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=== Page 1 ===
From:
Subject: Accepted: Mark Epstein Meeting
Date: Mon, 04 Nov 2019 14:18:51 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-2413
V. Maxwell "Motion Order FILED"
Date: Fri, 09 Oct 2020 20:04:58 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 10/09/2020
Case Name:
V. Maxwell
Case Number: 20-2413
Document(s): Document(s)
Docket Text:
MOTION ORDER, letter requesting re-aligment of argument time is GRANTED [132] filed by Appellant
Ghislaine Maxwell, FILED. [2949579][138] [20-2413]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
, Deputy Clerk
Quality Control 1
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The following document(s) are associated with this transaction:
Document Description: Motion Order FILED
Original Filename:
.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/09/2020] [FileNumber=2949579-0]
[1eb91beb235262f13f29a77d3c8a8ad9e45ccd46173bced754d297a5ab68e653e60959431bb9416903028178204a
1e334a3a8f3eb96d15906948a04d32bebd21]]
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=== Page 1 ===
Curriculum Vitae
DAWN M. HUGHES, PH.D. ABPP
2020
PROFESSIONAL ADDRESS
EDUCATION
1996
Doctor of Philosophy in Clinical Psychology
Nova Southeastern University, Fort Lauderdale, FL
1992
Master of Science in Clinical Psychology
Nova Southeastern University, Fort Lauderdale, FL
1988
Bachelor of Arts in Psychology
Hamilton College, Clinton, NY
PROFESSIONAL TRAINING
9/96 - 9/97
Postdoctoral Fellow - Research Associate in Psychiatry
Weill Cornell Medical College - New York Presbyterian Hospital
Anxiety and Traumatic Stress Program - Payne Whitney Clinic
New York, NY
6/94 - 6/95
Predoctoral Intern
Yale University School of Medicine - Department of Psychiatry
Substance Abuse Treatment Unit and West Haven Mental Health Clinic New
Haven, CT
CURRENT POSITIONS
1998 - Present
Independent Practice in Clinical and Forensic Psychology
Specialization in Traumatic Stress, Interpersonal Violence and
Anxiety Disorders
2010 - Present
Clinical Assistant Professor of Psychology in Psychiatry
Weill Cornell Medical College - New York Presbyterian Hospital
New York, NY
LICENSURE & BOARD CERTIFICATION
1997
New York Licensed Psychologist
2005
Board Certification in Forensic Psychology - American Board of Professional Psychology
2015
Connecticut Licensed Psychologist
2015
North Carolina Licensed Psychologist
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Dawn M. Hughes, Ph.D. ABPP
Page 2 of 7
PROFESSIONAL AFFILIATIONS
American Psychological Association (APA)
American Psychology and Law Society
Division of Trauma Psychology
Psychologists in Independent Practice
Society for the Psychology of Women
New York State Psychological Association (NYSPA)
American Board of Professional Psychology (ABPP)
Fellow - American Academy of Forensic Psychology (AAFP)
International Society for Traumatic Stress Studies (ISTSS)
Anxiety Disorders Association of America (ADAA)
Women's Mental Health Consortium (WMHC)
International Society for the Study of Trauma and Dissociation (ISSTD)
PROFESSIONAL ACTIVITIES
American Psychological Association (APA)
Council of Representatives - Division of Trauma Psychology - 2018-present
Member-at-Large - Division of Trauma Psychology - 2013-2014
Leadership Institute for Women in Psychology - 2011-2012
Awards Chair - Division of Trauma Psychology - 2010-2012
Convention Program Co-Chair - Division of Trauma Psychology 2008-2010
Women's Mental Health Consortium
President 2009-2017
Membership Chair 2007-2009
International Society for Traumatic Stress Studies (ISTSS)
Program Committee 2001
CLINICAL EXPERIENCE
1/97 - 9/97
Clinical Diagnostic Interviewer
Rockefeller University-Laboratory of Human Neurogenetics, NY, NY
9/92 - 8/93
Psychology Extern
Veterans' Administration Outpatient Clinic, Oakland Park, FL
9/91 - 8/92
Psychology Extern
Family Violence Program, Nova University, Fort Lauderdale, FL
9/90 - 6/91
Psychology Trainee
Nova University Community Mental Health Center, Lauderhill, FL
5/91 - 11/91
Crisis Clinician
Nova University Crisis Services, Fort Lauderdale, FL
5/89 - 7/90
Legal Services Assistant
The Legal Aid Society - Federal Defenders Services Unit, New York, NY
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Dawn M. Hughes, Ph.D. ABPP
Page 3 of 7
5/88 - 5/89
Substance Abuse Counselor
Narco Freedom, Bronx, NY
10/87 - 5/88
Field Study Intern
Central New York Psychiatric Center, Marcy, NY
TEACHING EXPERIENCE
2002 - 2010
Clinical Instructor of Psychology in Psychiatry
Weill Cornell Medical College, New York, NY
New York Presbyterian Hospital - Payne Whitney Clinic
1998 2000
Consultant: Professional Development, Education and Training
Victim Services, New York, NY
9/92 - 12/92
Teaching Assistant
9/93 - 12/93
Nova Southeastern University, Fort Lauderdale, FL
Courses: Advanced Research Design and Intermediate Statistics
RESEARCH EXPERIENCE
5/92 - 5/94
Research Coordinator
Sexual Abuse Survivors Program
Nova University Community Mental Health Center, Fort Lauderdale, FL
9/91 - 5/94
Research and Statistical Consultant
Nova University - Fort Lauderdale, FL
PUBLICATIONS
Tardiff K. and Hughes, D.M. (2011). Structured and clinical assessment of risk of violence. In
Drogin et al. (Eds.) Handbook of Forensic Assessment: Psychiatric and Psychological Perspectives, John Wiley &
Sons, Inc., New Jersey
Hughes, D.M. & Cloitre, M. (1999). Rape and sexual assault among adult women. In K. Tardiff
(Ed.). Medical Management of the Violent Patient, Marcel Dekker, Inc., New York
Gold, S.N., Hughes, D.M. & Swingle, J. (1999). Degrees of memory of childhood sexual abuse
among women survivors in therapy. Journal of Family Violence, 14, 35-46.
Gold, S.N., Elhai, J., Lucenko, B.A., Swingle, J.M., & Hughes, D.M. (1998). Abuse characteristics
among childhood sexual abuse survivors in therapy: A gender comparison. Child Abuse and Neglect,
22, 1005-1012.
Hughes, D.M. (1996). Memory for childhood sexual abuse: Prevalence and relationship to abuse
characteristics and psychological effects. Doctoral dissertation.
Gold, S.N., Hughes, D.M. & Swingle, J. (1996). Characteristics of childhood sexual abuse among
female survivors in therapy. Child Abuse and Neglect, 20, 323-335.
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Dawn M. Hughes, Ph.D. ABPP
Page 4 of 7
Gold, S.N., Hughes, D.M. & Hohnecker, L. (1994). Degrees of repression of sexual abuse
memories. American Psychologist, 49, 441-442.
PROFESSIONAL PRESENTATIONS
Hughes, D.M. and Rocchio, L.M. (August 2014). Essentials of Forensic Assessment of Trauma in Criminal
and Civil Matters. Presentation at the 122nd Annual Convention of the American Psychological
Association, Washington, D.C.
Hughes, D.M. (November 2013). It Matters: The Developmental Lifespan of the Trauma Therapist.
Symposium presentation at the 30th Annual Meeting of the International Society for the Study of
Trauma and Dissociation, Baltimore, MD
Hughes, D.M. (November 2011). Conceptualization of Complex Trauma and PTSD in Forensic Matters.
Panel presentation at the 27th Annual Meeting of the International Society of Traumatic Stress
Studies, Baltimore, MD
Hughes, D.M. (August 2011). Assessment of Complex Trauma in a Forensic Setting.
Presentation at the 119th Annual Convention of the American Psychological Association,
Washington, D.C.
Hughes, D.M. (June 2011). What Every Psychologist Needs to Know About Trauma. Workshop
presentation at the New York State Psychological Association Annual Conference, New York, NY
Hughes, D.M. (March 2011). Vicarious Traumatization in Forensic Practice: Why Does It Matter?
Presentation at the American Psychology and Law Annual Conference, Miami, FL
Hughes, D.M. and Rocchio, L.M. (November 2010). Forensic Assessment of Psychological Trauma and
PTSD. Workshop presented at the 26th Annual Meeting of the International Society of Traumatic
Stress Studies, Montreal, Canada
Hughes, D.M. (August 2010). Ethical Dilemmas and Professional Considerations for Working with the Adult
Survivor of Sexual Abuse: Forensic Psychology. Presentation at the 118th Annual Convention of the
American Psychological Association, San Diego, CA
Hughes, D.M., Courtois, C., Walker, L.E., and Vasquez, M. (August 2009). Trauma treatment in
independent practice: Principles and resources. Workshop presented at the 117th Annual Convention of the
American Psychological Association, Toronto, Canada
Hughes, D.M. (August 2008). Difficulties and dilemmas when dissociation is present in forensic cases.
Presentation at the 116th Annual Convention of the American Psychological Association, Boston,
MA
Hughes, D.M. (November 2007). Forensic issues in the assessment of trauma. International Society for
Trauma and Dissociation 24th Annual Conference, Philadelphia, PA
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Dawn M. Hughes, Ph.D. ABPP
Page 5 of 7
Hughes, D.M. (November 2000). Multi-method approach to assessment in forensic evaluations. In
A. Pratt (Chair) Forensic assessment and testimony: Psychological trauma. A workshop presentation at the
16th Annual Meeting of the International Society for Traumatic Stress Studies, San Antonio, TX.
Hughes, D.M. (August 1999). Training in interpersonal violence: The next generation. Presentation at the
American Psychological Association Annual Convention, Boston, MA.
Gold, S.N., Hughes, D.M. & Swingle, J. (November 2000). Memory for childhood sexual abuse: A matter
of semantics. Panel presentation at the16th Annual Meeting of the International Society for Traumatic
Stress Studies, San Antonio, TX.
Hughes, D.M. & Gold, S.N. (November 1997). Memory for childbood sexual abuse and adult
symptomatology. Poster session presented at the 13th Annual Meeting of the International Society for
Traumatic Stress Studies, Montreal, Canada.
Hughes, D.M., Cloitre, M., Hand, R., Klein, C., Herwitz, J., Bleiberg, K. & Pessier, J. (November
1997). Role functioning impairment in CSA-related PTSD. In D.M. Hughes (Chair), Role functioning
impairment among women with childhood sexual abuse related PTSD. Symposium presentation at the 13th
Annual Meeting of the International Society for Traumatic Stress Studies, Montreal, Canada.
Cloitre, M., Hughes, D.M. & Hand, R. (November 1997). A two-phase treatment for CSA-related
PTSD: Rationale and preliminary results. In D.M. Hughes (Chair), Role functioning impairment among
women with childhood sexual abuse related PTSD. Symposium presentation at the 13th Annual Meeting of
the International Society for Traumatic Stress Studies, Montreal, Canada.
Klein, C., Hughes, D.M. & Cloitre, M. Ethnocultural considerations in the assessment of PTSD in survivors of
sexual assault. (November 1997). Poster presentation at the Annual Meeting of the Association for
the Advancement of Behavioral Therapy, Miami, FL.
Gold, S.N., Hughes, D.M. & Swingle, J. (July 1995). Degrees of memory of childhood sexual abuse among
female survivors in therapy. Paper presented at the 4th International Family Violence Research
Conference, Durham, NH.
Stear, C.A., Gold, S.N., & Hughes, D.M. (November 1994). Family of origin atmosphere of sexual abuse
survivors, distressed, and non-clinical families. Paper presented at the Illinois Psychological Association
Annual Convention, Chicago, IL.
Gold, S.N., Williamson, C. & Hughes, D.M. (March 1994). Male sexual abuse survivors: Integrating
empirical and clinical findings. Paper presented at the Mid-Winter Convention of APA Divisions 29, 42,
& 43.
Hughes, D.M., Bramson, J., Galper, L., Gelpi, H., Rubenstein, F & Dutton, M.A. (June 1992).
Training in the context of relationships: A model for the family violence clinician. Paper presented at the First
World Congress of the International Society for Traumatic Stress Studies, Amsterdam, The
Netherlands.
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Dawn M. Hughes, Ph.D. ABPP
Page 6 of 7
INVITED ADDRESSES
Hughes, D.M. (September 17, 2019). Mental Health Issues and the Workplace. In CLE program, The
Interplay of Mental Health Disabilities and Workplace Accommodations. New York City Bar
Association, New York, NY
Hughes, D.M. (April 3, 2019). Psychological Issues in the Workplace 2019. Practicing Law Institute, New
York, NY
Hughes D.M. (June 8, 2018). Trauma and the Courtroom. Alumni College Speaker. Hamilton College,
Clinton, NY
Hughes, D.M. (February 2, 2018). Domestic Violence 2018: Survivors as Defendants, Respondents, and Parole
or Clemency Applicants. Practicing Law Institute, New York, NY
Hughes, D.M., & Rocchio, L.M. (August 6, 2016). Forensic work with trauma populations. APA
Division 56 - Trauma Psychology suite presentation at the American Psychological Association
Annual Convention. Denver, CO
Hughes, D.M., Courtois, C., & Brown, L. (August 5, 2016). Establishing a clinical practice in trauma
psychology. APA Division 56 - Trauma Psychology suite presentation at the American Psychological
Association Annual Convention. Denver, CO
Hughes, D.M. (September 16, 2015 and October 7, 2015). Interpersonal Violence, Trauma, and the
Courtroom in Understanding the Ties that Bind: Judicial Responses to Domestic and Sexual Violence. Judicial
Training -New York Unified Court System - Domestic Violence Task Force. White Plains and
Rochester, New York.
Dutton, M.A. and Hughes, D.M. (April 13, 2015). Expert Witness Testimony in Cases Involving Domestic
Violence. Webinar conducted for the National Clearinghouse for the Defense of Battered Women.
Hughes, D.M. (September 2012). The Relationship Matters: Maximizing Success. Presentation to
attorneys at Outten and Golden, LLP. New York, NY
Hughes, D.M. (June and August 2012). Promoting Healthy Relationships: Living Without Violence and
Abuse. Professional training presented to the United States Army National Guard. Fort Hamilton,
NY
Hughes, D.M. (July 2011). Remaining Civil with the Uncivil. College of Labor and Employment
Lawyers. EEOC. New York, NY
Hughes, D.M. (March 2011). The Victim of Interpersonal Violence and the Courtroom. Judicial
Commission on Women in the Courts invited Continuing Legal Education seminar. Brooklyn, NY
Hughes, D.M. (November 2010). The Use of Psychological Experts in Cases of Domestic Violence. Invited
Continuing Legal Education seminar presented at the Kings County Criminal Bar Association,
Brooklyn, NY
Hughes, D.M. (July 2010). Ethics and Risk Management in the Practice of Psychotherapy. Invited
presentation at the Women's Mental Health Consortium Quarterly Meeting, New York, NY
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Dawn M. Hughes, Ph.D. ABPP
Page 7 of 7
Hughes, D.M. (January 21 and 22, 2010). Understanding Domestic Violence. Professional training in
Advocating for Children in Cases of Domestic Violence by the New York Appellate Divisions and
the New York State Office of Court Administration. New York City and White Plains.
Hughes, D.M. (2009). The victim of interpersonal violence and the courtroom: Strategies for understanding.
Manhattan Integrated Domestic Violence Courts Continuing Legal Education Seminar (February
2009); Appellate Division Fundamental Training Series (May 2009 and January 2010); Queens
County Family Court Continuing Legal Education Seminar (June 2009).
Hughes, D.M. (March 2008). Collision course of children's wishes, best interests, and domestic violence. Invited
presentation and the Twelfth Annual Conference on Domestic Violence. Fordham Law School,
New York, NY
Hughes, D.M. (March 2007). The inconvenient truths of domestic violence. Invited address at the Eleventh
Annual Conference on Domestic Violence. Fordham Law School, New York, NY
Hughes, D.M. (June 2006). Issues and dilemmas in interpersonal violence. Invited presentation at STEPS
to End Family Violence. New York, NY.
Hughes, D.M. (December 2001). Relevance of domestic violence in the courtroom: Expert testimony in a duress
case. Chairperson of a mock trial continuing education seminar at the 17th Annual Meeting of the
International Society of Traumatic Stress Studies, New Orleans, LA.
Hughes, D.M. (September 2001). Psychological assessment in the aftermath of the World Trade Center disaster.
Emergency meeting of the New York Chapter of the International Society of Traumatic Stress
Studies. New York, NY.
Hughes, D.M. (April 2001). Moving beyond domestic violence 101: Challenges and solutions.
Invited presentation in J. Pearl and S. Herman (Chairs), Violence and the Family: Current legal and mental
health perspectives. Association of the Bar of the City of New York, New York, NY.
Hughes, D.M. (June 2000). Psychological testing in forensic evaluations. Invited presentation in
symposium, M. Dowd (Chair) Psychological evidence in pleas negotiations and sentencing. Association of the
Bar of the City of New York, New York, NY.
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Bcc:
"
Subject: Re: Epstein FOIA
Date: Wed, 23 Jun 2021 20:55:45 +0000
Thanks!
On Jun 23, 2021, at 4:53 PM,
(USANYS)
wrote:
Just FYI, I spoke with
and we are going to request an extension.
is going to reach out to the
New York Times and see whether they will consent to two weeks (or some shorter period).
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=== Page 1 ===
From:
To:
Subject: motions
Date: Wed, 19 May 2021 15:49:22 +0000
Attachments: NPA_v3.docx
Team,
Checking in on the status for the motions. I'm attaching the NPA point draft, which can be folded in. Can folks let me know
the status of pending motion points, for planning purposes? I think our deadline to get this to the chiefs is EOD today, so
ideally we'd combine this by this afternoon and circulate quickly around the team for edits.
Thanks all-
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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From: "
USANYS)"
To:
(USANYS) [Contractor]"
Subject: FW:
Date: Tue, 14 Jul 2020 21:35:23 +0000
Attachments: Initial_Review_of_Records.pdf
For MCC shared drive - we are getting the FBI case file, so maybe put in a folder titled that? We'll need to
review all of these 302s and make discovery decisions.
Original Message
From:
(NY) (FBI)
Sent: Tuesday, July 14, 2020 2:51 PM
To:
(USANYS)
Subject:
Hey
When looking through my case file, this is where
documented the phone number and last call made by
Epstein. Let me know if you need anything else
Special Agent
FBI New York Field Office
Violent Crimes Task Force
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From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein trustees' counsel
Date: Mon, 30 Dec 2019 21:04:25 +0000
Will come by to discuss.
From:
Sent: Monday, December 30, 2019 2:00 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein trustees' counsel
Following up on the below from the week before last, the attorneys had hoped to set up a meeting for sometime later this
week or next. Can I relay an answer about whether
is willing to meet with them?
thanks,
From:
Sent: Thursday, December 19, 2019 12:32
To:
(USANYS)
i
(USANYS)
Cc:
in
Subject: RE: Epstein trustees' counsel
In our call today with counsel for the respective Trustees of the Epstein estate, they asked that we convey a request to
meet with
, and anyone else she would want to include in such a meeting, to discuss the Trustees' interest in
resolving the Government's potential civil forfeiture claims against the estate. They said they appreciated our (the line
assistants') willingness to hear their regular updates, but that they understand we're not in a position to negotiate, or
even to provide feedback on the proposed plan for the fund, and so they'd like the opportunity to elevate that discussion
and convey why they believe it would be in all parties' interests, including the victims, to engage in meaningful discussions
about a possible resolution. When you've spoken with
,
could you please let us know whether she's willing to meet
with them? And we can convey the response, unless you and/or she would prefer to do so directly. If she is willing to
meet with them, they were hoping to put a date and time on the calendar as soon as is convenient for her after the
holiday.
thanks,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To: Gloria Allred
Cc:
)"
)"
Subject: RE: Call this week
Date: Tue, 31 Mar 2020 18:07:58 +0000
Inline-Images: image001.png; image002.png
Please call my cell at
(If we end up needing a conference line I'll send that before 3:00 EST as well.)
thanks,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:54
To:
Cc:
is
Subject: RE: Call this week
That works. Please advise as to which number I should call.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIA ALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's
of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:51 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Yes, if that works for you - so in a little more than an hour. Or let us know if there's a different preferable time.
EFTA00024259

