RE: Agenda
Team,
In preparation for our call (which we can reschedule to a time following the discovery deadline), I wanted to send around a list of topics to discuss for potential next steps. I'm sure I've missed some items, but this is a starting point at a least.
For context, I think we currently expect to call at least the following witnesses at trial:
The image is not a chart. It lists potential trial witnesses. The visible names are:
- Mother
- Records custodian from [Unspecified Source]
- Records custodian from [Unspecified Source]
- Court reporter(s) from GM depositions
*We haven't identified/spoken to these witnesses yet, so that's on the trial prep to-do list as well.
EFTA00040345
The following are some potential next steps — either individuals to interview or re-interview, records to search for/identify, and so forth.
• Relativity review of GM emails
• Identify an employee (likely retired) who managed donor relations with Epstein/can authenticate documents
• Identify a PBPD detective who can authenticate items recovered from search of PB house
• Talk to to make sure M has searched all her emails for relevant communications [ ]
• Potentially interview client
Potentially re-interview
Meet with
Interview
•
Interview
•
Interview
•
Re-interview
•
Interview
• Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including
• Interview mother
• Investigate immigration records/travel records re:
• Re-interview (with counsel)
•
Interview
• Review deposition transcripts for GM (keeping in mind SOL is approaching)
• Tip-line leads that flagged
Assistant United States Attorney
Southern District of New York
EFTA00040346
Thanks very much, ! This all looks right to me and makes sense. If we are pushing this past Monday, I'd ask that it be Wednesday afternoon, or anytime Thursday, please. I've got a lengthy grand jury presentation to make on Tuesday.
Here's the task list, based on our conversation:
• Relativity review of GM emails:
[ ] o Team will split a batch review as a shared project, which will commence after we complete all Relativity review for discovery purposes.
• Identify an employee (likely retired) who managed donor relations with Epstein/can authenticate documents
o Records custodian for student files can be dealt with closer to trial.
o will contact counsel to begin discussing, and to follow up on our last conversation about records. (Within two weeks)
• Identify a PBPD detective who can authenticate items recovered from search of PB house
- o will handle outreach to PBPD (within one month)
• Talk to to make sure has searched all her emails for relevant communications [ ]
- o will handle and give a heads up they will contact her mother (within two weeks) [ ]
• Potentially interview client
- o will review Relativity and set up interview (two weeks) [ ]
• Potentially re-interview
O Team will review 302 and schedule follow-up interview
o will contact regarding an interview (within two weeks)
• Meet with
[ ] o Discuss with chiefs tomorrow re: superseder timing
• Interview
- o Ask agents to contact and interview him [ ] [ ] within 2 weeks)
• Re-interview (with counsel)
[ ] o Ask agents to contact him re: appointed counsel ( —within two weeks) [ ]
• Interview
[ ] o Talk to agents about an interview, not a high priority (=)
• Interview
° will contact his attorney re in person interview
• Re-interview
о will contact his attorney re in person interview in January
o will review emails in Relativity
• Interview and other individuals on flights w/—
[ ] o will talk to agents about approaching them
EFTA00040344
- Review victim interview notes and interview outcry witnesses not yet spoken to, including [REDACTED] (within one month).
- Interview [REDACTED] mother; will ask agents to interview by phone.
- Investigate immigration records/travel records regarding [REDACTED]; will review and work with agents.
- Interview [REDACTED]; will call Sigrid about a potential interview.
- Review deposition transcripts for GM (SOL approaching).
- Tip-line leads flagged by [REDACTED] will be flagged for agents.
Hi all—checking in on this, I've highlighted tasks that are completed or in motion. Let me know if I've missed anything. None of this is time-sensitive, I'm mostly just checking in to stay organized, so no rush on anything.
• Relativity review of GM emails:
- Relativity review of GM emails: Team to split batch review as a shared project.
- Identify employee (likely retired) who managed donor relations with Epstein/authenticate documents:
- Records custodian for student files to be dealt with closer to trial.
- Will contact counsel to begin discussion and follow up on last conversation about records within two weeks.
- Identify PBPD detective who can authenticate items recovered from PB house search:
- Will handle outreach to PBPD within one month.
- Talk to [Redacted] to make sure [Redacted] has searched all her emails for relevant communications:
- Will handle and give a heads-up they will contact her mother within two weeks.
- Potentially interview client:
- Will review Relativity and set up interview within two weeks.
- Potentially re-interview:
- Team will review 302 and schedule follow-up interview.
- Will contact [Redacted] regarding an interview within two weeks.
- Meet with [Redacted]:
- Discuss with chiefs tomorrow regarding superseder timing.
- Interview [Redacted]:
- Ask agents to contact and interview him within two weeks.
- Re-interview [Redacted] (with counsel):
- Ask agents to contact him regarding appointed counsel within two weeks.
- Interview [Redacted]:
- Talk to agents about an interview, not a high priority.
- Interview [Redacted]:
- Will contact his attorney regarding an in-person interview.
- Re-interview [Redacted]:
- Will contact his attorney regarding an in-person interview in January.
- Will review emails in Relativity.
- Interview [Redacted] and other individuals on flights with [Redacted]:
- Will talk to agents about approaching them.
- Review victim interview notes and interview any outcry witnesses not yet spoken to, including [Redacted] (within one month):
- [Redacted details follow]
- Interview [Redacted] (mother):
- Will ask agents to interview by phone.
EFTA00040343
• Investigate immigration records/travel records re:
- o will take a look and work with agents
• Interview
o will call Sigrid about a potential interview
• Review deposition transcripts for GM (keeping in mind SOL is approaching)
- o will send SOL reminder
• Tip-line leads that flagged
- o will flag for agents