answering any questions to the best of our ability, and then to take a break and have a more substantive discussion later on.¶
Regarding the friend, does that individual also represent her as counsel? We aren’t normally able to include individuals in addition to the witness and counsel in an interview—what does sometimes work is for someone who is providing support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness wants to speak with that person, which would of course be totally fine in this instance. Or if he represents her in his capacity as an attorney then he of course could be in the interview in that role (with the only caveat that we would just want to confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not¶
EFTA00096994¶
able to pay for third parties (including counsel) to travel in connection with witness interviews, though – if it’s preferable, we certainly could pay for your client’s travel to the U.S. for the interview, including airfare and lodging, if that makes it easier for the friend to be present? And we’re happy to discuss any of this further by email or phone if that’s useful – I’ll be at my desk for the next several hours and most of tomorrow, at , or we could also set a time to chat, whatever would be helpful.¶
thank you,¶
Apologies for the slight delay. My client is willing to help but asks the following:¶
-
That there be a morning meeting at which introductions with a discussion as to the investigation and my clients involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist.
-
In the afternoon and after a break, my client would be willing to answer questions, in so far as she can.
-
That a friend of hers be allowed to be present as well. However that friend is based in the US and would need to be flown over to London. He is a US lawyer.
Perhaps you could let me know if this is possible?¶
Kind regards,¶
Jill¶
Personal Injury Team of the Year - Solicitors Journal Awards 2017¶
<image001.jpg>¶
Understood – thanks very much.¶