=== Page 2 ===
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:50
To:
Cc:
is
Subject: RE: Call this week
3P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIA ALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's
of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:46 AM
To: Gloria Allred
Cc:
)
is
Subject: RE: Call this week
Gloria,
That would be great, thanks. Would 3:00 work for you? Or please let us know if there's a more convenient time, we can
be flexible.
thanks again,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:31
To:
Cc:
is
Subject: RE: Call this week
May I call you with an update? What time today are you available for a call?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
EFTA00024260

=== Page 3 ===
www.amglaw.com
www.gloriaallred.com
GLORIA ALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's
of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:03 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Gloria,
We were wondering if you or your colleagues have been able to reach any of the clients we discussed last week? It would
be very helpful to know their views and reactions shortly - and we're of course happy to speak with them directly as well
if that would be helpful.
thanks,
From:
Sent: Thursday, March 26, 2020 15:45
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Gloria,
Thanks for speaking with us just now. The individuals we mentioned are
, and
Thanks,
Sent from my iPhone
On Mar 26, 2020, at 10:16 AM, Gloria Allred
wrote:
Thank you.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
EFTA00024261

=== Page 4 ===
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's
of Fame - 2019
From:
)
Sent: Thursday, March 26, 2020 12 AM
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
We can use the below conference line:
Dial-in:
Code: 933571
Thank you,
On Mar 25, 2020, at 8:55 PM, Gloria Allred
wrote:
I would be happy to send a Zoom number to you or feel free to send me a conference number to call.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's
of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 5:53 PM
To: Gloria Allred <
Cc:
is
Subject: Re: Call this week
Thanks very much. 3pm EST works for us. What number should we call?
Best,
On Mar 25, 2020, at 8:21 PM, Gloria Allred
wrote:
EFTA00024262

=== Page 5 ===
Yes. What time tomorrow is better for you, 3 P.M. e.s.t. or 4P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's
of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 1:55 PM
To: Gloria Allred
Cc:
is
Subject: Call this week
Gloria,
Would you have time for a call with the SDNY Epstein team tomorrow or Friday? We would like to provide you with a
bit of an update and discuss some of your clients in particular.
Hope you are staying safe and healthy.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
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EFTA00024263

=== Page 6 ===
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c1: EFTA00026428
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026428.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: White Collar Law360 <news@law360.com>
To:
Subject: Convicted Hedge Fund Exec Claims SDNY Hid Evidence
Date: Wed, 08 Jul 2020 07:43:50 +0000
Law360 White
Collar
WHITE COLLAR
Wednesday, July 8, 2020
Follow Law360
TOP NEWS
Law360 Practice Groups of the
Convicted Hedge Fund Exec Claims SDNY Hid Evidence
Year
Convicted Former Premium Point Investments CEO Anilesh Ahuja says that
a federal prosecutor in the Southern District of New York drafted a
cooperator's guilty plea and then told a judge he didn't - a fact Ahuja claims
casts doubt on the fairness of his trial.
Letter attached Read full article
Deutsche Bank Fined $150M For Epstein, Partner Bank Lapses
New York state's financial regulator said Tuesday it fined Deutsche Bank
$150 million for failing to appropriately manage its dealings with alleged bad
actors including millionaire sex offender Jeffrey Epstein, who died in federal
custody.
1 document attached Read full article
LAW FIRMS
Analysis
Barnes & Thornburg
Molotov Cases Prosecuted Like Terrorism In All But Name
Bird Marella
Brooklyn federal prosecutors have stopped just short of invoking the legally
Bruce S. Rogow PA
and politically fraught term "terrorism" against the defendants, including a
now-suspended Pryor Cashman associate, in alleged Molotov cocktail
Conrad & Scherer
attacks on NYPD vehicles.
Crowell & Moring
Read full article
Duane Morris
Faegre Drinker
Gov't Ties Ex-Panama President's Sons To Odebrecht Scheme
Ghidotti Berger
New York federal prosecutors have charged two sons of former Panamanian
Gibson Dunn
President Ricardo Martinelli over their alleged roles in a massive bribery and
Hughes Hubbard
money laundering scheme tied to Brazilian conglomerate Odebrecht SA.
Jackson Lewis
Complaint attached
Read full article
Jomarron Lopez
Alleged Accomplices To Ghosn Escape Can't Nix US Arrests
Kang Haggerty
Kasowitz Benson
A federal judge in Massachusetts on Tuesday shot down a bid to invalidate
the arrests of a Green Beret and his son who face extradition to Japan for
Kozyak Tropin
allegedly helping Carlos Ghosn escape the country while on bail over
Kramon & Graham
criminal financial misconduct charges.
Labaton Sucharow
2 documents attached Read full article
»
Lieff Cabraser
Marino Finley
NYC Grand Juries To Return To State Courthouses In August
Matthews Shiels
Grand juries will begin to reconvene in New York City state courts starting on
Aug. 10, and some criminal matters that have been heard remotely since the
Mayer Brown
beginning of the COVID-19 pandemic may soon be heard in person, the New
McDonald Hopkins
York State Unified Court System announced Tuesday.
Morgan Lewis
EFTA00026428

