EFTA00090575.pdf

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: RE: SDNY investigation 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 11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025 Tel: Fax Email: Web: www.psblaw.com 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. 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 EFTA00090575 responsible for any statutes of limitations or other deadlines for your case or potential case. Ori inal Messa e From: [mailto: Sent: Wednesday, February 12, 2020 8:51 AM To: Robert Glassman Cc: ; Nathan Werksman u jest: : investigation Robert, Kevin Boyle Just as a brief heads up, were in the process of requesting certain student records from schools- previously attended, to corroborate aspects of the relevant timeline, and some of those entities may take the position that they need to notify her of our requests. Rather than have her hear that in the first instance from them, we wanted to let you know. As you would expect, we have not referenced the Epstein investigation in our communications with any of those entities, or in the subpoenas, but again in an abundance of caution we wanted to reach out so you knew. thanks, Ori inal Messa e From: Sent: Monday, Februa 10 2020 17:09 To: Robert Glassman Cc: ;I~~~) ana; Nathan Werksman ; Kevin Boyle Subject: RE: SDNY investigation Confirmed, thanks -- see you at 11:00 on the 27th. Original Message From: Robert Glassman Sent: Monda Febru To: Cc: Nathan Werksman Subject: RE: SDNY investigation Yes. See you then. ; Kevin Boyle Robert Glassman, Esq. Panish Shea & Boyle LLP 111 11 Sant oulevard, Suite 700 Los Angeles, CA 90025 Tel: Fax Email: Web: www.psblaw.com CONFIDENTIALITY NOTICE: This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any EFTA00090576 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. 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. Ori inal Messa e From: [mailco: Sent: Saturday, Februa 08 2020 11:59 AM To: Robert Glassman C Cc: ; Nathan Werksman Subject: RE: SDNY investigation Great, thanks. Should we plan for 11:00 again? Or let us know if you prefer a different time, we should be flexible. Original Message Frida Febru On From: Robert Glassman Sent: To: Cc: Nathan Werksman ‹ ; Kevin Boyle Subject: RE: SDNY investigation ; Kevin Boyle 2/27 works. Thanks, and see you then. Robert Glassman, Esq. Panish Shea & Boyle LLP 11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025 Tel: Fax: Email: Web: www.psblaw.com 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. 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. Original Message EFTA00090577 From: Sent: Friday, February 07, 2020 3:08 PM To: Robert Glassman Cc: [mailto: ; Nathan Werksman < ; Kevin Boyle Subject: RE: SDNY investigation Robert, We should be able to do any time Wednesday through Frida.h-28th) of that week, with a preference for Thursday the 27th if that would be convenient for you and What's good on your end? thanks, Original Messa e From: Sent: Friday, February To: Robert Glassman Cc: Nathan Werksman Subject: RE: SDNY investigation Robert, aNIMIE>, ; Kevin Boyle <11.1e> Thanks very much for getting back to us -- I left a voicemail just a few minutes ago, hadn't yet seen your email, but we'll figure out the team's schedule and get back to you very shortly. That should work, but let us confirm. thanks, Original Message From: Robert Glassman -c i> Sent: Frida , Februa 07 2020 15:43 To: Cc: Nathan Werksman Kevin Boyle Subject: Re: SDNY investigation how's the week of 2/24 instead? That's better for her. Robert S. Glassman Panish Shea & Boyle psblaw.com > On Feb 6, 2020, at 11:08 AM, a a wrote: > Robert, > We're still hoping to try to schedule an interview with on February 19 (or the following couple days), EFTA00090578 per the below -- would that be a possibility? I'll give you a call tomorrow if we haven't connected by then but wanted to bump this from last week. Thank you! > Original Messa > From: > Sent: Friday, January 31 2020 14:01 > To: 'Robert Glassman' > Cc: 'Nathan Werksman' ; 'Kevin > Subject: RE: SDNY investigation > Robert, > Wanted to follow up on the below in case it was still useful to chat -- some combination of the team will be around next week if you want to have a call. > Separately, we're continuing to move forward with the investigation, including interviews with members, and we wanted to see if we might be able to put something on the calendar to come talk with again once we've completed those steps. Would it work for you and her to meet anytime noon or later on February 19? Or if not the 19th, any availability on the 20th or 21st? > thanks very much, > Ori inal Messa e > From: > Sent: Friday, January 2 • > To: Robert Glassman > Cc: ; Nathan Werksman Kevin > Subject: RE: SDNY investigation > Robert, > Apologies for the belated reply, it's been a crazy week for us, but we'd be happy to talk. We should be generally available tomorrow (Friday) until about 2 p.m. our time, or also early next week if that's easier. > thanks, >ME > Original Message > From: Robert Glassman > Sent: Wednesday. January 21 2020 15:39 > To: > Cc: Nathan Werksman ; Kevin EFTA00090579 > Subject: Re: SDNY investigation > Thanks MI ended up seeing these too. > Our judge is John Koeltl and the magistrate is Barbara Moses. > Moskowitz already reached out to us. > Is there a good time to chat? > Robert S. Glassman > Panish Shea & Boyle > psblaw.com >> On Jan 20, 2020, at 1:11 PM, C wrote: » Robert, » Thanks very much for sending the complaint, we appreciate it. We'll try to keep an eye on the docket, but if you wouldn't mind letting us know when a judge is assigned, that would also be helpful. In terms of media, it was covered in the Daily News on Friday, here: >> https://vvww.nydailynews.com/new-yorlc/ny-epstein-trump-victim-suit-202 >> 00118-m6sqsa2h7venpf3uewjrkvigo4-story.html >> And then picked up by the Post and other outlets on Saturday: >> https://nypost.corn/2020/01/18/new-jeffrey-epstein-accuser-says-he-mol >> ested-her-at-13-told-her-to-wear-childrens-underwear/ >> https://www.the-sun.corn/news/274369/jeffrey-epstein-first-victim-kids >> -underwear/ >> https://www.dailymail.co.ukJnews/article-7901651/Woman-claiming-Jeffr >> ey-Epsteins-victim-says-introduced-Trump-age-14.html » thanks, >> Original Message >> From: Robert Glassman >> Sent: Friday, January 17. 