EFTA00024413.pdf
efta-20251231-dataset-8 Court Filing 141.1 KB • Feb 13, 2026
From:
To: "Moyne, Parvin"
Cc: "Moyer, Thomas"
, " "
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Date: Wed, 21 Aug 2019 03:58:21 +0000
Parvin,
That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early
September, if we can — is there a time during the afternoon of September 5 or the morning of September 6 that would
work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the
following week.
thank you,
From:
Moyne, Parvin
Sent: Tuesday, August 20, 2019 14:03
To:
< >;
)
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
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
EFTA00024413
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, 201912:04
To:
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
<->:
Hi —
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:
cE>
1.S
)
<->:
EFTA00024414
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,
New York, NY 10036-6745 I USA I Direct: +1
Fax: -1
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alSgialp.COm I PI3
Internal:M
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- Feb 13, 2026