EFTA00023283.pdf

From: ' To: Jill Greenfield Subject: RE: Epstein investigation Date: Sun, 23 Feb 2020 00:17:13 +0000 Inline-Images: image001.jpg If I happen to have stepped away from my desk when you call, please feel free to try my cell -- thanks again, From: Jill Greenfield Sent: Saturday, February 22, 2020 17:09 To: Cc: Kyle Phillips c) ; Louise Scott c Subject: Re: Epstein investigation Thanks- Understood I will call tomorrow Regards Jill Greenfield Partner D: Personal Injury Team of the Year - Solicitors Journal Awards 2017 Sent from my iPhone On 22 Feb 2020, at 21:51, > wrote: Jill, No problem at all, we understand this takes time, and we appreciate you getting back to us, and we're very grateful that your client is open to speaking with us. On your questions, we are certainly fine with the first two questions / requests — we're happy to meet with you and your client in an initial conversation, during which we can do the kind of introductions and explanations we've done with you (and that we do with all victim witnesses we meet), including answering any questions to the best of our ability, and then to take a break and have a more substantive discussion later on. EFTA00023283 Regarding the friend, does that individual also represent her as counsel? We aren't normally able to include individuals in addition to the witness and counsel in an interview—what does sometimes work is for someone who is providing support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness wants to speak with that person, which would of course be totally fine in this instance. Or if he represents her in his capacity as an attorney then he of course could be in the interview in that role (with the only caveat that we would just want to confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not able to pay for third parties (including counsel) to travel in connection with witness interviews, though — if it's preferable, we certainly could pay for your client's travel to the U.S. for the interview, including airfare and lodging, if that makes it easier for the friend to be present? And we're happy to discuss any of this further by email or phone if that's useful — I'll be at my desk for the next several hours and most of tomorrow, at or we could also set a time to chat, whatever would be helpful. thank you, From: Jill Greenfield < Sent: Saturday, February 22, 2020 13:55 To: Cc: Kyle Phillips ca ; Louise Scott < Subject: RE: Epstein investigation Hello Apologies for the slight delay. My client is willing to help but asks the following: • That there be a morning meeting at which introductions with a discussion as to the investigation and my clients involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist. • In the afternoon and after a break, my client would be willing to answer questions, in so far as she can. • That a friend of hers be allowed to be present as well. However that friend is based in the US and would need to be flown over to London. He is a US lawyer. Perhaps you could let me know if this is possible? Kind regards, Jill Jill Greenfield Partner D: M: Personal Injury Team of the Year - Solicitors Journal Awards 2017 kirnage001.jpgd From: ) Sent: Saturday, February 15, 2020 7:08 PM To: Jill Greenfield Cc: Kyle Phillips ; Louise Scott ‹ ; EFTA00023284 Subject: RE: Epstein investigation Understood — thanks very much. From: Jill Greenfield Sent: Saturday, February 15, 2020 07:22 To: Cc: Kyle Phillips c Louise Scott < Subject: Re: Epstein investigation Thanks This is helpful. I've gone back to my client with this. I will be back in touch shortly. Regards Jill Jill Greenfield Partner MD: Personal Injury Team of the Year - Solicitors Journal Awards 2017 kirnag e003.jpgd Sent from my iPhone On 14 Feb 2020, at 21:43, > wrote: Jill, Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding some of the additional follow-up questions you asked, and to describe in more detail for your client how we would expect to approach any discussion with your client if she were comfortable meeting with us. The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the decision to meet with us but also as to any topic or question—your client would be absolutely free to determine what topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything that would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell her, as we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is no problem at all. In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves, explained the status of our investigation, talked about how a discussion would proceed if your client ended up being comfortable with that, and answered in person any questions she. We have done that previously, where we do the talking rather than asking questions in an initial meeting, and that would of course be without any requirement for anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are able EFTA00023285 to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or victimization she experienced. We wrote in our first email that we would primarily be interested in talking about topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as always we would be guided by her comfort level. In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell you in advance if there came a time when we thought that might be important to address, and how we could facilitate that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure you that every one of us has now spoken with dozens of victims in this case, and every one of us has extensive experience more generally working with victims and working on cases involving sex offenses. We are proud of how we have been able to work with victims in this case especially, given all of the circumstances, and we absolutely would take the same sensitive approach with your client as we have with the many other victims in this case who have spoken with us. Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how our process works, and answer any questions your client has in person, we would absolutely be happy to do that with no obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could just address the general subject of her employment, for example. But no obligation and no