This is a routine legal correspondence between attorneys scheduling a phone interview, part of the Giuffre v. Maxwell civil litigation from May 2020.
The document consists of email exchanges between attorneys from Boies Schiller Flexner LLP (representing Virginia Giuffre) and opposing counsel coordinating logistics for a witness phone interview. The emails discuss scheduling options for May 8-11, 2020, and include standard procedural notes about attorney-client privilege during remote depositions. This is administrative legal correspondence with no substantive revelations about the Epstein case.
From: To:' Cc: ' Subject: RE: follow-up request Date: Fri, 08 May 2020 20:20:45 +0000 )11 < No problem. We will speak to you tomorrow at 11:00 a.m. Eastern. Best, Partner BOIES SCHILLER FLEXNER LLP www.bsfIlp.com From: ) Sent: Friday, May 8, 2020 3:55 PM To: Cc: Subject: RE: follow-up request ( Al LION: External email. Please do not respond to or click on links/attachments unless you recognize the sender. Tomorrow morning would actually be fine — we'll send you a calendar invite for 11:00 a.m. Eastern time, including a conference line number, and we'll plan to talk with you then. And just as a heads up, not that I particularly expect this will be necessary, but similar to how we always tell witnesses that if they want to talk with their counsel privately during an in- person meeting, we'll let her know that the same thing holds true for over the phone as well, that you two can always have a side call at any point! And otherwise I think it will be the usual awkwardness of phone but hopefully not too bad. thanks again, From: Sent: Friday, May 08, 2020 14:46 To: Cc: Subject: RE: follow-up request EFTA00023162
If that does not work she also said she could do it this Monday morning — 10:00 Eastern (9:00 if that is better for your team. Just let me know. Thanks Partner BOIES SCHILLER FLEXNER LLP www.bsfllp.com From: Sent: Friday, May 8, 2020 1:59 PM To: Cc: Subject: RE: follow-up request ) [mailto: > CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender. Thanks for getting back to us so quickly. Goes without saying that we of course would be happy for you to be on the call as well—I should have mentioned that in my initial email. On timing, let us just check with the agents on the case to see if that works for them, and we hope to be able to confirm with you in the next couple hours. thanks, From: Sent: Friday, May 08, 2020 13:27 To: Cc: Subject: RE: follow-up request < Hello — said she has time tomorrow if that would work for you team. She is in so an hour behind us. I would like to be on the call as well. Would it work to do something tomorrow at 11:00 EST? Let me know. If that does not work I can try to get other times. Partner BOIES SCHILLER FLEXNER LLP EFTA00023163
www.bsfllp.com From: ) [mailto: Sent: Friday, May 8, 2020 11:02 AM To: Cc: Subject: RE: follow-up request CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender. I unfortunately was on trial during the previous interview, but I think somewhat less time than how long it went last time. Ordinarily we try not to go longer than about 90 minutes in any event, so I think if she is able to block out that amount of time, that would be great — and we'll try to be as efficient as possible and hopefully take less than that. If that sounds alright? thanks, From: Sent: Thursday, May 07, 2020 18:57 To: Cc: <M > Subject: RE: follow-up request Hello a, I am sure will be happy to help in any way she can. Let me find out what her patient schedule is like for next week and find a time that works. How much time do you think she should allot for the interview — just so she can plan? < Best, Partner BOIES SCHILLER FLEXNER LLP www.bsthp.com From: Sent: Thursday, May 7, 2020 6:41 PM To: Cc: ) [mailto:' Subject: RE: follow-up request EFTA00023164
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender. Hi We wanted to follow up in connection with — our supervisors have asked us to do an additional interview with her, both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview, which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any questions at all. And if is willing to speak with us again, we're happy to work around her schedule, including talking during an evening or weekend if that's easier for her than during the day—whatever you and she would prefer. Please let us know if any questions, or if it would be useful to chat, and thanks very much. From: Sent: Thursday, January 16, 2020 14:35 To: Cc: Subject: RE: follow-up request st > Got it, thanks. Assistant United States Attorney Southern District of New York New York, NY 10007 From: Sent: Thursday, January 16, 2020 2:29 PM To: Cc: Subject: RE: follow-up request >;I >; I checked back with and she said that the last entry in her journal is in late February and she went to in April. Thanks EFTA00023165
Partner BOLES SCHILLER FLEXNER LLP www.bsfllp.com Sent by Boxer On January 16, 2020 at 1:05:54 PM EST, Thank you very much, wrote: Just to confirm, does have any journal entries regarding the time when she traveled to believe she told us during our interview that she does not have any entries from that time, but I just wanted to make sure. Thanks again, Assistant United States Attorney Southern District of New York New York, NY 10007 From: Sent: Thursda Janua 16, 2020 12:31 PM To: Cc: ; Subject: RE: follow-up request Hello — attached are the pages sent me to provide to you. Here is a bit of an explanation and I also asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let me know if you need anything else: "The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the movies with him." Best, EFTA00023166
Partner BOIES SCHILLER FLEXNER LLP www.bsfllp.com From: [mailto: Sent: Friday. Janua 10, 2020 4:0 I PM To: Cc: ) • Subject: RE: follow-up request Thanks very much, . Yes, we received the photographs from , which we very much appreciate. Anything else she is willing to share, including her journal entries, would be very helpful. ..est Assistant United States Attorney Southern District of New York New York, NY 10007 From: Sent: Frida Janua 10 2020 3:59 PM To: Cc: ; Subject: RE: follow-up request Hello Let me follow up with about her journal. I know she shared some pictures with you from around the time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to you and will check with her to see if she has anything else that might be helpful to the investigation. All best, EFTA00023167
Partner BOIES SCHILLER FLEXNER LLP www.bsfllp.com From: [mailto: Sent: Frida , Janua 10, 2020 3:30 PM To: Cc: Subject: follow-up request • Hi ME, Hope you had a wonderful holida season and very happy New Year. We wanted to follow up on a request we made after interviewing a few months ago. During her interview, referred to several entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As we mentioned at the end of the interview, it would be very helpful to our investigation if we could review those journal entries, as well as any other records or documents may have that relate to her experiences with Epstein and Maxwell. Would be willing to share with us any relevant journal entries (or any other relevant documents she may have) to assist in our investigation? Happy to have a call to discuss if that would be helpful. Assistant United States Attorney Southern District of New York New York, NY 10007 The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that. among other protections, is the subject of attorney-client privilege. attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1 082011131BS9 EFTA00023168



