Text extracted via OCR from the original document. May contain errors from the scanning process.
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(USANYS)"
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
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
0
•
Re-interview
Ask agents to contact and interview him (M— within 2 weeks)
(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
•
Interviewer
o
•
Re-interview
o
will contact his attorney re in person interview in January
will review emails in Relativity
•
Interview
and other individuals on flights w/
0
will contact his attorney re in person interview
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)
o
•
Interview
mother
will ask agents to interview by phone
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•
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
From:
To:
Here's the task list, based on our conversation:
(USANYS)
•
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
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
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•
Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including
(within one month)
0
•
Interview
mother
•
will ask agents to interview by phone
•
Investigate immigration records/travel records re:
o
will take a look and work with agents
•
Interview
will call Sigrid about a potential interview
•
Review deposition transcripts for GM (keeping in mind SOL is approaching)
•
will send SOL reminder
•
Tip-line leads that
flagged
•
will flag for agents
From:
To:
(USANYS) <
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:
To:
Team,
>;
(USANYS) <
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:
•
•
•
•
•
•
•
mother
•
*Records custodian from
•
*Records custodian from
•
*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.
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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