Subject: Re: 2019.8.15 - SDNY Production Index.xlsx¶
Date: Wed, 21 Aug 2019 01:06:29 +0000¶
Same, thanks.¶
Sent from my iPhone¶
On Aug 20, 2019, at 8:34 PM,¶
Sounds good. Either of you have any conflicts on the 5th or 6th? (I’m totally free both days.)¶
From:¶
Sent: Tuesday, August 20, 2019 14:20¶
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx¶
I tend to agree.¶
From:¶
Sent: Tuesday, August 20, 2019 2:15 PM¶
Subject: FW: 2019.8.15 - SDNY Production Index.xlsx¶
Up to you guys, but given that there’s no rush on moving on financial leads, it seems most efficient to just do this together on 9/5, when everyone is back from Florida. But I don’t have strong views.¶
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx¶
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.)¶
EFTA00099258¶
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.¶
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.¶
EXTERNAL Email¶
Parvin,¶
EFTA00099259¶
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¶
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EFTA00099260¶