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efta-efta00020114DOJ Data Set 8CorrespondenceEFTA00020114
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EFTA DisclosureText extracted via OCR from the original document. May contain errors from the scanning process.
From: "Moyne, Parvin" 4
To: "
Cc: "Moyer, Thomas"
"
"
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Date: Thu, 22 Aug 2019 16:01:30 +0000
Sounds good.
We made another production last night. If it is helpful for us to run through that with you before the proffer, let us know
and we can jump on a call.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD Lev
One Bryant Park1 New York, NY 10036-6745 I USA I Direct: +1
Fax: +1
I
j akingmp.com I Bio
From:
Sent: Wednesday, August 21, 2019 11:29 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
I Internal: MI
Subject: RE: 2019.8.15 - SONY Production Index.xlsx
Thanks, let's do 10:30 a.m. on Thursday the 12th. Please let us know if your schedule changes, or if it's useful to talk
substantively in the interim, and we look forward to seeing you then.
From: Moyne, Parvin
Sent: Wednesday, August 21, 2019 20:01
To:
Cc: Moyer, Thomas
Subject: Re: 2019.8.15 - SDNY Production Index.xlsx
Either works for us so please choose what is most convenient for you.
Best,
Parvin
On Aug 21, 2019, at 6:45 PM,
wrote:
EFTA00020114
Parvin,
Not a problem. We could do any time after noon on that Tuesday (the 10th) or any time on the Thursday (the 12th).
Would either of those work?
thanks,
From: Moyne, Parvin
Sent: Wednesday, August 21, 2019 09:25
To:
Cc: Moyer, Thomas
>
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
I'm so sorry for the inconvenience but those dates are not good on our end.
The following week is relatively clear. Might September 9th work? Or other dates that week?
Best,
Parvin
From:
Sent: Tuesday, August 20, 2019 11:58 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
>
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early
September, if we can — is there a time during the afternoon of September 5 or the morning of September 6 that would
work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the
following week.
thank you,
From: Moyne, Parvin
Sent: Tuesday, August 20, 2019 14:03
To:
I<
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
-
Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from DB Legal) deliver a
presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with
Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have
EFTA00020115
noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we
have provided so you can more readily identify whatever information you are most interested in. Following the proffer,
if there are particular accounts or transactions of interest, we can identify the person within DB who can best answer
questions on those areas and that person would then meet with you.
In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.)
Best,
Parvin
From:
Sent: Monday, August 19, 2019 8:14 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
<
Parvin,
)
Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out
scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with
Deutsche Bank personnel, etc? And approximately how long should we be planning to block out?
thanks,
From: Moyne, Parvin
Sent: Monday, August 19, 2019 12:04
To:
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SONY Production Index.xlsx
<
Hi MI —
The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most
sense on your ends.
We have time this week (Thursday or Friday afternoon) and next week (Monday — Wednesday), and we have time in
September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends.
Best
Parvin
From:
)
Sent: Saturday, August 17, 2019 1:59 PM
To: Moyne, Parvin
)
EFTA00020116
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
**EXTERNAL Email**
Parvin,
We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think
we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and
trials in the next couple weeks, but we could do early September if that works on your end. Thoughts?
thanks,
From: Moyne, Parvin <
Sent: Thursday, August 15, 2019 09:48
To:
I 4
Cc: Moyer, Thomas
Subject: 2019.8.15 - SDNY Production Index.xlsx
&
Please find attached an index to our productions to date. This is a work in progress — we will update it as we gather and
produce additional documents.
Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
One Bryant
SP
<
Flew York NY 10036-6745 I USA I Direct: +1
Fax: +1
I
I akingttnp.com I Bio
Internal:=
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
EFTA00020117
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00020118
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