=== Page 2 ===
Read full article
Paul Weiss
COMPLIANCE
Perlman Bajandas
Pierce Bainbridge
FinCEN Warns Banks About COVID-19-Related Scams
Pryor Cashman
The Financial Crimes Enforcement Network warned financial institutions
Scott H. Palmer PC
Tuesday about two forms of consumer fraud that have proliferated during the
COVID-19 pandemic, issuing an advisory with tips for detecting impostor
Seyfarth Shaw
scams and money mule schemes.
Spertus Landes
1 document attached Read full article
Summit Law Group
Thornton Law Firm LLP
FTC Targets Belizean Executive In Real Estate Scam Suit
Tripp Scott
The Federal Trade Commission has urged a Maryland federal judge to hold a
Venable LLP
Belizean man liable for more than $138 million in an alleged Belize real
Walden Macht
estate scam, accusing him of trying to escape his part in running a fraudulent
operation that deceived American consumers.
Weissberg and Associates Ltd
Motion attached Read full article
Willkie Farr
Winston & Strawn
SECURITIES
COMPANIES
Ex-LA Broker Gets 6 Years For $215M Portfolio Pumping Fraud
Abbott
A former Beverly Hills stockbroker was sentenced on Monday to 72 months
American Bar Association
in prison after being convicted last year of participating in a stock price
BARBRI
manipulation scheme that pumped up the reported profits of hedge funds and
BNP Paribas SA
caused investors to lose $215 million.
Braskem SA
Read full article
Center for Justice
Ex-JPMorgan Trader Can't Ditch Forex-Rigging Conviction
Citigroup Inc.
A former JPMorgan trader's conviction for scheming with the competition to
Democratic National Committee
fix prices in the foreign currency market remains intact after a Manhattan
Deutsche Bank AG
federal judge said the evidence at trial was more than enough to support the
verdict.
Dropbox Inc.
Opinion attached Read full article
Facebook Inc.
Federation Internationale de
Football Association
SEC Settles With Rabbi For Bilking Jewish Investors Of $10M
Forever 21
The U.S. Securities and Exchange Commission on Monday announced a
judgment against Rabbi Zvi Feiner and his two companies for allegedly
Fox Corp.
conning at least 62 investors in Chicago's Orthodox Jewish community out of
Google Inc.
more than $10 million, including $1 million from an 86-year-old Holocaust
LexisNexis Group
survivor.
Linkedln Corp.
Decision attached Read full article
Microsoft Corp.
CYBERSECURITY
Mylan NV
Odebrecht SA
Alsup Slams Feds' 'Stunts' In Trial Of Alleged Russian Hacker
State Street Corp.
U.S. District Judge William Alsup criticized a prosecutor Tuesday for
StubHub Inc.
presenting "obviously prejudicial" jailhouse phone records instead of "real
TrueCar Inc.
evidence" against a Russian national on trial in California for allegedly
Twitter Inc.
hacking into Linkedln and Dropbox, saying, "You may end up losing this case
because of stunts like that."
Virage Capital Management LP
Read full article
ViroPharma Incorporated
Washington Post Co.
EBay Cyberstalking Case Expands As Feds Charge Ex-Cop
eBay Inc.
Federal prosecutors in Boston said Tuesday they have charged a seventh
former eBay employee, a retired cop who worked security for the company, in
GOVERNMENT AGENCIES
connection with an alleged cyberstalking campaign against a Massachusetts
Centers for Disease Control and
couple who ran an e-commerce industry blog.
Prevention
1 document attached
Read full article
Federal Bureau of Investigation
Federal Trade Commission
EFTA00026429

=== Page 3 ===
Microsoft Sues To Block 'COVID-19 Themed' Phishing Scheme
Financial Crimes Enforcement
A Virginia court has unsealed documents related to Microsoft's recent efforts
Network
to prevent alleged cybercriminals from stealing its users' personal information
Internal Revenue Service
through a "COVID-19 themed" phishing campaign, the company said.
National Economic Council
2 documents attached Read full article
New York Attorney General's Office
New York Police Department
LEGAL ETHICS
New York State Unified Court
System
5th Circ. Clears Texas Gov. From Ex-Judge's Retaliation Suit
Small Business Administration
The Fifth Circuit ruled Monday that a group of former Texas prosecutors -
including Gov. Greg Abbott - are shielded by prosecutorial immunity from a
Texas Health and Human Services
Commission
former state judge's retaliation suit that alleges they investigated, charged
and convicted her on bogus bribery charges, but held that one county
U.S. Attorney's Office
prosecutor is not protected.
U.S. Court of Appeals for the Fifth
Opinion attached Read full article
Circuit
U.S. Court of Appeals for the
TAX
Second Circuit
U.S. Department of Housing and
Solar Schemers Threatened With Jail For Defying Court
Urban Development
Owners of a solar company found to have perpetrated an abusive $50 million
U.S. Department of Justice
tax fraud were threatened with jail time by a Utah federal judge because
U.S. Department of the Treasury
they've repeatedly flouted contempt-of-court orders, destroyed evidence and
U.S. District Court for the Central
deceived the federal government.
District of California
Order attached Read full article
U.S. District Court for the District of
Maryland
COMPETITION
U.S. District Court for the District of
Massachusetts
FTC Fights Shkreli's Bid To Duck Monopolization Case
U.S. District Court for the District of
The Federal Trade Commission and a contingent of states have urged a New
Minnesota
York federal court not to toss their suit accusing former pharmaceutical
executive Martin Shkreli and a company he founded of monopolizing the
U.S. District Court for the Eastern
District of New York
market for a lifesaving drug used to treat parasitic infections.
3 documents attached Read full article
U.S. District Court for the Eastern
District of Virginia
SPORTS & BETTING
U.S. District Court for the Northern
District of California
Ex-Fox Execs Want Separate Trial In FIFA Bribery Case
U.S. District Court for the Northern
District of Illinois
A pair of former Fox Sports executives accused of bribing South American
soccer officials have urged a New York federal judge to try them separately
U.S. District Court for the Southern
from other defendants in the sprawling FIFA corruption case, arguing that
District of New York
prosecutors had hastily and incorrectly "lumped them in" with a host of
U.S. Securities and Exchange
unrelated defendants.
Commission
Motion attached Read full article
U.S. Sentencing Commission
U.S. Supreme Court
EXPERT ANALYSIS
United States District Court for the
District of Utah
Are Your Slack Communications Primed For E-Discovery?
World Health Organization
With the increasing use of channel-based platforms such as Slack,
Messenger and Teams in the work-from-home era, companies should
assume they may be compelled to produce channel-based data in litigation
and take proactive steps to protect sensitive information, say Jessica Brown
and Collin James Vierra at Gibson Dunn.
Read full article
LEGAL INDUSTRY
Chief Justice Hospitalized In June, Supreme Court Confirms
EFTA00026430

=== Page 4 ===
Chief Justice John Roberts was hospitalized last month after injuring himself
in a fall, the U.S. Supreme Court said in a statement Tuesday, confirming a
report in the Washington Post.
Read full article
Black Leaders Call Out Diversity 'Excuses' Law Firms Make
Despite decades of efforts to create a more equal and inclusive legal
profession, more change is urgently needed, a panel of top Black attorneys
said on Tuesday, pointing to several "excuses" law firms tend to make when
failing to hire and promote Black lawyers.
Read full article
Midyear Report: The Biggest Legal Ethics Moments So Far
With the COVID-19 pandemic dominating the headlines and just about
everything else this year, there has still been plenty happening in the world of
legal ethics, from the culmination of an unusual probe into a lawyer fee award
to a major court setback for New York's new prosecutor watchdog group.
Read full article
Oyez! High Court's 1st Female Marshal, Reporter Are Retiring
U.S. Supreme Court Marshal Pamela Talkin and Reporter of Decisions
Christine Luchok Fallon, the first women to serve in those roles, are retiring
this year after nearly 50 years of combined service at the court.
Read full article
Hughes Hubbard Lays Off Associates Amid Pandemic
Despite claiming a small business loan as part of the federal government's
COVID-19 relief efforts, New York law firm Hughes Hubbard & Reed LLP
confirmed Tuesday that it had laid off an undisclosed number of associates
and staff to weather the pandemic.
Read full article
Coronavirus Regulations: A State-By-State Week In Review
The uptick in the spread of COVID-19 reenergized an emphasis on face
coverings this past week, leading to a public awareness campaign in
California and a new law in Texas. And in Pennsylvania, Gov. Tom Wolf
shared World Health Organization research in an effort to get commonwealth
citizens to cover up.
Read full article
Seyfarth Opens Seattle Office With Labor, Real Estate Focus
Seyfarth Shaw LLP on Tuesday announced the launch of a new Seattle office
with a focus on real estate and labor law, with the firm saying it decided to
move ahead with the planned expansion into the Pacific Northwest despite
the COVID-19 pandemic.
Read full article
Firm Must Produce Email Allegedly Used To Blackmail Judge
A Florida judge ordered Tripp Scott PA on Tuesday to produce an email sent
to one of its former attorneys allegedly containing nude photographs of a
Palm Beach County judge that the judge says were later used by a prominent
Fort Lauderdale attorney to blackmail her.
Read full article
Ex-National Economic Council Deputy Joins Mayer Brown
Former White House economic adviser Andrew Olmem has returned to
Mayer Brown LLP, joining the firm's public policy, regulatory and political law
practice after taking part in the development and coordination of U.S.
economic policies in various sectors.
Read full article
EFTA00026431

=== Page 5 ===
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c1: EFTA00024879
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024879.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Thu, 07 Jan 2021 16:10:14 +0000
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
EFTA00024879

=== Page 2 ===
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00024880

=== Page 3 ===
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
)
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
EFTA00024881

=== Page 4 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
EFTA00024882

=== Page 5 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
EFTA00024883

=== Page 6 ===
Hope you are also staying safe and healthy.
Thanks,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
EFTA00024884

=== Page 7 ===
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
EFTA00024885

=== Page 8 ===
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00024886


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c3: VOL00008
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c0:
=== Page 1 ===
From:
)"
To:
)"
N. (NY) (FBI)"
,
)"
Subject: RE:
Checks
Date: Tue, 02 Jul 2019 19:41:20 +0000
Importance: Normal
Attachments: jeffreyepsteinorg.AccountInfo.txt; jeeitunes.AccountInfo.txt; jeevacation.AccountInfo.txt
Following up on this, not sure if you guys have had time to check this yet, but attached is the subscriber info I have-but
worth checking on your end to see if you have returns from Yahoo as well. Can we discuss later this afternoon whether a
GPS or pen makes sense? Thanks.
From:
Sent: Monday, July 1, 2019 9:16 PM
To:
is
is
N. (NY) (FBI)
is
Subject: RE:
Checks
Hi
Thanks, we'll take a look-if you could send over a summary of her flights with him over the past 6 months, that would be
helpful. Have you guys looked at the phone numbers associated with the email accounts we got subscriber info for? Let us
know if you think any of those numbers are live.
Thanks,
From:
Sent: Monday, July 1, 2019 8:53 PM
To:
is
)
>;
N. (NY) (FBI)
is
Subject:
Checks
See attached phone records for
As per our conversation her cell phone number may be
relevant to her recent travels with Epstein.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00026667


c1: EFTA00024553
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c3: VOL00008
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c0:
=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 19:13:49 +0000
Inline-Images: image001.png
Thanks!
From
Sent: Thursday, July 2, 2020 1:24 PM
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Amazing work. Congrats!
From
Sent: Thursday, July 02, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF SOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00024553

