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
0 will handle outreach to PBPD (within one month)
• Talk to to make sure has searched all her emails for relevant communications
0 will handle and give a heads up they will contact her mother (within two weeks)
• Potentially interview client
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
° will ask agents to interview by phone

• Investigate immigration records/travel records re:

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° will take a look and work with agents
• Interview
° will call Sigrid about a potential interview
• Review deposition transcripts for GM (keeping in mind is approaching)
will send reminder
•Tip-line leads that flagged
° will flag for agents

From:

Sent: Wednesday, November 11, 2020 4:25 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
0 |will handle and give a heads up they will contact her mother (within two weeks)
Potentially interview client
° 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
0 will contact his attorney re in person interview
• Re-interview
0 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
°

will ask agents to interview by phone

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• Investigate immigration records/travel records re:| ° will take a look and work with agents • Interview 0 will call Sigrid about a potential interview • Review deposition transcripts for GM (keeping in mind is approaching) will send reminder • Tip-line leads that flagged ° 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 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 (with counsel)
• Interview
• Review deposition transcripts for GM (keeping in mind 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

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