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efta-efta00040343DOJ Data Set 9Other

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DOJ Data Set 9
Reference
EFTA 00040343
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4
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2
Integrity
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From: ' )" To: ' Subject: RE: Agenda Date: Mon, 07 Dec 2020 16:40:11 +0000 (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

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From: ' )" To: ' Subject: RE: Agenda Date: Mon, 07 Dec 2020 16:40:11 +0000 (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 EFTA00040343 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: Sent: Wednesday, November 11, 2020 4:25 PM To: Subject: RE: Agenda 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 EFTA00040344 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: Sent: Friday, November 6, 2020 2:12 PM To: Subject: RE: Agenda (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: Sent: Friday, November 6, 2020 2:09 PM To: Subject: Agenda 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. EFTA00040345 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

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