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00024554

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00024555


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
)"
)"
Subject: RE: Courtroom connect
Date: Thu, 18 Nov 2021 01:34:14 +0000
Attachments: 2021-11-17_Courtroom_Connect_Letter.docx
Following up on this actually, I just spoke with
who is requesting courtroom connect for
(and he did for NCAA
also). He said that getting courtroom connect is not going to happen without a signed order from the judge. He
recommended getting it submitted sooner rather than later to leave time for logistics to be worked out. Would it be
possible to submit a proposed order and request to Judge Nathan soon, tonight or tomorrow? I've drafted one (attached)
using the language used in his, which I forwarded below. Let me know what you think or if you need anything from me,
thanks.
From:
(USANYS) [Contractor]
Sent: Wednesday, November 17, 2021 6:23 PM
To:
is
(USANYS)
>;
is
)
Subject: FW: Courtroom connect
FYI, I am going to check in with
tomorrow about the procedure for courtroom connect internet (I flagged it for
her yesterday but forgot to check in this afternoon), but it looks like we will need to send a letter and proposed order to
the judge to approve it before coordinating with the tech folks who install and make it happen. If this is in fact what we
need to do, which l'll again check with
about tomorrow, I think we should try and send such a letter/proposed
order tomorrow (to ideally get it approved as soon as possible and a tech check scheduled for before Thanksgiving).
From: Mark, (USANYS)
Sent: Wednesday, November 17, 2021 5:59 PM
To:
(USANYS) [Contractor]
Subject: RE: Courtroom connect
From:
(USANYS) [Contractor]
Sent: Wednesday, November 17, 2021 5:58 PM
To: Mark,
(USANYS)
Subject: Courtroom connect
Hey
When you get a chance could you please send me the application you sent to Judge Kaplan to get courtroom connect
approved?
Thanks,
Paralegal Specialist
U.S. Attorney's Office I
SDNY
EFTA00024921

=== Page 2 ===
New York, NY 10007
Office:
Cell:
EFTA00024922


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c3: VOL00008
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=== Page 1 ===
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 26, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No. 02879-509)
MDC Brooklyn
Metropolitan Detention Center
P.O. Box 329002
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the disc containing witness materials and discovery pertinent to Ghislaine
Maxwell (02879-509) is
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00024225


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=== Page 1 ===
OFFICIAL RECORD
FD-1036 (Rev. 10-16-2009)
Document
signed
UNCLASSIFIED//FOUO
FEDERAL BUREAU OF INVESTIGATION
Import Form
Form Type: FD-1023 - Confidential Human Source
Date: 10/19/2020
Reporting Document
Title: (U)
Approved By:
Drafted By:
Case ID #:
(U//FOUO) 2020 Election Influence Threat
INTELPRODS
Assessment; FBI Los Angeles Area of
Responsibility; Type 3 Assessment;
Intelligence Products
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Synopsis: (U) Foreign influence on U.S. officials by Israel, Russia, and
UAE
Enclosure (s) : Enclosed are the following items:
1. (U) DELTA Imported Attachment
2.
(U) DELTA Imported Attachment
3.
(U) DELTA Imported Attachment
UNCLASSIFIED//FOUO
EFTA00025004


c1: EFTA00023710
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c3: VOL00008
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c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: RE: Epstein search warrant documents
Date: Wed, 08 Jul 2020 15:18:58 +0000
Great, thanks.
From:
Sent: Wednesday, July 8, 2020 11:13 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
We're expecting it today - just spoke to
she's going to drop it off and then I'll have it sent via FedEx to
From:
(USANYS)
Sent: Wednesday, July 08, 2020 10:57
To:
)
Subject: RE: Epstein search warrant documents
Did we get this?
From:
Sent: Tuesday, July 7, 2020 5:39 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Thanks - if you just have it brought over to my office tomorrow, we'll take care of getting it to
no problem. No need
for you guys to ship.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, July 07, 2020 17:36
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I'll see what we can arrange.
EFTA00023710

=== Page 2 ===
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jul 7, 2020 5:34 PM,
(USANYS) [Contractor]"
wrote:
Hello
Our office is not open and I am still working from home. Is it possible to have this data sent to my home?
Thank you.
From:
(NY) (FBI)
Sent: Tuesday, July 7, 2020 5:14 PM
To:
>;
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
y.
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Everything with the exception of a couple of items are ready. I will get you an actual number before I send it over.
We can send it over tomorrow. There will be ReadMe files included so it will be easy to see where the items came from. I
am a little worried about how the e-mail will present. While looking through on a spot check, the attachments are not
connected to the e-mails in the forensic tool. I believe it is a function of the e-mail client they were using to begin with. I
know that the attachments are a concern of yours. We may have to massage things a bit to get it right. Now that we are
working every day, and everything has been processed, it shouldn't be too big a deal. So far the export is about 350 GB. It
copies slowly because it is a ton of pretty small files. You are getting the whole ball of wax, here, Macs, Windows boxes,
loose media, etc. There will be a few iPhone and iPad reports, but unsure if I can get you those tomorrow as they very
often take a LONG time to copy. Again, lots of small files. If not tomorrow, the next day.
Are you around tomorrow? Reach out to me when you get the production so we can correct any problems we might
encounter. Thanks.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, July 07, 2020 3:42 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
V.
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
EFTA00023711

=== Page 3 ===
I understand that some number of the devices are ready to come to us as early as today or tomorrow. Could you please
let us know the following information, so we can figure out who the hard drive should go to in the first instance:
1. How many total devices are coming to us in this initial production?
1. What are those devices - i.e., type of device and which ones, from the spreadsheets you've sent?
2. What's the total volume of data coming in this round of production?
Once we know that, I can let the agents know where the drive needs to go in the first instance.
thanks,
From:
)
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
>;
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
in
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
EFTA00023712

=== Page 4 ===
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll be
able to see how many items to export, so we'll have a better sense of when we'll get those?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
>;
(NY) (FBI)
V.
is
>;
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
y.
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how many
items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI materials?
I
think that is quite a bit more. Just looking for an estimated completion date for everything.
EFTA00023713

=== Page 5 ===
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and USVI?
thanks,
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
i
)
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per my
discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as 1 item in
particular has over 500,000 emails. We will be able to provide discovery once Defense Council has provided
drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let you know when
everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could you
please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as early as this
week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything that
was collected (including reproducing the materials that you previously gave us, but which are not searchable), or have you
and
figured out a way to categorize the prior productions so they're useful for us? We would strongly prefer to just
get everything at once in a usable format, but please let us know if you expect to produce materials differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
is
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
EFTA00023714

=== Page 6 ===
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
)
is
is
(NY) (FBI)
in
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what
the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go from
there.
EFTA00023715

=== Page 7 ===
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
is
)
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in searchable
format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to specific devices -
so if we're able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to
get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
EFTA00023716

=== Page 8 ===
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
in
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
EFTA00023717

=== Page 9 ===
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
V.
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
)
is
(USANYS) [Contractor]
Cc:
is
)
is
EFTA00023718

=== Page 10 ===
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
)
Subject: RE: Epstein search warrant documents
EFTA00023719

=== Page 11 ===
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
EFTA00023720

=== Page 12 ===
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
i
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
)
>;
(NY) (FBI)
>;
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
EFTA00023721

=== Page 13 ===
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
EFTA00023722

=== Page 14 ===
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
i
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
EFTA00023723

=== Page 15 ===
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
>;
(USANYS)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
EFTA00023724

=== Page 16 ===
Senior Forensic Examiner
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
>;
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
>;
>;
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
in
)
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
V.
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
)
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
EFTA00023725

=== Page 17 ===
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
EFTA00023726

=== Page 18 ===
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00023727


c1: EFTA00026660
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026660.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
LAW ENFORCEMENT SENSITIVE
U.S. Department of Justice
United States Marshals Service
Personal History of Defendant
Taken into Federal custody by the following:
Street Arrest (not from a correctional/detention facility)
Writ Used (Must provide copy of writ) ARREST WASHANT
Custodial Arrest (from a correctional/detention facility)
Prior Federal Arrest or Safekeeper Register
Safekeeper Location:
BIOGR APHIC Al INFORMATION
Last Name: EPSTEIN
F
Transgender
First Pregnant: Name: Jeffrey Y
Middle Name: Edward
Sex:
Race: W
Hair: GRY
Eyes: BLUE
Height: 6'
Weight:
185
DOB
City of Birth:
State/Country of Birth:
Citizenship: Yes
FBI #:
State ID#:
Alien #:
SSN
Resident Address/City/State/ZIP: 9E7/SI New York NY 10021
Home Phone:
Cell Phon
Marital Status: s
COURT CASE
Agency:
NY FBI
Agency ORI: NYFBINYCO
Agent Last Name:
First Name:
Agent Phone #:
Arrest Date: 7/6/19
Court Location/Facility Docket #: of Arrest: Teterboro CR AUSA(s) AIRPORT, Assigned: Bergin COUNTY, New Jersey
OFFENSE
NCIC Code
Charge Description SEX TRAFFICKING Carpp
Title/Code
18 USC 371
Known Detainers/Warrants:
Y Agency:
(Must provide M copy of any detainers)
CAUTIONS AND MEDIC AL
Long Term Medical Conditions (e.g., heart problems. diabetes. asthma. tuberculosis. IIIV. AIDS. hepatitis. etc.):
N
Y
Psychiatric/Emotionally Disturbed (e.g., mental health concerns. suicidal. etc.):
N
Y
Injuries/Medical Ailments/Post-Op Recovery:
N
Y
Do the above conditions require:
Medical attention?
N
Y
Medication?
N
Y
Medical clearance by a licensed physician:
N
Y
Is Defendant under the influence of drugs or alcohol:
N
Y
Languages English:
N
Y
Limited
Other Language:
N
Y List:
Security Cautions:
Current or former military
Current or former I.E/corrections
Current or former intelligence
Current or former public official
Assault on LE/corrections
SAM subject or candidate
Eligible for diplomatic immunity
Leadership role
Separation needs Describe below)
Threat to witness (Describe below)
CT (Describe below)
Other Describe below)
U/LES
Form USM-312
Page I of 3
Rev 11/17
EFTA00026660

=== Page 2 ===
LAW ENFORCEMENT SENSITIVE
Remarks:
ALIASES
ALIAS Last Name
ALIAS First, MI
Remark
Date of Birth
SSN
State Driver's License
ASSOCIATES / CO-DEFENDANTS/ RELATIVES / THILDREN / SIGNIFIC ANI OTHER
Resident Address. City. State.
Relationship
Last Name
First, MI
Register #
ZIP Code
Phone
MARKS
Scar/Mark/Tattoo N/A (Specify)
Location
Description
VEHICLES
Vehicle
State and
Registration
Year
Make
Model
Color(s)
Vehicle Style
Plate #
Date
VIN
LICENSES
License Number
License State
MISCELL ANEOUS NUMBERS
Miscellaneous Number
Type (Select from dropdown menu or type below)
Remarks (e.g., Issuing States Country, etc.)
OCCUPATIONS
Occupation: SecF Employed
Company/Employer Name: Southern TRUST COMP.
Employment Address: VIRGEN IsLANds
Phone
Start Date:
End Date:
Point of Contact:
FINANCIAL
Bank Name
Account Type
Account #
Branch Address
Phone #
MILITARY
N/A
Entry
Discharge
Branch
Rank
Date
Date
Discharge Type
Military Occupation
Remarks
REMARKS
Additional Information/Remarks/Continuation:
PROFILE
Defendant Risks: *Requires remarks below
Sex Offender:
Escapee
Planned Murder
Arrest
Conviction
Organized Crime*
Protected Witness
Registered
Registration Violation
International Terrorist
Domestic Terrorist
Gang Member*
Significant Criminal History
Multiple Defendants
Death Penalty Case
U.LES
Form USM-312
Page 2 of 3
Rev 11/17
EFTA00026661