2020 22:18 » To: » Cc: ; Nathan Werksman >> Subject: RE: SDNY investigation sorry for not giving you a heads up on this. That was not my intent. Just been really busy with a couple ofilMig matters going on now. Please see attached. What media is picking it up? I don't see anything. >> » Robert Glassman, Esq. » Panish Shea & Boyle LLP >> 11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025 EFTA00090580 » Tel: » Fax » Email >> Web: www.ps aw.com >> >> 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. >> 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. >> » Ori » From: » [mailto: >> Sent: Friday, January 17 2020 4:52 PM >> To: Robert Glassman » Cc: inal Messa e >> Nathan Werksman >> Subject: RE: SDNY investigation » Robert, >> Based on media reports today it looks like you filed the civil lawsuit? I don't think we realized that was imminent -- could we ask you to please send us a copy of the filing? I don't yet see it on PACER. >> Original Messa e » From: >> Sent: Monday, December 30, 2019 22:28 >> To: Robert Glassman » Cc: ; 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: Monday, December 30, 2019 22:20 EFTA00090581 » 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, wrote: >» >» Robert, >» for us to begin reachin out this week to the contacts she idellMs -- in articular, w w Id in:. >>> Following up on our most recent meeting with you and we wanted to confirm that it's alright is to contact and and then an We also wanted to see if it we are able at this stage to contact her mot er, w o is po en is y a key witness -- I know had wanted to speak with her mother in advance of us doing that. Please let us know if it's alright to m e t ose calls? And separately, if you could please let us know if her brother has since we last spoke -- no problem at all if not, but I think she happened to have any contact with mentioned that was a possibility so wanted to check. >» >>> Thanks very much, and hope you're having a good holiday season. >» >» thanks again, » a >» >» >>> -----Ori inal Messa e >» From: >>> Sent: Friday, December 13, 2019 17:06 >» To: Robert Glassman < >» Cc: >>> ; Nathan Werksman >>> Subject: RE: SDNY 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 Glassman >>> Sent: Frida December 11.1. Mi >» From: Robert >» To: >» Cc: >>> ; Nathan Werksman < >>> Subject: Re: SDNY investigation >» EFTA00090582 >» unfortunately, we can't do earlier than 11. She just needs time to get to my office after taking care of kid stu 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 1:3o 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 left 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 headed if and when an interview of her were to be appropriate. >>» >>» >>» >>>> Ori inal Messa e----- »» From: >>>> Sent: Wednesday, December 11, 2019 13:15 »» To: Robert Glassman C >>» Cc: ; Nathan Werksman >>» >>>> u ject: inves igation >>» >>>> 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 f that would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent s comfortable with that at this stage. And we'll also likely refresh on some other topics as well, bu jus o ag 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: Wednesda Decem er , : >>» To: >>>> Cc: EFTA00090583 ; Nathan Werksman >>>> >>>> u jec : : wives igation >>» >>>> Let's do 11 a.m. on Monday. >>» >>» Robert Glassman, Esq. >>>> Panish Shea & Boyle LLP >>>> 11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025 »» Tel: »» Fax »» Email: »» Web: www.psblaw.com >>» >>» 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. >>» >>>> 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. >>» >>» >>>> ----Original Messa »» 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 p uesi • 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 ay if that ends up being useful as well. >>» >>» thanks, >>» >>» >>>> -----Original Message----- »» From: Robert Glassman >>>> Sent: Tuesday. December »» To: »» Cc: ; Nathan Werksman >>>> EFTA00090584 >>>> 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 wi anytime this coming Sunday, Monday, or Tuesday, if any of those work? Also, if it's at all posse e o ef er 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, >>>»= >>>» >»» Ori inal Messa e >»» From: >>>>> Sent: Monday, Decemb >»» To: Robert Glassman < >>>» >>>» >>>» >>>>> 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 Message---- >>>» From: Robert Glassman >>>>> Sent: Monday. Decembe >»» To: >>>» Cc: >>>» >>>» >>>>> Subject: Re: SDNY investigation >>>» >»» Yes. Call me on my cell today. >>>» >>>» >»» Robert S. Glassman >»» Panish Shea & Boyle >»» psblaw.com >>>» ; Nathan Werksman ; Nathan Werksman EFTA00090585 >>>» >>>>>>> On Dec 9, 2019, at 9:21 AM, 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 >>>>» >>>>» >>>>» 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, >>»».= >>>>» >>>>» >>»» Original Message >>»» From: Robert Glassman >>>>>> Sent: Friday. November 2 : >>>>>>. To: >>>>» Cc: ; Nathan Werksman >>>>» >>>>» >>>>» 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: >>>>>>> >>>>>> EFTA00090586