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From: " )" <
To: "Bloom, Suzanne Jaffe" < E>
Cc: "Hudgens, Johanna Rae"
Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
Date: Tue, 23 Jul 2019 18:55:12 +0000
Attachments: blank_proffer_agreement.pdf
Suzanne,
Following up on our conversations last week and yesterday, and in response to your email, we are available to meet with you and
Johanna next week. Given our continued discussions, and the possibility of a voluntary interview with Ms. we can confirm the
understanding that we are able to hold in abeyance the grand jury appearance date of July 24, 2019, until further notice.
As we covered on the phone yesterday, you should feel free to reach out to any of us on the team if you have any questions as you meet
with your client, and thank you in advance for copying all of our team on email communications, as we also discussed. I think I also
said that we would send you the docket numbers of the primary civil cases, which are 15 Civ. 7433 (RWS) (SDNY), 17 Civ. 616 (JOK)
(SDNY), and 08 Civ. 80736 (SDFL) (the CVRA litigation). I believe there are also a number of docketed civil cases involving Mr.
Epstein in federal court in Florida, and there may also be additional state cases.
Separately, I don't recall if I said we would send this, but in case it is useful for your consideration, attached is an example of our
standard proffer agreement.
In terms of scheduling, next week we are available at 2:30 on Monday; anytime on Tuesday except for 12:30 to 1:30; and at either 9:30
a.m. or 5:00 p.m. on Wednesday, due to a court conference and other meetings during the day.
Please let us know if we're forgetting anything or if any additional information would be useful, and we look forward to being in touch
soon.
Original Message
From: Bloom, Suzanne Jaffe cr ,.
Sent: Monday, July 22, 2019 12:32
To:
Cc: Hudgens, Johanna Rae
Subject: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
HiM. Thank you again for your time on the phone last week. I'm following up on our conversation. First, I'm writing to confirm that
we have now been formally retained in connection with the above-referenced matter. Second, we are available to meet with you on July
29 at 2 pm. Please let us know whether that date and time works for you. Finally, I want to confirm our understanding that the July 24,
2019 appearance date listed in the above-referenced grand jury subpoena has been adjourned and no appearance is required on that
date.
We look forward to hearing back from you regarding the above. Many thanks.
Best,
Suzanne
Suzanne Jaffe Bloom
Partner
Winston & Strawn LLP
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