=== Page 3 ===
LAW ENFORCEMENT SENSITIVE
Criminal History (Select from dropdown menu or type offense below)
Arrest (#)
Conviction (#)
Remarks N/A (e.g., name of gang or criminal organization, etc.):
Money Launderer
Kingpin
Violent Offender
INTERNET SOI
Internet Source
Remarks (e.g., email address, website address, username, etc.)
NOTICE TO ARRESTING AGENTS: As a courtesy. the USMS may temporarily hold an arrestee received by non-USMS
personnel in the cellblock until the arresting agent(s) make arrangements for the prisoner's initial appearance before a United States
Magistrate. A prisoner remains the responsibility of the arresting agency until remanded to the custody of the USMS by the courts.
When a courtesy hold is allowed by the USMS to be housed in a USMS cellblock. a minimum of one agent from the arresting
agency must be available to respond to the cellblock in order to address any issues with their prisoner (e.g., medical. disciplinary ). If
the arresting agency refuses to comply with USMS procedures. the courtesy hold may be refused. Meals are not provided by the
USMS. and remain the responsibility of the arresting agent(s).
ARRESTEE PROCESSING CHECKLIST
ARRESTEE PROCESSING CHECKLIST
For Arresting Officer Only
For USMS Personnel Only
USM-312 (Personal History of Defendant)
Confirm all arresting agent documentation is completed and
Medical clearance (from licensed physician). if necessary
inserted into prisoner's file
Copy of Arrest Warrant. if issued
USM-312 (Personal History of Defendant) reviewed
signed and dated by intake DI SW DEO
Copy of Complaint. Information. or Indictment. if completed
USM-552 (Prisoner Medical Records Release Form)
Copy of Detainer(s). if issued
completed signed and dated by intake DI SM DEO
Copy of Writ. if applicable
USM-18 (Federal Prisoner Property Receipt) " completed
Correctional facility discharge papers. if applicable
signed and dated by intake DE SM DEO
Correctional facility prisoner receipt. if applicable
USM-40/41 (Prisoner Remand) - inserted into prisoner's file
Correctional facility medical summary. if applicable
USM-130 (Prisoner Custody Alert Notice). if applicable
Prepared By Name:
inserted into prisoner's file
Agency: NYPD- NYFBI- IFQ
FD-249 (Fingerprint Card) printed and inserted into
Date: 7/6/19
prisoner's file
Cell Phone
Prisoner Photograph (from Booking Package) printed and
inserted into prisoner's file
Reviewed By:
Badge #:
Date:
FMLY. member (Brother)
MARK EPSTEIN
U/LES
Form USM-312
Page 3 of 3
Rev. 11/17
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=== Page 1 ===
From:
To: "Weinstein, Marc A."
Cc: Andrew Tomback
Subject: RE: SDNY investigation
Date: Fri, 02 Oct 2020 14:39:09 +0000
Marc,
Received, thanks very much.
Hope you're doing well-
From: Weinstein, Marc A.
Sent: Wednesday, September 30, 2020 1:52 PM
To:
Cc: Andrew Tomback ;
Subject: RE: SDNY investigation
The transcripts are attached. We trust that the US Attorney's Office will keep these confidential other than to the extent
disclosure is required in any pending case.
Regards,
Marc
MarcA. .Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate,
distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail
transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain
viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If
verification is required please request a hard-copy version.
From: Weinstein, Marc A.
Sent: Wednesday, September 30, 2020 12:03 PM
To:
Cc: Andrew Tomback
i
Subject: RE: SDNY investigation
I connected with Jack Scarola last week. I just sent him an email to confirm that we can provide you with the
transcript. Once we receive confirmation from him, we will send you the transcript.
Best regards,
Marc
From:
Sent: Tuesday, September 29, 2020 3:40 PM
To: Weinstein, Marc A.
Cc: Andrew Tomback
i
Subject: RE: SDNY investigation
EFTA00023699

=== Page 2 ===
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Hope you're doing well. I wanted to check in on the status of this issue - have you been able to connect with Mr. Scarola?
Thanks,
From: Weinstein, Marc A.
Sent: Tuesday, September 22, 2020 4:54 PM
To:
Cc: Andrew Tomback
Subject: RE: SDNY investigation
Thanks
I will give him a call.
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Tuesday, September 22, 2020 4:42 PM
To: Weinstein, Marc A.
Cc: Andrew Tomback
is
is
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Thanks for following up on this. If it's okay with you, I think it makes sense to connect you with the plaintiff's attorney,
Jack Scarola, so that he can convey this to you directly. I have spoken with him and explained the context here, and he has
told me that he would be happy to speak with you. He is also seeking a copy of the transcript, as he has informed me that
he no longer has his case files for matters this old. Here is his contact information:
Jack Scarola
Thank you,
From: Weinstein, Marc A.
Sent: Tuesday, September 22, 2020 11:24 AM
To:
Cc: Andrew Tomback
is
>;
Subject: RE: SDNY investigation
We haven't found a governing protective order, but to be safe, would you be able to get a letter or email from
attorney stating that they are not aware of a protective order/agreement governing the disclosure of the transcript, and
to the extent one existed, they are waiving any provisions in order to permit the Estate to provide the transcript to the US
Attorney's Office, and that they will not claim, in any forum, that the Co-Executors, the Estate, or any representatives of
either, breached any such order/agreement in that case by providing the transcript to the US Attorney's Office.
Let us know if that works on your end.
EFTA00023700

=== Page 3 ===
Best regards,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Monday, September 14, 2020 3:01 PM
To: Weinstein, Marc A.
Cc: Andrew Tomback
i
is
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Thanks - we have conferred with plaintiff's counsel, who has informed us that he is unaware of any protective order
relating to the
lawsuit.
Best,
Assistant United States Attorney
Southern District of New York
From: Weinstein, Marc A.
Sent: Monday, September 14, 2020 12:07 PM
To:
Cc: Andrew Tomback
is
>;
Subject: Re: SDNY investigation
we are still looking to see what confidentiality restrictions might apply. If her lawyer has any such confidentiality or
protective order that governed the case, it might be helpful if you could obtain and share that.
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
On Sep 14, 2020, at 11:56 AM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Thanks very much. Are you able to provide it to us? If there are any issues with providing it to us, or if a call would be
useful to discuss, please let us know.
Thanks,
EFTA00023701

=== Page 4 ===
From: Weinstein, Marc A.
Sent: Monday, September 14, 2020 11:51 AM
To:
Cc: Andrew Tomback
is
Subject: RE: SDNY investigation
we have the transcript of
deposition.
Regards,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Friday, September 11, 2020 1:40 PM
To: Weinstein, Marc A.
Cc: Andrew Tomback
is
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
Thanks, Marc. We'll look forward to hearing from you, and thanks for your assistance with this.
From: Weinstein, Marc A.
Sent: Friday, September 11, 2020 1:35 PM
To:
Cc: Andrew Tomback
is
is
Subject: RE: SDNY investigation
Thanks
It wasn't clear to me from the call that it was the plaintiff's deposition that you were after, as opposed to
another witness in the case. Now that it's clear, we will see if we can track it down.
Regards,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Friday, September 11, 2020 1:30 PM
To: Weinstein, Marc A.
Cc: Andrew Tomback
is
is
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
EFTA00023702

=== Page 5 ===
Marc,
Thanks for speaking earlier. The plaintiff's name is
who is represented by Jack Scarola. The deposition
took place in 2009, and Jeffrey Epstein was represented by Mark Luttier and Bob Critton of Critton, Luttier, and Coleman
LLP in West Palm Beach.
Thanks very much,
Assistant United States Attorney
Southern District of New York
From: Weinstein, Marc A.
Sent: Friday, September 11, 2020 11:11 AM
To:
Cc: Andrew Tomback
is
>;
Subject: RE: SDNY investigation
I just realized that you didn't share with us the deponent's name for the transcript you are looking for. Let us know
so that we can make the appropriate inquiries.
Best regards,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Thursday, September 10, 2020 11:14 AM
To: Weinstein, Marc A.
Cc: Andrew Tomback
is
>;
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
That works well, thanks very much. Talk to you then.
From: Weinstein, Marc A.
Sent: Thursday, September 10, 2020 11:13 AM
To:
Cc: Andrew Tomback
is
>;
Subject: Re: SDNY investigation
if 11:00 works, I can send a dial-in.
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or
EFTA00023703

=== Page 6 ===
error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
On Sep 10, 2020, at 10:46 AM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Andy and Marc,
Are you available for a brief call tomorrow? I'm available before 1 p.m., if there's a time that works for you in that window.
Thanks very much,
Assistant United States Attorney
Southern District of New York
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From:
(USANYS)"
To:
)"
Cc:
(USANYS) [Contractor]"
Subject: RE: Shared Access
Date: Tue, 04 May 2021 14:16:55 +0000
Attachments:
Transcription.doc
Good morning
and
I have finished up with the
transcription and have attached it here. I referred to one of the interviewers as
UM1 because his full name was never mentioned, but am happy to go back and change that if you know his full name. Let
me know if there's anything you'd like me to edit or change!
Thanks!
From:
(USANYS)
Sent: Wednesday, April 28, 2021 1:25 PM
To:
Subject: RE: Shared Access
Great, thank you so much! I'm helping
out with a few things for Maxwell and have been preoccupied with that. I
believe I can get this transcript to you by the end of next week, but if you need it sooner let me know and I can figure
some things out/see if another intern is available to help.
Thanks!
From:
Sent: Wednesday, April 28, 2021 12:26 PM
To:
(USANYS)
Subject: RE: Shared Access
Hi
Thanks for reaching out! Happy to be flexible on this. What timing is realistic on your end, given other commitments?
Thanks.
From:
(USANYS)
Sent: Wednesday, April 28, 2021 11:35 AM
To:
Subject: RE: Shared Access
Hi
I hope all is well! My progress on this transcription has been a little delayed due to some time-sensitive projects that have
come up. I'm chipping away at it, but I was wondering if you could give me an idea of when you'd like this transcript by. I
just want to make sure I'm not delaying you in any way!
EFTA00024926

=== Page 2 ===
Thanks so much,
From:
Sent: Monday, April 19, 2021 9:41 AM
To:
(USANYS)
is
(USANYS) [Contractor]
Subject: RE: Shared Access
Thanks for checking - that timing sounds good, thanks.
From:
(USANYS)
Sent: Monday, April 19, 2021 9:40 AM
To:
is
(USANYS) [Contractor]
Subject: RE: Shared Access
Good morning,
Thank you for getting me access! I'm happy to be helping out. I currently have a few things on my plate so I was
wondering if it would be okay if I started this transcription either at the end of this week or the beginning of next week?
Just wanted to make sure in case this was super time-sensitive. Let me know!
Thanks so much!!
From:
Sent: Thursday, April 15, 2021 6:00 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
Subject: RE: Shared Access
Thanks so much for helping out with this,
!
I'll email now to get you shared access.
From:
(USANYS) [Contractor]
Sent: Monday, April 12, 2021 4:09 PM
To:
Cc:
(USANYS)
Subject: Shared Access
Hi
is going to help out with transcribing the
recording. When you have a chance would you please ask
IT to give her access to the shared. Thanks!
Paralegal Specialist
United States Attorney's Office I
SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office
Cell:
EFTA00024927


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
October 26, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No. 02879-509)
MDC Brooklyn
Metropolitan Detention Center
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed are witness materials and discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
Enclosure
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OFFICIAL RECORD
FD-1036 (Rev. 10-16-2009)
Document have signed
UNCLASSIFIED
2
FEDERAL BUREAU OF INVESTIGATION
Import Form
Form Type: OTHER - Other
Date: 09/04/2020
Title: (U) Documentation of Services by
04/01/2020-
06/30/2020
Approved By:
Drafted By:
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Synopsis: (U) Documentation of Services by
04/01/2020-06/30/2020
so
UNCLASSIFIED
EFTA00025003


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From:
"
(USANYS)"
To:
)"
Subject: Emailing: WOLSEN_20201211131426410_DRAFT.pdf
Date: Fri, 11 Dec 2020 18:14:50 +0000
Attachments: WOLSEN_20201211131426410_DRAFT.pdf
EFTA00024306


