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From: ' To:' )" )" Cc: ' )" Subject: Re: SDNY investigation Date: Wed, 30 Sep 2020 18:32:56 +0000 [=. [=. We connected with the attorney who represents the witness. She does not object to notifying the Met Police using her name. Should our agents submit the notification through regular channels, or does the legat intend to make notification in a different manner? Thanks, Sent from my iPhone On Sep 30, 2020, at 1:47 PM, cza wrote: Give me a call if you get the chance. I'd like to close the loop on my conversations with LEGAT US Mobile: On Sep 30, 2020, at 6:42 PM, - London ) < > wrote: Is there a counterpoint at OIA in Washington we should be emailing for OIA approval, or should we send you an email requesting approval? Thanks, From: Sent: Wednesday, September 30, 2020 11:18 AM To: Cc: Subject: RE: SDNY investigation Is she OK with the Met Police knowing about her speaking with us? EFTA00095309 From: Sent: Wednesday, September 30, 2020 4:17 PM To

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From: ' To: ' )" )" Cc: ' )" Subject: Re: SDNY investigation Date: Wed, 30 Sep 2020 18:32:56 +0000 [=. [=. We connected with the attorney who represents the witness. She does not object to notifying the Met Police using her name. Should our agents submit the notification through regular channels, or does the legat intend to make notification in a different manner? Thanks, Sent from my iPhone On Sep 30, 2020, at 1:47 PM, cza wrote: Give me a call if you get the chance. I'd like to close the loop on my conversations with LEGAT US Mobile: On Sep 30, 2020, at 6:42 PM, - London ) < > wrote: Is there a counterpoint at OIA in Washington we should be emailing for OIA approval, or should we send you an email requesting approval? Thanks, From: Sent: Wednesday, September 30, 2020 11:18 AM To: Cc: Subject: RE: SDNY investigation Is she OK with the Met Police knowing about her speaking with us? EFTA00095309 From: Sent: Wednesday, September 30, 2020 4:17 PM To: Cc: Subject: RE: SDNY investigation Hi M, We have not seen the statement she has given, and we do not know the names of the police officers involved. Thanks, From: ) Sent: Wednesday, September 30, 2020 11:16 AM To: Cc: Subject: RE: SDNY investigation Thanks. Very helpful. Am I correct in assuming that you have not seen the statement she gave to the police? Also, do you have the names of the Met officers involved? From: Sent: Wednesday, September 30, 2020 3:53 PM To: Cc: Subject: RE: SDNY investigation Hi M, Thank you. We have not interviewed this witness, so we have not confirmed the details about where the abuse happened, who the perpetrator was, or how old she was when it happened. What we do know is (1) she is currently in England, reporting some sort of past abuse by Jeffrey Epstein (and not necessarily the full scope of the information she may have in connection with our investigation), so we would be open to the possibility of sharing her name with the Met Police if, in your view, that was necessary. We are preparing travel paperwork on our end, and will try to get this moving quickly. Thanks so much for your guidance on this. Best, From: Sent: Wednesday, September 30, 2020 7:07 AM To: ) 4a; Subject: RE: SONY investigation One other question. If there is anything that would implicate UK government interests in this witness (other than any connection with witness PA) - if she was assaulted in EFTA00095310 connection with a UK gov't function, or was a UK gov't employee, etc. - that would also be helpful to know. From: Sent: Wednesday, September 30, 2020 11:05 AM To: 1<a; Subject: RE: SDNY investigation In speaking with LEGAT colleagues about how to do this without disclosing the witness identity, they said the UK will want to know if the conduct is also a UK crime. So a few questions: is the victim a UK national; did the alleged conduct occur on UK soil; if the conduct occurred elsewhere, was the perp a UK national and the victim under age (I think it has to be under age 16)? Also, what country is the victim currently in - England/Wales; Scotland, or N. Ireland (they each have their own procedures)? Did the victim ever report the conduct to UK law enforcement? Thx, From: Sent: Tuesday, September 29, 2020 6:40 PM To: ) <a; Cc: Subject: Re: SDNY investigation My apologies. I haven't been able to get back on the line. UK Mobile: Sent from a mobile device From: Sent: Tuesday, September 29, 2020 6:09:57 PM To: - London Cc: Subject: RE: SDNY investigation Hi M, Thanks again for taking the time to talk to us today. We can use this conference line: EFTA00095311 From: Cl= > Sent: Monday, September 28, 2020 11:58 AM To: Subject: Re: SDNY investigation I'll be in court much of the day tomorrow, so how about 1:30 pm EDT or later? Thx - London UK Mobile: Sent from a mobile device From: Sent: Friday, September 25, 2020 8:14:17 PM To: Subject: FW: SDNY investigation From: Sent: Friday, September 25, 2020 8:14:13 PM (UTC+00:00) Dublin, Edinburgh, Lisbon, London To: Cc: ); (USANYS) Subject: Re: SDNY Investigation Thanks very much. Is there a time on Tuesday that works best for you? Sent from my iPhone On Sep 25, 2020, at 1:49 PM, > wrote: Hi - I will be out of the office on Monday, but could do it any other day of the week. If Monday is a critical day, I could do a call on Monday evening BST - which would be mid- afternoon your time. Let me know what works. Thx, United States Embassy - London U.K. Mobile: From: Sent: Friday, September 25, 2020 3:16 PM To: EFTA00095312 Cc: ›; (USANYS) Subject: SDNY investigation Hi=, I hope you're doing well. Are you possibly available for a brief call on Monday? Thanks very much, Assistant United States Attorney Southern District of New York New York, NY 10007 EFTA00095313

Related Documents (6)

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KIRKLAND & ELLIS LLP

KIRKLAND & ELLIS LLP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutors have pursued the allegations against Mr. Epstein is highly irregular and warrants full review by the Department. While we repeatedly have raised our concerns regarding misconduct with the United States Attorney's Office in Miami (the "USAO"), not only has it has remained unwilling to address these issues, but Mr. Epstein's defense counsel has been instructed to limit its contact to the very prosecutors who are the subject of this misconduct complaint. For your review, this document summarizes the USAO's conduct in this case. Background 1. In March 2005, the Palm Beach Police Department opened a criminal investigation of Palm Beach resident, Jeffrey E. Epstein. The press has widely reported that Mr. Epstein is a close friend of former President Bill Clinton. 2. In July 2006, after an intensive probe, including interviews of dozens of witnesses, re

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Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 1 of 54

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H A D D O N

H A D D O N MORGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. PairBoca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] Defendant Ghislaine Maxwell through counsel, submit the following summary pursuant to Fed. R. Crim. P. 16(b)(1)(C). I. EXPERT DISCLOSURE BY THE DEFENSE A. Dr. Elizabeth Loftus Dr. Loftus is the Distinguished Professor of Psychological Science and Law at the University of California, Irvine School of Law. Dr. Loftus is one of the nation's leading experts on the science of memory. In addition to her experience as an academic and clinical researcher, she has been an expert witness or consultant in hundreds of cases. Her extensive experience and credentials are recited in her cur

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