EFTA00092486.pdf

From: Kevin Boyle To: Robert Glassman Cc: Nathan Werksman Subject: Re: SDNY investigation Date: Wed, 12 Feb 2020 16:58:56 +0000 Also all— No objection that I can see from ud regarding these subpoenas (without having see. them), but note that some states (CA at least, in civil cases) a "Notice to Consumer" must be done with subpoenas like this. If it is not done, then the entity can not produce anything demanded in the subpoena. I'm not sure if the same requirement applies to criminal subpoenas. Kevin R. Boyle www.psblaw.com > On Feb 12, 2020, at 8:55 AM, Robert Glassman < wrote: > 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 > 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 e > From: [mailto: > Sent: Wednesday, Febru. 12, 2020 8:51 AM > To: Robert Glassman > Cc: ; Nathan Werksman Kevin Boyle EFTA00092486 > Subject: RE: SDNY investigation > Robert, > Just as a brief heads up, we're 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, February 10, 2020 17:09 > To: Robert Glassman < > Cc: Nathan Werksman ; Kevin Boyle < > Subject: RE: SDN > Confirmed, thanks -- see you at 11:00 on the 27th. > Original Message > Sent: Monda Februa > From: Robert Glassman > To: > Cc: Nathan Werksman ; Kevin Boyle < > Subject: RE: SDN v s iga ion > Yes. See you then. > Robert Glassman, Esq. > 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. Los Angeles, CA 90025 EFTA00092487 > Ori inal Messa e > From: ) [mailto: > Sent: Saturday, Februa 08 2020 11:59 AM > To: Robert Glassman > Cc: ; Nathan Werksman ; Kevin Boyle >11 ,11. 1 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 > From: Robert Glassman -cl IWS > Sent: Frida , February 07. 2020 I v:-{ I > To: > Cc: Nathan Werksman > Subject: RE: SD > 2/27 works. Thanks, and see you then. > Robert Glassman, Esq. > Panish Shea & Boyle LLP > 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 e > From: [mailto: > Sent: Friday, February 07, 2020 3:08 PM > To: Robert Glassman < > Cc: Kevin Boyle Los Angeles, CA 90025 Nathan Werksman • ; Kevin Boyle > Subject: RE: SDNY investigation EFTA00092488 > Robert, > We should be able to do any time Wednesday through Frida 26th-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, > Ori inal Messa e > From: > Sent: Friday, February 07, 2020 15:52 > To: Robert Glassman < > > Cc: • cz iMIW; Nathan Werksman ; Kevin Boyle > Subject: RE: SD > Robert, > 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 > Sent: Frida Febru. 07 > To: > Cc: Nathan Werksman < ; Kevin Boyle < > Subject: Re: SD > I, 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, C wrote: » Robert, >> We're still hoping to try to schedule an interview with an February 19 (or the following couple days), 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 Message----- EFTA00092489 » 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 24 2120 03:45 » 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, >> Original Message » From: Robert Glassman alla >> Sent: Wednesda Janu. 22, 2020 15:39 » To: » Cc: >> • ; Nathan Werksman < ; Kevin >> Subject: Re: SDNY investigation >> » Thanks I ended up seeing these too. >> Our judge is John Koeltl and the magistrate is Barbara Moses. >> Moskowitz already reached out to us. EFTA00092490 >> » Is there a good time to chat? >> >> Robert S. Glassman » Panish Shea & Boyle » psblaw.com >>>> On Jan 20, 2020, at 1:11 pm, wrote: >» >» >» >>> 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.corn/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://vvvvw.the-sun.corn/news/274369/jeffrey-epstein-first-victim-kids >>> -underwear/ >>> https://www.dailymail.co.uk/news/article-7901651/Woman-claiming-Jeffr >>> ey-Epsteins-victim-says-introduced-Trump-age-14.html >» >» thanks, >»lim >» >» >» -----Original Message >» From: Robert Glassman >>> Sent: Friday. January 17 >» To: >» Cc: >» ; Nathan Werksman >>> Subject: RE: SDNY investigation >» ll >>>i sorry for not giving you a heads up on this. That was not my intent. Just been really busy with a cou other big 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 >» >» >» >» >» Web: www.psblaw.com >» >» CONFIDENTIALITY NOTICE: Robert, Los Angeles, CA 90025 EFTA00092491 >>> 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 >>> From: >>> [mailto: >>> Sent: Friday, January 17.2020 4:52 PM >>> To: Robert Glassman >>> Cc: ; 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. >>> >>> thanks, >>>- >>> >>> -----Ori inal 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 Glassman >>> Sent: Monda DecembilIPPW >>> From: Robert >>> To: >>> Cc: >» ; Nathan Werksman < >>> Subject: Re: SDNY investigation >>> >>>..