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From:
To:
Cc:
Subject: GM
Date: Fri, 13 Mar 2020 01:41:52 +0000
Attachments: 2020-03-12,_GM,_prosecution_memo.docx
Attached is a draft prosecution memo regarding Maxwell. The team is happy to discuss whenever you've had a chance to
review.
Thanks,
EFTA00025546


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=== Page 1 ===
DAWN M. HUGHES, PH.D., ABPP
CLINICAL AND FORENSIC PSYCHOLOGIST
NEW YORK STATE LICENSED PSYCHOLOGIST
BOARD CERTIFIED IN FORENSIC PSYCHOLOGY
ENGAGEMENT AGREEMENT FOR PSYCHOLOGICAL EXPERT SERVICES
In the matter of
Service. A forensic psychological service is a psychological evaluation, consultation, or
expert witness service that is undertaken for legal purposes. Dr. Hughes provides forensic
psychological services to a law firm who is the client. The litigant is not Dr. Hughes' client.
A forensic psychological evaluation typically involves face-to-face interview with the person
to be evaluated, psychological testing, collaborative interviews with individuals deemed
necessary by Dr. Hughes to conduct a thorough and complete evaluation, and review of
documents and other evidence. Evaluation sessions, including testing, are arranged by
appointment. Dr. Hughes may form and provide findings, impressions, opinions,
conclusions, and recommendations regarding the legal issue(s) at hand. These services are
not intended for the purpose of therapy. Dr. Hughes' findings, impressions, opinions,
conclusions, and recommendations are based on the evaluation procedure and are
independent.
Confidentiality. The usual laws governing confidentiality between psychotherapist and
patient do not apply to the relationship or information obtained during the course of the
forensic evaluation. Information obtained in the course of the forensic evaluation will be
shared with the individual's attorney. This policy also recognizes Dr. Hughes' use of
professional test scoring services, and other professional consultation as deemed advisable
by Dr. Hughes. Be aware that in certain instances the law requires Dr. Hughes to disclose
privileged information, for example, in situations of suspected child abuse, of potential harm
to oneself or another, and in instances where the court orders the disclosure of privileged
information and records.
Results. Written reports may be requested by an attorney or the court. Any results, reports,
and copies of records shall only be prepared, written, and provided after the full evaluation is
completed. Partial reports will not be provided.
Fees. Dr. Hughes' usual and customary fee is $500 per hour or portion thereof for all
forensic services including but not limited to evaluation appointments, psychological testing
and test scoring, collateral interviews, attorney consultation, review of documents/records,
preparation of written reports/affidavits/declarations, deposition and testimony preparation,
and travel time (door to door).
Court and deposition testimony are billed in full or half-day increments at the hourly rate of
$500 - that is, $2000 per half-day (9:00 to 1:00) and $4000 per full-day (9:00 to 5:00).
Payment is required at least 72 hours in advance. In the event that a deposition/testimony is
EFTA00024767

=== Page 2 ===
cancelled, or the case settled less than 72 hours in advance, Dr. Hughes will be paid for time
allotted for said testimony as Dr. Hughes' schedule is made far in advance. In addition, if
opposing counsel calls for my deposition and refuses to pay according to my stated fee
structure, the retaining attorney is responsible. Fees for photocopying and other staff-related
activities are billed at $50 per hour. Disbursements, which will also be billed, include actual
costs associated with psychological testing, for example, test scoring, as well as travel
expenses and other reasonable expenses incurred.
The financially responsible party shall be the law firm by whom Dr. Hughes is retained. The
responsible party shall pay the fees and disbursements for all time and services provided by
Dr. Hughes. Dr. Hughes will not accept payment from the litigant directly. If the litigant
fails to attend the scheduled evaluation, fails to provide more than 72 hours notice of
cancellation, or fails to cooperate with the evaluation, the financially responsible party shall
be responsible for full payment for full time allotted for the evaluation.
Retainer or Court Order. A retainer of $7000 is due at least 48 hours before the first
consultation or evaluation session with Dr. Hughes and before Dr. Hughes may be identified
to opposing counsel or to the Court as having been retained by the law firm. The first $3500
is non-refundable. The remaining retainer shall be applied to the final billing statement, and
Dr. Hughes shall return any unused remaining portion of the retainer to the payer. In lieu of
a retainer, a court order or other document guaranteeing payment will be required.
The actual final cost of forensic services varies widely depending on the amount of time
spent by Dr. Hughes, the amount of contact with the parties and the attorneys, the amount
of information to be read, and the degree of complexity of the matter. Dr. Hughes' fees may
substantially exceed the initial retainer and additional retainers shall be required. Additional
retainers and fees shall be paid promptly when requested by Dr. Hughes.
Agreement. All agreements and contracts with Dr. Hughes are in writing. Any
modification of the terms of this agreement must be in writing and signed by Dr. Hughes.
Dr. Hughes, in agreeing to provide this forensic psychological service, is specifically relying
on the responsible party's agreement to abide by all the terms of this agreement.
An authorized representative of the law firm retaining Dr. Hughes shall signify agreement to
this Engagement Agreement by signing below.
DAWN M. HUGHES, PH.D., ABPP
DATE
CLINICAL AND FORENSIC PSYCHOLOGIST
ATTORNEY AUTHORIZED TO ENTER INTO AGREEMENT
DATE
October 8, 2020
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=== Page 1 ===
From:
To:
Subject: Tentative: Call with PAE re Epstein
Date: Thu, 25 Mar 2021 19:31:21 +0000
Importance: Normal
Attachments: unnamed
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From:
To:
Cc:
Subject: RE: RE: travel approval request
Date: Fri, 11 Oct 2019 14:56:51 +0000
Sitil approved
From:
Sent: Friday, October 11, 2019 10:48 AM
To:
Cc:
Subject: RE: RE: travel approval request
I'm sorry, this coming Tuesday, not Monday.
From:
Sent: Friday, October 11, 2019 10:47
To:
Cc:
Subject: RE: travel approval request
We just found out yesterday that we're being sent to Florida for an FBI-arranged meeting with victims in the Epstein case,
so again in connection with that investigation (2018R01618), I'd like to please request permission to travel on Monday to
Florida and back. Unfortunately because of scheduling I expect l'll need to fly down and back both on Monday (and back
in time to make an afternoon flight to Tennessee for a separate work obligation), but it's possible
may need to go if
we can't get the scheduling. In any event, we're requesting approval for travel for one person for either zero nights or one
night, and no need for a conference room for this trip.
thanks very much,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject: FW: Maxwell
Date: Mon, 13 Jul 2020 20:58:56 +0000
Attachments: 6653181._Maxwell,_Ghislaine.pdf
From:
Sent: Monday, July 13, 2020 16:29
To:
Cc:
Subject: Maxwell
Good Afternoon-
There was a minor typo with some of the dates. Final report with the changes attached. Please disregard the report
attached in the prior email.
U.S. Pretrial Services Officer Specialist - Intake Coordinator
Southern District of New York
Office:
Fax:
EFTA00024470


c1: EFTA00026979
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026979.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein search warrant documents
Date: Mon, 06 Jul 2020 18:45:51 +0000
I'm talking to the team about discovery generally at 3, so if there have been any developments, or, in particular, anything
more I should be asking them, let me know.
From:
(USANYS)
Sent: Monday, July 6, 2020 11:26 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
As expected, FBI is pretty resistant to using a vendor. I explained to
that we just can't mess around with this
anymore. She is going to get updated information about status and we will talk again later today (her team told her that
we have been provided with roughly 30 of 52 devices, so obviously our information is not matching up).
From:
(USANYS)
Sent: Monday, July 6, 2020 8:49 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
Pretty sure it's everything. The estimate references 57 devices, as noted below, I think we're now up to 62, but we're into
one of them, so really 61. We can get an updated estimate for the 61 if that would be helpful, but given how much
business the PC unit gives
he should be good to us on that
From:
(USANYS)
Sent: Monday, July 6, 2020 8:44 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
What is the estimate for? All of these? Just UVI?
From:
(USANYS)
Sent: Friday, July 3, 2020 2:50 PM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
Yes, there are a total of 62 devices which can be divided into three main buckets based on how/where we obtained them,
the second and third of which are by far and away the biggest:
1 Phone and 1 iPad seized from Epstein at the time of his arrest on July 6, 2019. The FBI first delivered copies of
the extractions from these devices last week. We were able to review the iPad, but we have not been able to
open the iPhone data. IS THIS AN FBI TRANSMISSION ISSUE WITH THE IPHONE DATA, OR IS IT THAT IT WAS UN-
OPENABLE?
33 electronic devices seized from the New York residence on July 11, 2019. These include multiple hard drives,
multiple computers, multiple USB drives, and multiple iPads. We currently have extractions from/access to none
of them.
EFTA00026979

=== Page 2 ===
27 electronic devices seized from the Virgin Islands residence on August 12, 2019. These include multiple
computers, multiple iPads, and multiple USB drives. We currently have extractions from/access to none of them.
From:
(USANYS)
Sent: Friday, July 3, 2020 1:51 PM
To:
(USANYS)
Subject: Re: Epstein search warrant documents
Can you have the team summarize status of different buckets of devices for me? I'll push this to resolution,
possibly through vendor.
On Jul 2, 2020, at 7:13 PM,
(USANYS)
wrote:
Let's discuss. I just don't have a lot of confidence that is going to get this done.
Sent from my iPhone
On Jul 2, 2020, at 6:35 PM,
(USANYS)
wrote:
Ok. Audrey is also prepared to call
about pushing this issue if need be.
On Jul 2, 2020, at 6:32 PM,
(USANYS)
wrote:
On this issue of the Epstein devices, the team got an estimate from BRG that seems reasonable in terms of both cost
and time line. At this point, I would be inclined to do this, but let's find some time to chat more about it tomorrow if
you're around or early next week if that's better. Thanks
From:
)
Sent: Thursday, July 2, 2020 5:11 PM
To:
(USANYS)
Cc:
(USANYS)
i
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI - they are now well over a
month later than their estimate from April on when we would get the New York materials, they're also past their
estimate of getting us the New York materials from just this Monday, and we don't have anything close to an
estimate on the USVI materials, which constitute the overwhelming majority of the data and are vastly more
voluminous than the New York devices. We have kept pushing the timeline back for this option, hoping that CART
will finalize, but I think at this point we should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-
friendly format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very
effective and efficient, and they get the materials we need. And most importantly, they estimate they can do it all in
less than a month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
EFTA00026980

=== Page 3 ===
From:
)
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
>;
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
is
is
>;
(NY)
(FBI)
y
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
V.
y.
>;
(NY)
(FBI)
V.
(USANYS)
>
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks
again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
>;
)
Cc:
(USANYS)
i
(NY) (FBI)
is
is
i
(NY)
(FBI)
V.
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll
be able to see how many items to export, so we'll have a better sense of when we'll get those?
EFTA00026981

=== Page 4 ===
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
>;
(NY) (FBI)
is
is
>;
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how
many items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI
materials? I think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and
USVI?
thanks,
EFTA00026982

=== Page 5 ===
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per
my discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as
1 item in particular has over 500,000 emails. We will be able to provide discovery once Defense Council
has provided drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let
you know when everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could
you please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as
early as this week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything
that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or
have you and
figured out a way to categorize the prior productions so they're useful for us? We would strongly
prefer to just get everything at once in a usable format, but please let us know if you expect to produce materials
differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK
when I can expect the drives. Thanks.
NY CART Coordinator
EFTA00026983

=== Page 6 ===
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
i
)
is
is
(NY) (FBI)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July
and September searches before moving forward with possible additional charges in the case. I know you had
mentioned you needed to push back your prior estimate of complete production by early June, by a couple weeks, so
wanted to see what the current estimate is? I don't think we've started to get anything yet but please correct me if
I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
)
Cc:
(NY) (FBI)
is
is
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go
from there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
EFTA00026984

=== Page 7 ===
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If
we can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our
staffing levels will be steadily increasing over the next few weeks, but I'm going to have to push back my
estimate by a week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can
easily identify what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in
searchable format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to
specific devices - so if we're able to match them up by Bates number now, that might work, but otherwise I think it
makes sense for us to get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think
we've gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial
numbers. Any questions, let me know.
FBI NY CART Coordinator
EFTA00026985

