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From: " To: ir" I, 11 Subject: FW: SDNY investigation Date: Tue, 31 Dec 2019 17:31:24 +0000 FYI, called me, and she asked among other things about the status of next steps or.= I told her we'd received the go ahead. She and =will call the brothers and mother later this week to ask to schedule interviews. Ori inal Messa e From: ) Sent: Monday, December 30, 2019 10:28 PM To: Robert Glassman < Cc: aNIMIE>; Nathan Werksman < Subject: RE: SDNY investigation Great, thanks very much. We'll likely start with siblings and mother and then go from there. As soon as we have a sense of when it would be productive for us to return for a follow-up meeting with we'll reach out -- as I mentioned, we're hoping that will be sometime in January, but just depending on how quickly we're able to schedule these discussions. And as always, please don't hesitate to let us know if anything comes up in the meantime. Original Message From: Robert Glassman Sent: Monda December 30 20

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From: " To: ir" I, 11 Subject: FW: SDNY investigation Date: Tue, 31 Dec 2019 17:31:24 +0000 FYI, called me, and she asked among other things about the status of next steps or.= I told her we'd received the go ahead. She and =will call the brothers and mother later this week to ask to schedule interviews. Ori inal Messa e From: ) Sent: Monday, December 30, 2019 10:28 PM To: Robert Glassman < Cc: aNIMIE>; Nathan Werksman < Subject: RE: SDNY investigation Great, thanks very much. We'll likely start with siblings and mother and then go from there. As soon as we have a sense of when it would be productive for us to return for a follow-up meeting with we'll reach out -- as I mentioned, we're hoping that will be sometime in January, but just depending on how quickly we're able to schedule these discussions. And as always, please don't hesitate to let us know if anything comes up in the meantime. Original Message From: Robert Glassman Sent: Monda December 30 2019 22:20 To: Cc: Nathan Werksman Subject: Re: SDNY investigation - yes, all good to contact those folks. Thanks for checking in. Robert S. Glassman Panish Shea & Boyle psblaw.com > On Dec 30, 2019, at 1:10 PM, c l=1.> wrote: > Robert, > Following up on our most recent meeting with you and .we wanted to confirm that it's alright for us to beg reaching this week to the contacts she identified for us -- in articular we would initially expect to contact, and and the and We also wan e are able at this stage to contact her mother, who is potentially a key witness -- I know EFTA00084157 had wanted to speak with her mother in advance of us doing that. Please let us know if it's alright to mak 9 nd separately, if you could please let us know if her brother has happened to have any contact with since we last spoke -- no problem at all if not, but I think she mentioned that was a possibility so wanted to check. > Thanks very much, and hope you're having a good holiday season. > thanks again, > Original Messa e > From: > Sent: Friday, December 13, 2019 17:06 > To: Robert Glassman > Cc: I=ME ) aIMIE>; Nathan Werksman > Subject: RE: SD investigation > Totally understand, just wanted to ask. We'll see you Monday at 11:00. And thanks for that additional info as well. > ----Original Message > From: Robert Glassman <IMM=> > Sent: Frida , December 13. 2o It) 16 :14 > To: > Cc: aNIMIE>; Nathan Werksman > Subject: Re: investigation unfortunately, we can't do earlier than 11. She just needs time to get to my office after taking care of kid stuff etc. > Re the mom, my understanding is that she is overseas somewhere. Pretty sure she's not in the US. I will find out and we can chat about it on Monday. > Robert S. Glassman > Panish Shea & Boyle > psblaw.com >> On Dec 12, 2019, at 1:30 PM, wrote: » Robert, >> We wanted to ask if it might be possible to start at 10:00 on Monday rather than 11:00? If not, we totally understand (I think you may have wanted time to meet with her before starting with us) but wanted to check. >> >> Separately, I know aft you a message earlier, but since we're emailing about this we can just ask -- we were wondering if it might be possible to tell us where mother currently lives? Not her literal address, but just city and/or state -- we don't have any intention of contacting her before we speak to you and your client in person, but just for our longer-term logistical planning, we're wondering where we would be EFTA00084158 headed if and when an interview of her were to be appropriate. » thanks, >> Original Messa e » From: >> Sent: Wednesday, December 11, 2019 13:15 >> To: Robert Glassman >> Cc: ; Nathan Werksman < >> Subject: RE: SDNY investigation >> Confirmed, thanks -- we'll see you then. And just on substance, I think we mentioned these topics when we spoke on the phone earlier, but just to refresh, I expect we'll want to talk through some additional specifics on travel, we'll talk more about other steps we'll be looking to take in our investigation for corroboration and what the appropriate timing and format of that would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent is comfortable with that at this stage. And we'll also likely refresh on some other topics as well, but just to flag some of the more immediate areas we'll expect to cover. Let us know if it's useful to chat again before Monday, otherwise we'll see you then. » thanks again, >> >> >> >> Original Message----- >> From: Robert Glassman < > >> Sent: Wednesday. December 11.2019 12:38 » To: » Cc: ; Nathan Werksman >> Subject: RE: SDNY investigation » Let's do 11 a.m. on Monday. » Robert Glassman, Esq. » Panish Shea & Bo le LLP » Tel: » Fax: » Ema » Web >> CONFIDENTIALITY NOTICE: >> This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. Los Angeles, CA 90025 >> If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. EFTA00084159 >> Ori inal Messa e >> From: [mailto: >> Sent: Wednesday, December 11, 2019 8:26 AM >> To: Robert Glassman » Cc: ; Nathan Werksman >> Subject: RE: SDNY investigation » Robert, >> That's great, thanks very much. Do you have a preference on timing? Anytime that morning starting at 10:00 a.m. or later would be fine for us, or we could also start early afternoon if that's easier--whatever you and prefer. And our hope is that we'd be able to cover everything on Monday, but we'll also be available on Tuesday if that ends up being useful as well. >> Original Message >> From: Robert Glassman >> Sent: Tuesday. December 10.2019 20:59 » To: » Cc: ; Nathan Werksman >> Subject: Re: SDNY investigation >> Monday morning works at my office. Tuesday may also work too if you need more time. But confirm for Monday. » Robert S. Glassman >> Panish Shea & Boyle » psblaw.com >>>> On Dec 10, 2019, at 9:35 AM, wrote: >» Robert, >>> Following up on our call, in terms of logistics, we can come to California to meet with anytime this coming Sunday, Monday, or Tuesday, if any of those work? Also, if it's at all possible to either set aside a significant amount of time on one day or--possibly preferably--a few hours on two consecutive days (and if so, we could do the second meeting on Wednesday if that's helpful), that will allow us to review relevant case notes, do quick research, or anything else that would provide for helpful follow-up where we'd just need a little time between discussion sessions. And as always, happy to discuss via phone if that's helpful. >» thanks, >» Alex. >>> Ori inal Messa e >» From: EFTA00084160 >>> Sent: Monday, December 09, 2019 17:46 >» To: Robert Glassman < >» Cc: ; Nathan Werksman >>> Subject: RE: SDNY investigation >>> Thanks Robert -- we'll call you in 5-10 minutes, just gathering everybody up in the same place. Thanks very much. >» -----Original Glassman Message----- >» Sent: Monda DecembeW >»From: Robert >» To: >» Cc: ; Nathan Werksman >» Subject: Re: SDNY investigation >» Yes. Call me on my cell today. >» Robert S. Glassman >» Panish Shea & Boyle >» psblaw.com »»>OnDec9,2019,at9:21AM,I wrote: >>» >>» Robert, >>» >>» Checking in on the below -- is there a good time to chat this week? >>» »» thanks, >>»- >>» »» -----Ori inal Messa e »» From: »» Sent: Wednesday, December 04, 2019 13:06 »» To: Robert Glassman < »» Cc: ; Nathan Werksman <a; »» Subject: RE: SDNY investigation >>» »» Hi Robert, >>» >>>> Following up on our discussion a couple weeks ago, would it make sense to have a quick call later this week or early next to check in on current status? We also have one additional data point we'd like to convey as well, at your convenience. >>» »» thanks, »»IM. >>» >>» >>» Original Message EFTA00084161 »» From: Robert Glassman >>» Sent: Friday, November "2. . : »» To: »» Cc: »» Subject: Re: SDNY investigation >>» »» Thanks. Cell is best >>» >>» »» Robert S. Glassman »» Panish Shea & Boyle »» psblaw.com >>» >>» >>>>>> On Nov 22, 2019, at 10:14 AM, wrote: >>>» >>» ; Nathan Werksman eza; EFTA00084162