- yes, all good to contact those folks. Thanks for checking in. EFTA00092492 >» >» >» Robert S. Glassman >» Panish Shea & Boyle >» psblaw.com >» >» >>>» On Dec 30, 2019, at 1:10 PM, C <C> wrote: >>» »» Robert, >>» >>>> Following up on our most recent meeting with you and we wanted to confirm that it's alright for us to begin reaching out this week to the contacts she identified for us -- in articular we would initial) expect to contact and and then ele also want e if it we are able at this stage to contact her mot er, w o is potentially a key Mir-- I know Ms. had wanted to speak with her mother in advance of us doing that. Please let us know if it's alright to make those calls? And se arately, if you could please let us know if her brother has happened to have any contact with since we last spoke -- no problem at all if not, but I think she mentioned that was a possibility so wante to c eck. >>» >>.» Thanks very much, and hope you're having a good holiday season. >>» >>» thanks again, >>»- >>» >>» >>>> -----Ori inal Messa e »» From: ) >>>> Sent: Friday, December 2019 17: >>» To: Robert Glassman < >>» Cc: >>» ; Nathan Werksman >>>> Subject: RE: SONY 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 »» From: Robert Glassman: • >>>> Sent: Friday, December I 3. 2019 16:14 »» To: >>>> Cc: >>>> ; Nathan Werksman >>>> Subject: Re: SDNY investigation >>» >>» kid stil l. unfortunately, we can't do earlier than 11. She just needs time to get to my office after taking care of >>>> 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. >>» >>» EFTA00092493 >>>> Robert S. Glassman »» Panish Shea & Boyle >>» psblaw.com >>» >>» >>>>» On Dec 12, 2019, at 1:30 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 mi e possible to tell us where Ms. 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. >>>» >»» thanks, »»>- »»> >»» -----Ori inal Messa e >»» From: >>>>> Sent: Wednesday, December 11 2019 13:15 >»» To: Robert Glassman < >>>» Cc: ; Nathan Werksman >>>» < >>>» Subject: RE: SDNY investigation >>>» >>>>> 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 form would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent Ms. is comfortable with that at this stage. And we'll also likely refresh on some other topics as well, but j 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 December : >»» To: >>>» Cc: ; Nathan Werksman >>>» >>>» Subject: RE: SDNY investigation >>>» >>>>> Let's do 11 a.m. on Monday. >>>» EFTA00092494 >»» Robert Glassman, Esq. >»» Panish Shea & Bo le LLP >>>» os Angeles, CA 90025 >>>» >>>» >>>» >»» 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 >»» From: >»» [mailto: >>>>> Sent: Wednesday, December 11 2019 8:26 AM >»» To: Robert Glassman < >>>» Cc: ; Nathan Werksman >>>» >>>>> u ject: investigation >>>» >»» Robert, >>>» >>>>> That's great, thanks very much. Do you have a preference on timing? Anytime that morning starting at 10:00 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 Tuesday if that ends up being useful as well. >>>» >»» thanks, >>>» >>>» >>>» >>>» Original Message----- >>>>> Sent: Tuesda Decembe >>>» From: Robert Glassman >»» To: >>>» Cc: ; Nathan Werksman >>>>> >>>>> u jec : e: roves igation >>>» >>>>> Monday morning works at my office. Tuesday may also work too if you need more time. But confirm for Monday. >>>» >>>» EFTA00092495 >»» 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 with anytime this coming Sunday, Monday, or Tuesday, if any of those work? Also, if it's at all possible to either 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, December 09 2019 17:46 >>»» To: Robert Glassman >>>>» Cc: ; Nathan Werksman >>»» <werksman a sblaw.com>; >>>>» >>>>>> 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,December , : >>»» To: >>>>» Cc: ; Nathan Werksman >>>>>> <werksman a sblaw.com>; >>>>» >>>>» Subject: Re: SDNY investigation >>>>» >>»» Yes. Call me on my cell today. >>>>» >>>>» >>»» Robert S. Glassman >>»» Panish Shea & Boyle >>»» psblaw.com >>>>» >>>>» >>>>>>» On Dec 9, 2019, at 9:21 AM, -ca wrote: >>>>>» >>>>>» Robert, >>>>>» EFTA00092496 >>>>>>> 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----- >>>>>>> Sent: Frida November >>>>>» From: Robert Glassman >>>>>» To: >>>>>» Nathan Werksman >>>>>» >>>>>» >>>>>» Subject: Re: SDNY investigation >>>>>» >>>>>» Thanks. Cell is bes >>>>>» >>>>>» >>>>>» Robert S. Glassman >>>>>» Panish Shea & Boyle >>>»» psblaw.com >>>>>» >>>>>» >>>>>>>>> On Nov 22 2019 at 10:14 AM, wrote: >>>>>>>> >>>>>>> EFTA00092497