RE: Epstein investigation [FFW-DOCS.FID6003375]

Ms. Greenfield,

Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection with our investigation into the conduct of Jeffrey Epstein.

As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to her trauma or causing re-victimization.

As we mentioned on the • hone our client we discussed, our knowledge of your client specifically is somewhat limited, having never spo en o er—an • therefore knowing about her only through other witnesses and records—but it certainly has been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we hope to speak with her.

Separately, and as we also discussed, any discussion with our team would be entirely voluntary—and that extends not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that would be beneficial while we're meeting, etc.

In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein and his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked directly for. That would broadly include how she came to be in contact with them, the nature and scope of her employment, any instructions she was given relating to other women or girls, and just generally her experiences and observations in interacting with them. We ordinarily would also be interested in understanding the general nature of the abuse she was subjected to, but I want to emphasize that we would not need to discuss with her the specifics if she weren't comfortable with that, and in particular we often don't even broach that subject in a first meeting.

Please let us know if you have any additional questions, and in particular whether any other information from us would be useful, and we look forward to speaking with you again soon.

Regards,

Hi

[ ]

Thanks for this. I've been asked who would be in the room and thereafter who would have access to any notes made. Would her permission be sought before disclosing to any other parties or officials?

As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to provide any comfort on this?

Many thanks

Jill

Jill Greenfield
Partner
D:
M:

Personal Injury Team of the Year - Solicitors Journal Awards 2017

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Sent from my iPhone

Jill,

Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise we're of course happy to travel to her.)

Regarding access to notes, it would principally be the investigative team—so again, the prosecutors and the FBI team working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types up those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but I can also check on that to see if I can make a more specific representation with respect to your client.

With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't change even for individuals who are in the position of your client, who have been widely publicly reported to have been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any follow-up via email.

thanks,

Thanks

[ ]

This is helpful. I’ve gone back to my client with this. I will be back in touch shortly.

Regards

Jill

Jill Greenfield

Partner
D:
M:

Personal Injury Team of the Year - Solicitors Journal Awards 2017

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Sent from my iPhone

Understood — thanks very much.

Hello

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

Jill Greenfield
Partner
D:
M:

Personal Injury Team of the Year - Solicitors Journal Awards 2017

Understood. I will call tomorrow.

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 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,

Jill,

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,

Hi

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

Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017

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,