Document EFTA00023318 appears to be a series of email exchanges regarding a follow-up on a legal matter, potentially involving a protective order and discussions about witness safety and confidentiality.
This document consists of forwarded email communications from August and October 2020. The emails involve Colleen scheduling and rescheduling a call to discuss a protective order, witness safety, and confidentiality. Teri Gibbs is included in some of the email chains. The content suggests ongoing legal discussions, possibly related to a case where witness safety is a concern.

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From: To: Cc: Subject: Fwd: Follow-up Date: Fri, 16 Oct 2020 20:33:09 +0000 Hi Do you recall where you left things with this firm about Thanks. Sent from my iPhone Begin forwarded message: From: ' Date: To: Colleen ri E12941F1 VA KAMM WO E2 II Subject: RE: Follow-up Colleen, Per our discussion — the protective order is attached, as are the Court's opinion on this as well as the Government's strong argument on these issues. thanks. From: Colleen Sen To: Cc: Teri Gib • Subject: Re: o ow-u Thank you, I will give you a call today. Colleen On Thu, Aug 20, 2020 at 3:05 PM wrote: Colleen, The times were EST, but I can do 1:00 p.m. PST (4:00 p.m. EST) tomorrow, thanks. We can use the following dial-in: conference ID: 698244 From: Colleen Sent: Thursda 20 2020 15:30 To: EFTA00023318
Subject : Re: Follow-up I am available tomorrow after 1pm (PST). Are your proposed times in PST or EST? Colleen On Thu, Aug 20, 2020 at 9:55 AM wrote: Colleen, I don't, I'm sorry — I'm unfortunately totally booked today. I could talk at 12:30 or 1:00 tomorrow, or sometime early next week, if that's better for you? thanks, From: Colleen Sent: Thursda To: Cc: Teri Gibbs IMN I Subject: Re: Follow-up l y.,ave time to speak today around 1pm (PST)? Please let me know. Colleen Wed Au 19 2020 at 6:35 PM wrote: I Colleen, lilt ing up on the below — please let us know? Thanks very much. From: Sent: Tuesday, To: Colleen Cc: Teri Gibbs ect: ow-up Colleen, We are happy to speak with you — we had only followed up because we were under the impression she was interested in speaking with us. We certainly can discuss issues of witness safety and confidentiality, but we also are not looking to pressure anyone, at all. Please let us know if it makes sense to chat, and if so, what time ranges would work for you later this week or next. From: Colleen Sen To: Cc: ject: e: o ow-up Do you have any time to speak this week? My client is deeply concerned about her personal safety and wishes to maintain her anonymity. Best, Colleen On Thu. Au= 6. 2020 at 10:26 AM wrote: Colleen, EFTA00023319
We wanted to follow up on this from last month. Please let us know? (And obviously we're past late July now, but we could look at dates and times for an interview this month.) thanks, From: Sent: Wednesday, Jul 08 2020 17:30 To: Colleen Cc: Ten Gibbs u Jec o ow-up Colleen, Thanks very much for being in touch, and we would like to speak with Ms. As a threshold question, would it be possible for you to share with us the documents from and email correspondence with Maxwell referenced in your email below? And is there a good date or dates later in July that would work for a phone or videoconference interview? again, From: Colleen Sent: Monday, Jul To: Cc: Teri Gibbs • 06 1.11 ow-up As stated earlier, Ms. worked for Ms. Maxwell (and, by extension, Jeffrey We wanted to follow up on ourprior email and offer to speak with our client Epstein). I confirmed with our client that she is willing to speak with you and wants to fully cooperate with the criminal investigation/action pending against Ms. Maxwell. She could be a valuable witness for you. Please let us know if you would like to speak with our client. We are happy to facilitate this conversation. Best, Colleen On Wed, Jan 29, 2020 at 12:57 PM r wrote: Received, thanks very much. From: Teri Gibbs Sent: Tuesday, Janua 28, 2020 19:08 To: Sulfite: Follow-up Hi As we discussed last week, our client, as in her possession documents from and email correspondence with Ghislaine Maxwell. Thus far, we have received authorization to share the list of office numbers Ms. used during her employment with Ghislaine Maxwell from 2003-2007. Please see attached. Please let us know if you have any questions. Best, Teri rt Wed Jan 22 2020 at 1:48 PM wrote: Will do, speak with you then. Thanks. EFTA00023320
From: Teri Gibbs Sent: W an 22 2020 16:44 To: Colleen u jec : e: o ow-up Great. Tomorrow at 12PM PST/3PM EST works. Please call our conference line at Best, Teri On We Jan 22, wrote: Teri, I can give you a call at 3:00 p.m. tomorrow (Thursday). Please let me know what number is best to reach you at, and I'll plan to call you then. Ns' From: Teri Gibbs Sent: Tuesda To: Cc: 21.2020 20:15 Subject: Re ow-up Wonderful,M. I am available tomorrow through Friday from 1PM-3PM EST. Please let me know what time works best for you. Best, Teri On Tue Jan 21, 2020 at 5:06 PM wrote: Teri, We would be happy to set up a call to speak with you and receive the new information—please let us know a few times this week that would work for you. From: Teri Gibbs Sen • • To: Cc: ; Colleen Su Re: Follow-up Hi I am following up regarding our cli nt and We have more information from Ms. that may be important to your investigation. Please let us know if you would like to speak with us over the phone or set up interviews with either of them. Best regards, Teri On Mon, Jan 6, 2020 at 1:12 PM Teri Gibbs > wrote: Great. Please call our conference line at . You should receive an invitation EFTA00023321
in a few moments from UberConference. You will not need a sign-in pin. Looking forward to our call on Wednesday at 12:30PM PST. Best, Teri wrote: Yes, we can do Wednesday at 12:30 p.m. PST (3:30 p.m. EST). Please let us know the best to reach you at, and we'll call you then. From: Teri Gibbs Sent: Monde Janua 06 2020 12: I lb Subject: Re: Witness re Prince We have a last-minute mediation that is now scheduled for Tuesday. Are you available on Wednesday between 10-11AM PST and 12-2PM PST or Thursday at any time between 9 AM-5PM PST? Thank you in advance for your flexibility. Best, Teri On Fri Jan 3, 2020 at 6:04 PM wrote: Teri, No problem, and thanks for getting back to us. We could do a call on Tuesday the 7th at 11:00 a.m. PST (2:00 p.m. EST). Please let us know the best number to reach you at, and we'll give you a call then. thanks, From: Teri Gibbs Subject: Re: Witness re Prince Hi Thank you for your response. I apologize for the delay. I hope you had a wonderful holiday. Attorney Lisa Bloom and I are available at the following times for a phone or video conference: • Tuesday (1/7) between LOAM-1PM PST • Wednesday (1/8) between 10-11AM PST and 12-2PM PST Please let me know if any of these times work for you. Best regards, Teri On Fri, Dec 20 2019 at 9:55 AM rote: Teri, Thanks for being in touch. In the first instance, before we would request an interview directly, it would be helpful for us to get a full attorney proffer from you about what the EFTA00023322