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From: Kevin Boyle To: Robert Glassman Cc: Nathan Werksman Subject: Re: SDNY investigation Date: Wed, 12 Feb 2020 16:58:56 +0000 Also all— No objection that I can see from ud regarding these subpoenas (without having see. them), but note that some states (CA at least, in civil cases) a "Notice to Consumer" must be done with subpoenas like this. If it is not done, then the entity can not produce anything demanded in the subpoena. I'm not sure if the same requirement applies to criminal subpoenas. Kevin R. Boyle www.psblaw.com > On Feb 12, 2020, at 8:55 AM, Robert Glassman < wrote: > Thanks for letting us know. Can you send me a list of the schools you've subpoenaed and reached out to? Just want to make sure if she gets a call from someone, it is actually from someone who you've contacted and is legit. As you can imagine, there are lots of calls and emails to her and her manager saying all kinds of stuff. > Robert Glassman, Esq. > Panish Shea & Boyle LLP > Web: www.psbl

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From: '1 ~ 1. ~la To: Robert Glassman Cc: , Nathan Werksman Subject: RE: SDNY investigation Date: Wed, 12 Feb 2020 17:30:59 +0000 Kevin Boyle Of course, and I should say, if it's alright, we can give the schools our information in the first instance in the hopes that they're willing to go through you rather than bothering irectly (or if that adds complications, rather than reducing them, let us know). The schools / entities are n 'ew 'or .In p u , mu r m•yr n n pr r- .r ac, T. y connect with you separately on a , and we can continue to keep you posted. As to Kevin's note, ordinarily there's no notice requirement, but there are some unusual rules that apply to educational institutions, which we think is driving some of the back-and-forth we're having. Thanks for your help with this, as always, and we'll keep in touch on this. Original Message From: Robert Glassman ‹ > Sent: Wednesda Febru• 12, 2020 11:55 To: Cc: Nathan Werksman '-; Kevin Boyle Subject:

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