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efta-efta00079395DOJ Data Set 9Other

Fudali

From: To: Cc: Fudali Lisa Bloo Colleen Mullen Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Date: Thu, 08 Aug 2019 19:11:18 +0000 Inline-Images: image00 1 jpg; image002.jpg Arick Hi Teri, That sounds great, thanks. On scheduling, we'll plan to meet with Ms t 12 p.m. on 8/26 at our office, and we will plan to speak with Ms. y video conference at 5 p.m. on 8/27. Regarding travel logistics for Ms. our office has a witness coordinator who can make travel arrangements. Let us know if there is someone at your office she should connect wit to iscuss arrangements, or whether you would like her to coordinate with your client directly to arrange travel. As for the video conference logistics, if you could please provide us with dial in information as we get closer, that would be great. Thanks, From: Teri Gibbs Sent: Thursday, August 8, 2019 1:45 PM To: Cc: Lisa Bloom Arick Fudali ›; ; Colleen Mullen Subject: Re: CONFIDENTIAL: Vict

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Unknown
Source
DOJ Data Set 9
Reference
EFTA 00079395
Pages
3
Persons
1
Integrity

Summary

From: To: Cc: Fudali Lisa Bloo Colleen Mullen Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Date: Thu, 08 Aug 2019 19:11:18 +0000 Inline-Images: image00 1 jpg; image002.jpg Arick Hi Teri, That sounds great, thanks. On scheduling, we'll plan to meet with Ms t 12 p.m. on 8/26 at our office, and we will plan to speak with Ms. y video conference at 5 p.m. on 8/27. Regarding travel logistics for Ms. our office has a witness coordinator who can make travel arrangements. Let us know if there is someone at your office she should connect wit to iscuss arrangements, or whether you would like her to coordinate with your client directly to arrange travel. As for the video conference logistics, if you could please provide us with dial in information as we get closer, that would be great. Thanks, From: Teri Gibbs Sent: Thursday, August 8, 2019 1:45 PM To: Cc: Lisa Bloom Arick Fudali ›; ; Colleen Mullen Subject: Re: CONFIDENTIAL: Vict

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From: To: Cc: Fudali Lisa Bloo Colleen Mullen Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Date: Thu, 08 Aug 2019 19:11:18 +0000 Inline-Images: image00 1 jpg; image002.jpg Arick Hi Teri, That sounds great, thanks. On scheduling, we'll plan to meet with Ms t 12 p.m. on 8/26 at our office, and we will plan to speak with Ms. y video conference at 5 p.m. on 8/27. Regarding travel logistics for Ms. our office has a witness coordinator who can make travel arrangements. Let us know if there is someone at your office she should connect wit to iscuss arrangements, or whether you would like her to coordinate with your client directly to arrange travel. As for the video conference logistics, if you could please provide us with dial in information as we get closer, that would be great. Thanks, From: Teri Gibbs Sent: Thursday, August 8, 2019 1:45 PM To: Cc: Lisa Bloom Arick Fudali ›; ; Colleen Mullen Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Hi Thank you for your email. Ms. is available to meet with you on 8/26 at 12 PM. Please send us details regarding her travel arran ements an t e meeting location. Our New York attorney, Arick Fudali, will accompany Ms. Ms.= available for a video conference on either 8/26 or 8/27 between the hours of 9 AM and 5 PM EST. As we intend to be on the call with Ms. e propose to schedule the call for 5 PM EST/2 PM PST/6 AM Okinawa Time. Best regards, Teri On Wed, Aug 7, 2019 at 2:03 PM > wrote: EFTA00079395 Ted, Thanks very much for reaching out regarding scheduling. We would propose meeting at 12 p.m. on 8/26 with Ms. f that is convenient for her. For Ms. even the time zone difference, could you please let us know w at Imes would work for a video conference wi er on either 8/26 or 8/27? Thanks, Alison Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 From: Ted Gibbs Sent: Monday, August 5, 2019 6:52 PM To: 4c = > Cc: Lisa Bloom ; Arick Fudali < Subject: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Hi olleen Mullen .• • Thank ou for takin the time to s eak with our firm on Friday, August 2, 2019, regarding our clients, ho believe they were assaulted by Epstein in or around June 2004. We have confirmed our clients' availability for interviews with your office. Ms. available for an for an interview via video co referably the week of Aug. P . Please confirm whether your office in-person interview on August 26, 2019, or August 27, 2019. Ms who is local is available is available to meet with Ms. n those dates and whether we can arrange a video conference for Ms. Additional) as discussed in our call, we have attached two PDF files for your review which contain pictures of Ms d Ms. Mom 2004. If possible, please confirm whether our clients are in any of the a m photograp s seize from Epstein's home. Thank you. We look forward to hearing from you soon. Best regards, Teri Gibbs EFTA00079396 Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication pnvileged by law. If you received this e-mail in error. any review. use. disseminabon. distribution. or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e- mad and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. IRS Circular 230 Disclosure: In order to comply wth requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of 0) avoiding penalties under the Internal Revenue Code or (s) promoting. marketing. or recommending to another party any transaction or matter addressed herein. Notice To Recipient: This e-mail is meant for orty the intended recipient of the transmission. and may be a communication privileged by law. If you received this e-mail in error, any review, use, dtssemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please delete this message and any and all dupbcates of this message from your system. Thank you in advance for your cooperation, IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Interns Revenue Service. we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (*avoiding penalties under the Internal Revenue Code or (s) promoting. marketing. or recommending to another party any transaction or matter addressed herein. EFTA00079397

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DOJ Data Set 9OtherUnknown

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant

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Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)

Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Date: Mon, 26 Aug 2019 21:48:47 +0000 Inline-Images: image001.jpg; image002.jpg Hi Ted, We were very grateful to Ms. or her courage in speaking with us today. For Ms. you all? 8/29 would be best. My recollection is that we planned to begin at 5pm EST—is that still the best time for Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 From: Teri Gibbs Sent: Monday, August 26, 2019 1:52 PM To: ) Cc: Colleen Mullen ) < )*ca Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Hi It was great to meet you, this morning. Thank you for patience with Ms. i speaking to you was quite challenging or er. For Ms. terview, she is available on either 8/29 or 8/30 for the rescheduled video call. Please email us back at st convenience confirming the interview time. Thank you, Teri On Fri, Aug 23, 2019 at 1:25

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Epstein Depositions

10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps

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DOJ Data Set 8CorrespondenceUnknown

EFTA00015929

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DOJ Data Set 8CorrespondenceUnknown

EFTA00010819

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