client's information is, what you expect she would convey in an interview, any relevant documentary or other corroborating materials, etc. That way we can make sure we're not re-victimizing any individual unnecessarily, and be efficient with any necessary follow-up interview of the individual him- or herself. Please let us know when a good time would be for an attorney proffer? And we can figure out scheduling. thanks very much, From: Teri Gibbs Se J 11111111 To: Cc: Sulii•Witness re Prince Hi We have a client who witnessed Prince interactions with= I would like to set up a phone or video interview with the appropriate party to allow our client to make a statement. Please let me know how to proceed. Best regards, Teri Gibbs Notice To Recipient: This e-mail is meant for only the intended recipient oldie transmission. and may be a communication privileged by law. If you received this e-mail in error, any review, use, dissemination, distribution or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return email and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service. we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used. and cannot be used. for the purpose of (dl avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing. or recommending to another party any transaction or matter addressed herein. Notice To Recipient: This e-mail is mean for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-mail in error. any review, use. dissemination. distribution or copying of this e-mail is strictly prohibited. Please notify us immediately of the Mier by return e-mail and please delete this message and any and all duplicate; of this message from your system. Thank you in advance for your cooperation. IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used. for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting. marketing. or recommending to another party any transaction or matter addressed herein. Notice le Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-mail in error. any review. use, dissemination. distribution or copying of this equal' is strictly prohibited. Please notify us immtxliately of the error by return e.nthil and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be tried, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Cale or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein. Notice To Recipient: This equall is meant the only the intended recipient of the transmission. and may be a communication privileged by law. If you received this e-mail in error, any review, use, dissemination, distribution. or copying of this e-mail is strictly prohibited. Please Mgt us immediately of the error by return equall and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service. we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of Wavoiding penalties EFTA00023323
under the Internal Revenue Code or (i it promoting, marketing. or recommending to another party any transaction or matter addressed herein. Notice To Recipient: This email is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-mail in error. any review use. dissemination. distribution, or copying of this e-mail is strictly prohibited. Plane notify us immediately or the error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for vxtur cooperation. IRS Circular 230 Disclosure: In order to comply with requirement imposed by the Internal Revenue Service. we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used. and cannot be used. for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting. marketing. or recommending to another party any transaction or matter addressed herein. Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission. and may be a conenunkation privileged by law. If you received this e-mail in error, any review. use. dissemination, distribution. or copying of this email is strictly prohibited. Please notify in immediately of the error by return email and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service. we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used. and cannot be used. for the purpose or (s) avoiding penalties under the Internal Revenue Code or ( ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein. Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e- mail in error, any review, use. dissemination. distribution or copying of this e-mail is strictly prohibited. Platte notify us immediately of the error by retum e-mail and please delete this message and any and all duplicates or this message from your system. Thank you in advance for your coaperation. IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any US. tax advice contained in thiscommunication (including any attachments) is not intended to be used. and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing. or recommending to another party any transaction or matter addressed herein. Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e- mail in error. any review. use. dissemination distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return email and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Interval Revenue Service. we inform you that any U.S. Lax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose 01(0 avoiding penalties under the Internal Revenue Code or (ii) promoting. marketing, or reconenending to another party any transaction or matter addressed heran. Colleen M. M, Esq. To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office. This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited. Colleen M. M, Esq. To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office. This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited. EFTA00023324
Colleen M. , Esq. To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office. This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited. Colleen M. M, Esq. To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office. This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited. Colleen M. M, Esq. To protect the health and safety of our clients and employees, and in compliance with local orders, The Bloom Firm has closed its physical offices until further notice. We are fully operational remotely. Attorneys and staff continue to be available via videoconference, email, telephone, and fax. Please do not send mail or attempt service at our physical office. This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited. <2020-07-31, GM, signed protective order (docketed).pdf> <2020-07-31, GM, memorandum & order granting government motion.pdf> <2020-07-28, government letter re protective order (docketed).pdf> EFTA00023325



