From: ' (USANYS)"
To: '
Subject: RE: Agenda
Date: Fri, 06 Nov 2020 20:03:36 +0000
Same here, thank you. And thanks for the agenda!
From: cla
Sent: Friday, November 06, 2020 2:16 PM
To: 1 sr- >
Cc: (USANYS)
Subject: RE: Agenda
I'm open other than the two calls we have on the calendar for this case.
From:
Sent: Friday, November 6, 2020 2:13 PM
To: ) `c >
Cc: (USANYS)
Subject: Re: Agenda
What time works for everyone on Wednesday afternoon?
Sent from my iPhone
On Nov 6, 2020, at 2:12 PM, wrote:
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.
From:
Sent: Friday, November 6, 2020 2:09 PM
To: > (USANYS)
Subject: 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:
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• *Records custodian from
• *Records custodian from
• *Court reporter(s) from
*We haven't identified/spoken to these witnesses yet, so that's on the trial prep to-do list as well.
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 Lo make sure 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
• 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
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