EFTA00024410.pdf

From: "Moyne, Parvin" <[Redacted]>
To: "[Redacted]" <[Redacted]>, "[Redacted]" <[Redacted]>
Cc: "Moyer, Thomas" <[Redacted]>
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Date: Tue, 20 Aug 2019 18:03:17 +0000

[Redacted] –

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: [Redacted] <[Redacted]>
Sent: Monday, August 19, 2019 8:14 PM
To: Moyne, Parvin <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Cc: Moyer, Thomas <[Redacted]>
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,
[Redacted].

From: Moyne, Parvin <[Redacted]>
Sent: Monday, August 19, 2019 12:04
To: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Cc: Moyer, Thomas <[Redacted]>
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx

EFTA00024410

Hi [Redacted] –
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: [Redacted] <[Redacted]>
Sent: Saturday, August 17, 2019 1:59 PM
To: Moyne, Parvin <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Cc: Moyer, Thomas <[Redacted]>
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,
[Redacted].

From: Moyne, Parvin <[Redacted]>
Sent: Thursday, August 15, 2019 09:48
To: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Cc: Moyer, Thomas <[Redacted]>
Subject: 2019.8.15 - SDNY Production Index.xlsx

[Redacted], [Redacted] & [Redacted],

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 LLP
One Bryant Park | New York, NY 10036-6745 | USA | Direct: +1 [Redacted] | Internal: [Redacted]
Fax: +1 [Redacted] | [Redacted] | akingump.com | Bio

EFTA00024411

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EFTA00024412