=== Page 8 ===
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
is
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of
information we need is the serial number, or some other specific identifier, ideally for each device but at least for any
device that there is more than one of the same thing. So for example, we need to be able to somehow differentiate
the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the
USVI spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the
USVI list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to
reproduce all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we
aren't able to match any of the prior productions to specific devices - so if we're able to match them up by Bates
number now, that might work, but otherwise I think it makes sense for us to get everything. But let us know if any
issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
-
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
EFTA00026986

=== Page 9 ===
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I
could to convey the information. If you are confused by anything, please let me know. In the column for
approximate size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column,
I put what load file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight)
If there is no entry in that column, that data has yet to be transferred. There are 2 Macs and a DVR you
don't have as well as an iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what
I can to beef them up. I will get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
(NY) (FBI)
i
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a
format such that we can view them using a system we have access to. We're not able to get web-enabled access
through any FBI tool, so we asked for the materials to be transferred in a loadable format so we could put them on
Relativity, which both we and the agents can access. We're required to have the files in a format that we can
produce them to defense counsel. I've done that in many other cases and it hasn't previously been an issue. My
understanding from
is that the best way to do it now is just for us (the U.S. Attorney's Office) to get the original
files, which our vendor will process-by which I just mean converting into file formats that are loadable onto
Relativity. It doesn't really have anything to do with the taint review-we have to have access to the docs in our
systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents
earlier this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9.
Again, I understand from
that the best way forward is to just get copies of the materials in their original
formats, which I understand will be segregated and designated by device. That should work for us! I was just trying
to understand the approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
is
(USANYS) [Contractor]
Cc:
is
is
EFTA00026987

=== Page 10 ===
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking
files that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity)
to do a taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you
insisted you do the taint review in Relativity, I warned you that it was adding months worth of work on top
of what was already done, and that Relativity was incapable of viewing everything. You insisted we do it
this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get
it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it
piece by piece as things are processed, I was unaware that you didn't want to review as things were
processed, that you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a
differentiation of methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a
while back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just
basically sending us copies of everything? I don't totally understand why we couldn't have done that eight months
ago, but regardless of the passage of time, I want to make sure we understand so we can report to our supervisors.
I
assume that means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the
processing ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
-
Subject: RE: Epstein search warrant documents
EFTA00026988

=== Page 11 ===
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it
to a particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
in
Cc:
is
)
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so
we make sure we get all the info we need. I think you had previously sent us a list of certain information that
unfortunately wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload
it on our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already
been processed. I think what we talked about on the phone a month ago was getting, for example, data from one
device to make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
EFTA00026989

=== Page 12 ===
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data
and where the data was collected. I will work to send some hard drives to
so he can begin to copy the data
and send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
in
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to
review the returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
V.
)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave
you. If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for
complete transmission of the search warrant returns is no longer likely? If so could you please let us know what the
current estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
)
>;
EFTA00026990

=== Page 13 ===
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
i
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I
will be back in the office on Thursday and will be able to get you the list then as I have to access some of
our systems to do so.
Also,
,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're
waiting on that list to be able to do an updated search warrant on all of those devices. Please let us know the
current timeline - and also the current timeline on producing the results from those August and September
searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it
a couple months from our call, which would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
) [mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
>;
is
EFTA00026991

=== Page 14 ===
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us
know, otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
>;
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago,
but are you at all able to assist while working remotely? This has been pending for almost two months and we still
don't have a very basic list of each device or item that was seized and searched, or for which of those we've received
materials. We're happy to have a call if that would be useful, but as a first step the most basic thing we're looking for
is the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
)
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00026992

=== Page 15 ===
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24?
The excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we
sent on 2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you
mean by "loose media" without a specific comparison to what was seized, we don't know which items you're
referring to as "Windows machines," and we can't tell whether the entirety of any particular item has been
transferred, or just partial. For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see
the attached flight records," for example, we have no way of linking that up with the records themselves.
Not only is that a big problem for us in review, it's going to be a huge problem for producing the documents
to defense counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have
the native files show up in the database. Because many of the files are too large to open in the viewer, it
effectively means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of
numbers and no way to match up anything-that is, even if we were to try to go hunt down every individual
large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need
to get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more
than a million documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary
record-keeping, and we need that info at the very least, as well as anything else you think would be useful. Also
attaching the SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if
that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some
points of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3
copies of 3 drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were
all copies). All the loose media from the NY apartment is included. All the Windows machines from the NY apartment
are included. Only 2 Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the
tool they have to be processed with does not easily re-name the load files.
EFTA00026993

=== Page 16 ===
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so
we can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
i
)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
EFTA00026994

=== Page 17 ===
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together
to have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next
week? And what I think would be most helpful to facilitate that would be a spreadsheet of each separate device
referenced in the two search warrant returns, with columns for whether we've dumped the contents, whether
they've been reviewed and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the
attached is mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed,
transferred, and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I
think FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get
those to be able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
>;
(NY) (FBI)
>;
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they
mandated we delete old stuff (about 400 TB worth). Now that they are working on replacing the network,
we can do only local work. I should be able to give you an accounting of what is what. I can say, off the top
of my head, that all windows based items from the NY search have been handed over as well as all loose
media. The CDs from NY only contained pictures, no documents. There are still some Apple items from NY
that need to be produced. As far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac
has been produced. Still working on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e.,
EFTA00026995

=== Page 18 ===
which devices the materials came from, whether it's full or partial results, how many more devices we have coming,
etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of
moving pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming
week from Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be
plenty of time to schedule a productive meeting.
thanks all,
From:
)
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have
the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also
old materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's
new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of
what we're getting, and what has been completed, without some kind of identification or labeling system, along with
a list of which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a
modified date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we
haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled
"NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously
received? That folder by itself has more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the
folder or file names whether everything on the drive is new, or whether just additional materials were saved onto it
in addition to what we already have.
are you able to give us some guidance on this? Ultimately what we
really need is a spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying
that same info - which device, and what materials from it - are being given to us with each data transfer. Otherwise
I think organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
EFTA00026996

=== Page 19 ===
Southern District of New York
<mime-attachment>
EFTA00026997


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=== Page 1 ===
BEN SASSE
COMMITTEES
NEBRASKA
INTELLIGENCE
JUDICIARY
United States Senate
BANKING
WASHINGTON, DC 20510
August 10, 2019
The Honorable William P. Barr
Attorney General
U.S. Department of Justice
Washington, DC. 20530
Dear Attorney General Barr:
This morning, Jeffrey Epstein, the wealthy American financier indicted on numerous
charges for running an international child sex trafficking ring, was found dead by apparent
suicide. Epstein was being held in federal Bureau of Prisons custody after a federal judge denied
him bail. Disturbingly, his suicide occurred after an incident less than three weeks ago when he
was found injured and semi-conscious in his cell from a possible suicide attempt. News reporting
indicates that he was then placed on suicide watch but may have been taken off suicide watch
before today's events.
The Department of Justice failed, and today Jeffrey Epstein's co-conspirators think they
might have just gotten one last sweetheart deal. Every single person in the Justice Department -
from your Main Justice headquarters staff all the way to the night-shift jailer - knew that this
man was a suicide risk, and that his dark secrets couldn't be allowed to die with him.
Given Epstein's previous attempted suicide, he should have been locked in a padded
room under unbroken, 24/7, constant surveillance. Obviously, heads must roll.
During your nomination process, you committed to me to ensuring that justice would be
done for his victims. I was pleased to see the Department open an investigation into the
mishandling of the ridiculous 2008 non-prosecution agreement, and then the decision to bring
subsequent charges against Epstein. Knowing this monster's history of thwarting justice, I also
called for him to be held without bail upon his July 6 arrest.
It should have been abundantly clear that Epstein would go to any lengths to avoid being
held accountable for his crimes, including by killing himself. Being responsible for Epstein's
custody and prosecution, the Department of Justice should not have allowed this to happen. His
death not only deprives his victims of the opportunity to confront him in court and to see him
held accountable for his crimes, but also makes it harder to unravel his ring and to hold
accountable the many other powerful men who raped and exploited these children.
The Department must answer the following urgent questions for the American people:
1. Was Epstein in fact placed on suicide watch following his previous possible
suicide attempt?
KEARNEY OFFICE
LINCOLN OFFICE
OMAHA OFFICE
SCOTTSBLUFF OFFICE
WASHINGTON DC OFFICE
4111 FOURTH AVENUE
1128 LINCOLN MALL
304 NORTH 168TH CIRCLE
115 RAILWAY STREET
107 RUSSELL SENATE OFFICE BLDG
KEARNEY, NE 68845
LINCOLN, NE 68508
OMAHA, NE 68118
SCOTTSBLUFF, NE 69361
WASHINGTON, DC 20510-2709
(308) 233-3677
(402) 476-1400
(402) 550-8040
(308) 632-6032
(202) 224-4224
EFTA00023980

=== Page 2 ===
2. If so, was Epstein taken off suicide watch prior to his apparent suicide this
morning? And if so, why?
3. Can you confirm that you are ordering two investigations: one - presumably
Inspector General investigation - - into the Bureau of Prison's mismanagement of
the incarceration of Epstein; and another - presumably FBI investigation - into
any possible criminal activity surrounding this mismanagement?
4. Can you certify that all other potential evidence that investigators were
pursuing relating to Epstein's co-conspirators is being immediately secured by the
Department of Justice, so that no additional evidence or potential testimony is
also squandered?
Thank you in advance for your resolve to peruse justice in this matter.
Sincerely,
Ben Sasse
Ben Sasse
United States Senator
Chairman, Senate Judiciary Subcommittee on Oversight,
Agency Action, Federal Rights and Federal Courts
EFTA00023981


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c0:
=== Page 1 ===
From: Gary Bloxsome <gary.bloxsome@blackfords.com>
To:
Daniel Cundy
>, Jennifer
Richardson
Subject: Re: U.S. Department of Justice investigation
Date: Fri, 03 Jan 2020 15:30:01 +0000
Inline-Images: image083335.jpg; image921107.jpg
Dear Sirs,
Thank you for your email dated 2 January 2020.
I confirm that we do represent HRH the Duke of York.
I would be grateful if you could please clarify what specifically you invite us to contact you about.
Kind regards
Gary Bloxsome
Gary Bloxsome
Partner
RANKED IN
Chambers
LEGAL
UK
500
KINGDOM
Blackfords LLP I 15 Old Bailey London EC4M 7EF
2020
TOP TIER
DX 161400 Old Bailey 5
|
www.blackfords.com
Leading Firm
2020
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint
Walk, Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 2 Jan 2020, at 18:54,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department of Justice,
Southern District of New York. We have been advised that you currently represent HRH The Duke of York. Could you
please advise whether that is correct? We - my colleagues
and I - can be reached
anytime at these email addresses, or please let us know if you would prefer to set up a time to discuss via phone.
Regards,
EFTA00026542

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00026543


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c0:
=== Page 1 ===
From:
"
)"
To:
)"
Cc:
)"
i
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Jeffrey Epstein SW Returns- NP folders released
Date: Wed, 07 Oct 2020 13:46:50 +0000
Embedded: RE:_Jeffrey_Epstein_SW_Returns-_NP_folders_released_.msg
Sender:
Subject: RE: Jeffrey Epstein SW Returns- NP folders released
Message-Id:
<DM3P110MB05406EA8586D47AC8A43B5E2920A0@DM3P110MB0540.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
Cc:
Cc:
EFTA00026593


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c0:
=== Page 1 ===
From:
Subject: FW: US V. Maxwell, S2 20 Cr. 330 (AJN)
Date: Wed, 16 Jun 2021 03:44:27 +0000
Attachments: Maxwell_Reply_to_6-7-21_Conditions_Ltr.pdf
Hi
Please see the attached letter from Maxwell's counsel. Do you have time this week for a call to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
From: BOBBI c STERNHEIM <bcsternheim@mac.com>
Sent: Tuesday, June 15, 2021 6:49 PM
To:
Cc: Christian Everdell <CEverdell@CohenGresser.com>; Laura Menninger <lmenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Subject: US V. Maxwell, S2 20 Cr. 330 (AJN)
Good evening-
Attached is a courtesy copy of today's ECF fling.
Regards,
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main: 212-243-1100
Cell: 917-912-9698
Fax: 888-587-4737
bcsternheim@mac.com
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
EFTA00023918

