RE: Epstein investigation [FFW-DOCS.FID6003375]

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

Personal Injury Team of the Year - Solicitors Journal Awards 2017

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,

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

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,

Thanks

I am afraid that an attorney proffer will not be possible. I have been working with the DA in New York on the Weinstein case and have simply offered up my clients to questions which has worked well.

I am of course happy to speak over the phone but it seems to me that you are better off getting the information first hand. If you wish it may be sensible for you to initially have a call with my client?

My client has made a complaint to the Met police regarding a sexual assault by Jeffrey Epstein whilst in London and in the employment of G Maxwell. Apart from the complaint itself, no further information has been provided to the police.

I appreciate the issue re coronavirus of course.

Kind regards,

Jill

Jill Greenfield
Partner

Personal Injury Team of the Year - Solicitors Journal Awards 2017

Jill,

Following up on the below, given the development of the virus pandemic over the past week, any foreign travel for us is completely shut down. We certainly will plan to come to the U.K. whenever we are permitted, but in the interim this makes it even more valuable to get even a summary of what your client would expect to convey to us. Would it be possible to set up a call for later this week or sometime next week? And profound apologies for the inconvenience in changing plans, we certainly don't want to cause additional stress or anxiety to your client, the circumstances are just completely beyond our control.

thank you,