This is an internal prosecution memo from December 2020 outlining a task list for the Ghislaine Maxwell criminal case, including witness interviews, evidence authentication, and discovery review.
This document is a status update email from the prosecution team handling the Ghislaine Maxwell case, sent approximately one year before her trial began in November 2021. It provides a comprehensive checklist of investigative tasks including reviewing Maxwell's emails in the Relativity document review system, authenticating evidence from Jeffrey Epstein's Palm Beach house, interviewing multiple witnesses and victims, and coordinating with the Palm Beach Police Department. The memo reveals the scale of the pre-trial preparation, with multiple redacted names indicating numerous witnesses and victims being interviewed or re-interviewed.
From: To: Subject: RE: Agenda Date: Mon, 07 Dec 2020 16:40:11 +0000 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 Interlochen 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 o1 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 0 Discuss with chiefs tomorrow re: superseder timing • Interview 0 Ask agents to contact and interview him (—within 2 weeks) • Re-interview (with counsel) 0 • Interview 0 Ask agents to contact him re: appointed counsel ( —within two weeks) Talk to agents about an interview, not a high priority • Interview Jo Jo Fontanella will contact his attorney re in person interview • Re-interview will contact his attorney re in person interview in January will review emails in Relativity • Interview and and other individuals on flights w/ o1 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) 0I 01 01 • Interview o1 mother will ask agents to interview by phone • Investigate immigration records/travel records re: EFTA00027433
o will take a look and work with agents • Interview I. will call Sigrid about a potential interview • Review deposition transcripts for GM (keeping in mind is approaching) o1 will send reminder • Tip-line leads that flagged o1 will flag for agents From: Sent: Wednesday, November 11, 20204:25 PM To: Subject: RE: Agenda Here's the task list, based on our conversation: • 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 Interlochen 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 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 Jo Jo Fontanella will contact his attorney re in person interview • Re-interview will contact his attorney re in person interview in January will review emails in Relativity • Interview and and other individuals on flights w/ • 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) • Interview mother o will ask agents to interview by phone EFTA00027434
• Investigate immigration records/travel records re: o will take a look and work with agents • Interview I. will call Sigrid about a potential interview • Review deposition transcripts for GM (keeping in mind IN is approaching) • will send reminder • Tip-line leads that flagged o will flag for agents From: Sent: Friday, November 6, 2020 2:12 PM To: Subject: RE: Agenda 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, 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: >; • *Records custodian from Interlochen • *Records custodian from the Professional Children's School • *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. 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 Interlochen 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 I. has searched all her emails for relevant communications • Potentially interview • Potentially re-interview • Meet with • Interview • Interview • Interview Jo Jo Fontanella • Re-interview client EFTA00027435
• Interview and • 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 IM (with counsel) • Interview. • Review deposition transcripts for GM (keeping in mind IMI is approaching) • Tip-line leads that flagged Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00027436


