From:
To:
Subject: RE: Agenda
Date: Mon, 07 Dec 2020 16:40:11 +0000
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:
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 Interlochen 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.
• 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
will handle outreach to PBPD (within one month)
• Talk to to make sure has searched all her emails for relevant communications
o1 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
• will contact regarding an interview (within two weeks)
• Meet with
0 Discuss with chiefs tomorrow re: superseder timing
• Interview
0 Ask agents to contact and interview him (—within 2 weeks)
• Re-interview (with counsel)
0 Ask agents to contact him re: appointed counsel ( —within two weeks)
• Interview
0 Talk to agents about an interview, not a high priority
• Interview Jo Jo Fontanella
will contact his attorney re in person interview
• Re-interview
will contact his attorney re in person interview in January
will review emails in Relativity
• Interview and and other individuals on flights w/
o1 will talk to agents about approaching them
• Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including
(within one month)
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01
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• Interview mother
o1 will ask agents to interview by phone
• Investigate immigration records/travel records re:
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o will take a look and work with agents
• Interview I.
will call Sigrid about a potential interview
• Review deposition transcripts for GM (keeping in mind is approaching)
o1 will send reminder
• Tip-line leads that flagged
o1 will flag for agents
From:
Sent: Wednesday, November 11, 20204:25 PM
To:
Subject: RE: Agenda
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 Interlochen 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.
• 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
will handle outreach to PBPD (within one month)
• Talk to to make sure. 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
o will review Relativity and set up interview (two weeks)
• Potentially re-interview
o Team will review 302 and schedule follow-up interview
• 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 Jo Jo Fontanella
will contact his attorney re in person interview
• Re-interview
will contact his attorney re in person interview in January
will review emails in Relativity
• Interview and and other individuals on flights w/
• will talk to agents about approaching them
• Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including
(within one month)
• Interview mother
o will ask agents to interview by phone
EFTA00027434
• Investigate immigration records/travel records re:
o will take a look and work with agents
• Interview I.
will call Sigrid about a potential interview
• Review deposition transcripts for GM (keeping in mind IN is approaching)
• will send reminder
• Tip-line leads that flagged
o will flag for agents
From:
Sent: Friday, November 6, 2020 2:12 PM
To:
Subject: RE: Agenda
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: >;
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:
• *Records custodian from Interlochen
• *Records custodian from the Professional Children's School
• *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.
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 Interlochen 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 I. has searched all her emails for relevant communications
• Potentially interview client
• Potentially re-interview
• Meet with
• Interview
• Interview
• Interview Jo Jo Fontanella
• Re-interview
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• Interview and
• 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 IM (with counsel)
• Interview.
• Review deposition transcripts for GM (keeping in mind IMI is approaching)
• Tip-line leads that flagged
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00027436