EFTA00024410.pdf

From: "Moyne. Parvin" -- To: Cc: "Moyer, Thomas" <I Subject: RE: 2019.8.15 - SDNY Production Index.xlsx Date: Tue, 20 Aug 2019 18:03:17 +0000 - Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from DB Legal) deliver a presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we have provided so you can more readily identify whatever information you are most interested in. Following the proffer, if there are particular accounts or transactions of interest, we can identify the person within DB who can best answer questions on those areas and that person would then meet with you. In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.) Best, Parvin From: Sent: Monday, August 19, 2019 8:14 PM To: Moyne, Parvin Cc: Moyer, Thomas Subject: RE: 2019.8.15 - SDNY Production Index.xlsx Parvin, Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with Deutsche Bank personnel, etc? And approximately how long should we be planning to block out? thanks, From: Moyne, Parvin Sent: Monday, August 19, 2019 12:04 To: Cc: Moyer, Thomas Subject: RE: 2019.8.15 - SDNY Production Index.xlsx > >;I <->; EFTA00024410 Hi MI — The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most sense on your ends. We have time this week (Thursday or Friday afternoon) and next week (Monday — Wednesday), and we have time in September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends. Best Parvin From: Sent: Saturday, August 17, 2019 1:59 PM To: Moyne, Parvin Cc: Moyer, Thomas Subject: RE: 2019.8.15 - SDNY Production Index.xlsx **EXTERNAL Email" Parvin, We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and trials in the next couple weeks, but we could do early September if that works on your end. Thoughts? thanks, From: Moyne, Parvin Sent: Thursday, August 15, 2019 09:48 To: <E > ) <->; Cc: Moyer, Thomas < Subject: 2019.8.15 - SDNY Production Index.xlsx ~•~&~ Please find attached an index to our productions to date. This is a work in progress — we will update it as we gather and produce additional documents. Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m. Best, Parvin Parvin Daphne Moyne AKIN GUMP STRAUSS HAUER & FELD LLF, One Bryant Park New York, NY 10036-6745 USA I Direct: +1 Fax: +1 I I akingump.own Bio I Internal: MI EFTA00024411 The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e- mail, and delete the original message. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e- mail, and delete the original message. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e- mail, and delete the original message. EFTA00024412