=== Page 2 ===
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Jun 7, 2021, at 9:42 PM,
wrote:
Good evening,
Attached please find the Government's letter updating the Court about the defendant's conditions of confinement at
the MDC. The Government is still waiting to hear from defense counsel whether they are seeking redactions.
Accordingly, the Government is submitting the letter by email to the Court temporarily under seal to give the defense an
opportunity to propose and justify any redactions it deems necessary. We will file the letter on the docket at the Court's
direction.
Respectfully submitted,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
<2021-06-07 GM letter update re MDC conditions final.pdf>
EFTA00023919


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=== Page 1 ===
From:
To:
Subject: Read: RE: US V. Epstein
Date: Tue, 12 Nov 2019 19:49:56 +0000
EFTA00026771


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c0:
=== Page 1 ===
From:
To:
Subject: FW: Maxwell
Date: Mon, 13 Jul 2020 20:59:01 +0000
Attachments: 6653181._Maxwell,_Ghislaine.pdf
From:
Sent: Monday, July 13, 2020 4:29 PM
To:
Cc:
Subject: Maxwell
Good Afternoon-
There was a minor typo with some of the dates. Final report with the changes attached. Please disregard the report
attached in the prior email.
U.S. Pretrial Services Officer Specialist - Intake Coordinator
Southern District of New York
Office:
Fax:
EFTA00024494


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: relativity
Date: Sun, 24 Jan 2021 23:03:33 +0000
Yes, that sounds about right to me. As I recall, there were not a lot of emails between Epstein and Maxwell, and the
majority of the Maxwell emails came from just one of the thumb drives in the New York residence.
From:
Sent: Friday, January 22, 2021 3:49 PM
To:
Cc:
Subject: relativity
When I run the term "gmax" as a search term in the search warrant database, I'm getting only 3,835 hits. That seems low
to me. Is that right? I know you're on the road, so no rush, but when you have a chance to check that would be helpful.
Thanks,
Assistant United States Attorney
Southern District of New York
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c0:
=== Page 1 ===
09/06/06
ICMIPR01
19:21:34
FD-192
Page 1
Title and Character of Case:
EPSTEIN, JEFFREY
Date Property Acquired: Source from which Property Acquired:
DET.
08/28/2006
345 SOUTH COUNTY ROAD
PALM BEACH FL 33480
Anticipated Disposition: Acquired By:
Case Agent:
Description of Property:
Date Entered
1B 1
1) ONE PHONE MESSAGE BOOK
PBPD05-1024 (1)
2) THREE PHONE MESSAGE BOOKS
(2)
3) ONE FILE FOLDER WITH TWO FILES
(3)
4) SHREDDED PAPER
(4)
5) ONE FILE FOLDER - ORANGE
(5)
6) BEIGE MASSAGE TABLE
(6)
7) BROWN MASSAGE TABLE
(7)
8) BLACK FRAMED PHOTO OF NUDE GIRL
(8)
9) NINE PICTURES IN FRAMES
(9)
10) EIGHT PHOTOS FROM OFFICE
(10)
11) TWO PHOTOS - SITTING ROOM
(11)
12) TWO PHOTOS - TABLE
(12)
13) TWO VHS TAPES - POOL AREA
(13)
14) TWO CDS - MARKED "HAPPY BIRTHDAY"
(14)
15) THREE FRAMED PHOTOS - CABANA
(15)
16) ONE MESSAGE PAD - 1ST FLOOR
(16)
17) ONE MESSAGE PAD - DESK
(17)
18) THREE CDS - DESK
(18)
19) ONE 8MM - DESK
(19)
20) UNFRAMED PHOTOS - DESK
(20)
21) TWO FRAMED PHOTOS - DESK
(21)
22) TWO FRAMED PHOTOS - TABLE
(22)
23) THREE SOAPS ON A ROPE
(23)
24) TWO VIBRATORS - "TWIN TORPEDO"
(24)
25) TWO SOAPS ON A ROPE
(25)
26) ONE LARGE FRAMED PICTURE - MASTER BEDROOM
(26)
27) ONE HIGH SCHOOL TRANSCRIPT - AH
(27)
28) ONE BOTTLE OF JOY JELLY - MASTER BEDROOM
(28)
29) THREE VIDEO TAPES - MASTER BEDROOM
(29)
30) SIX FRAMED PHOTOS - MASTER BEDROOM, BATHROOM
(30)
Barcode:
Location:
09/05/2006
Case Number: 31E-MM-108062
Owning Office: MIAMI
File Copy
&
318-mm-108062-181
MM12-31E-MM-108062 SEC 001 SER 1-70-000004
EFTA00023516

=== Page 2 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B1
Barcode
:
Accepted By:
Printed Name:
Signature
Reason: Collected
Date/Time: 08/28/2006 11:00 am
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
MM12-31E-MM-108062 SEC 001 SER 1-70-000005
EFTA00023517

=== Page 3 ===
29/06/06
ICMIPR01
19:21:34
FD-192
Page 3
Title and Character of Case:
EPSTEIN, JEFFREY
Date Property Acquired: Source from which Property Acquired:
DET.
08/28/2006
345 SOUTH COUNTY ROAD
PALM BEACH FL 33480
Anticipated Disposition: Acquired By:
Case Agent:
Description of Property:
Date Entered
1B 2
31) ONE GREEN MASSAGE TABLE
PBPD05-1024 (31)
32) ONE THRIFTY RENTAL AGREEMENT
(32)
33) NOTE FROM
(33)
34) ELEVEN CDS - OFFICE
(34)
35) MESSAGE BOOK - GUEST HOUSE
(49)
(36) ONE MESSAGE BOOK
(50)
(37) TWO COMPACT FLASH CARDS
(51)
(38) SIX CDS - GUEST HOUSE
(52)
(39) POWER CORD TO CPU - GUEST HOUSE
(54)
(40) CPU - OFFICE
(55)
41) ONE POWER CORD TO CPU - OFFICE
(56)
42) THREE CDS - OFFICE
(57)
43) ONE PEACH MASSAGE TABLE
(58)
44) ONE GREEN FRAMED PHOTO
(59)
Barcode:
Location:
09/05/2006
Case Number: 31E-MM-108062
Owning Office: MIAMI
by
31E-MM-108062-1B2
MM12-31E-MM-108062 SEC 001 SER 1-70-000006
EFTA00023518

=== Page 4 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B2
Barcode :
Accepted By:
Printed Nam
Signature
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
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Date:
MM12-31E-MM-108062 SEC 001 SER 1-70-000007
EFTA00023519

=== Page 5 ===
9/06/06
ICMIPR01
19:21:34
FD-192
Page 5
Title and Character of Case:
EPSTEIN, JEFFREY
Date Property Acquired: Source from which Property Acquired:
DET
08/28/2006
345 SOUTH COUNTY ROAD
PALM BEACH FL 33480
Anticipated Disposition: Acquired By:
Case Agent:
Description of Property:
Date Entered
1B 3
1) TAPED CONVERSATION
PBPD 05-237 (1)
2) AUDIO TAPE #1
PBPD 05-243 (1)
3) AUDIO TAPE #2
(2)
4) COPY OF TAPE #1
(3)
5) MICRO TAPE
PBPD 05-256 (1)
6) PHOTO LINE-UP
PBPD 05-257 (1)
7) AUDIO TAPE
PBPD 05-294 (1)
8) MICRO TAPE
(2)
9) CD
PBPD 05-295 (2)
10) C-90 CASSETTE
PBPD 05-313 (1)
11) A/X MAIL
PBPD 05-378 (1)
12) WHITE PAPER
(2)
13) MESSAGE
(3)
14) WHITE PAPER J
(4)
15) MONTGOMERY COUNTY, MD
(5)
16) WHITE PAPER V.
PBPD 05-379 (1)
17) WHITE PAPER FLIGHT INFO
(2)
18) THREE WHITE PAPERS PREMIO COMPUTER INC
(3)
19) WHITE PAPER PHONE #
PBPD 05-380 (1)
20) YELLOW RECEIPT 04/04/05
(2)
21) WHITE PAPER
(3)
22) WHITE PAPER J.
(4)
23) WHITE PAPER FLIGHT 04/05/05
(5)
24) WHITE PAPER G.
(6)
Barcode:
Location:
09/06/2006
Case Number: 31E-MM-108062
Owning Office: MIAMI
3/E- MM -108062-133
MM12-31E-MM-108062 SEC 001 SER 1-70-000008
EFTA00023520

=== Page 6 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B3
Barcode :
Accepted By:
Printed Name
Signature
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
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Printed Name:
Signature:
Date:
MM12-31E-MM-108062 SEC 001 SER 1-70-000009
EFTA00023521

=== Page 7 ===
09/06/06
ICMIPR01
19:21:34
FD-192
Page 7
A
Title and Character of Case:
EPSTEIN, JEFFREY
Date Property Acquired: Source from which Property Acquired:
DET.
08/28/2006
345 SOUTH COUNTY ROAD
PALM BEACH FL 33480
Anticipated Disposition: Acquired By:
Case Agent:
Description of Property:
Date Entered
1B 4
1) WHITE PAPER A.
PBPD 05-381 (1)
2) WHITE PAPER JET BLUE RECEIPT
(2)
3). WHITE PAPER JU.
(3)
4) WHITE PAPER JO.
(4)
5) MESSAGE
(5)
6) WHITE PAPER
(6)
7) WHITE PAPER A.
(7)
8) WHITE PAPER
(8)
9) WHITE PAPER H.
(9)
10) WHITE PAPER ST. BARTHS
(10)
11) MESSAGE - G.
(11)
12) MESSAGE -
(12)
13) WHITE PAPER - F.
(13)
14) MESSAGE S.
(14)
15) MESSAGE
(15)
16) MESSAGE
(16)
17) WHITE PAPER - S.
(17)
18) WHITE PAPER #'S
(18)
19) WHITE PAPER - J.
(19)
20) WHITE PAPER - J.
(20)
21) WHITE PAPER (917)
(21)
22) WHITE PAPER
1.
(22)
23) PHONE # PRINT OUT
(23)
Barcode:
Location:
09/06/2006
Case Number: 31E-MM-108062
Owning Office: MIAMI
31E-MM-108062-184
MM12-31E-MM-108062 SEC 001 SER 1-70-000010
EFTA00023522

=== Page 8 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B4
Barcode :
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
Printed Name:
Signature:
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Printed Name:
Signature:
Date:
MM12-31E-MM-108062 SEC 001 SER 1-70-000011
EFTA00023523

=== Page 9 ===
09/06/06
ICMIPR01
19 21:34
FD-192
Page 9
Title and Character of Case:
EPSTEIN, JEFFREY
Date Property Acquired: Source from which Property Acquired:
DET
08/28/2006
345 SOUTH COUNTY ROAD
PALM BEACH FL 33480
Anticipated Disposition: Acquired By:
Case Agent:
Description of Property:
Date Entered
1B 5
1) FIVE MESSAGE PRINTOUTS
PBPD 05-382 (1)
2) WHITE PAPER
(2)
3) MESSAGE M.
(3)
4) MESSAGE
(4)
5) MESSAGE A.
(5)
6) MESSAGE
(6)
7) MESSAGE T.
(7)
8) CLEAR PLASTIC STICK
(8)
9) TWELVE WHITE PAPER - EXPENDITURES
PBPD 05-383 (1)
10) WHITE PAPER J.
(2)
11) WHITE PAPER D.
(3)
12) WHITE PAPER C.
(4)
13) WHITE PAPER J.
(5)
14) WHITE PAPER J.
(6)
15) WHITE PAPER M.
(7)
16) WHITE PAPER #
(8)
17) MESSAGE A.
PBPD 05-384 (1)
18) WHITE PAPER T.
(2)
19) WHITE PAPER
(3)
20) WHITE PAPER F.
(4)
21) MESSAGE
(5)
22) MESSAGE #
(6)
23) MESSAGE
(7)
24) WHITE PAPER
(8)
25) WHITE PAPER (917)
PBPD 05-385 (1)
26) WHITE PAPER A.
(2)
27) WHITE PAPER E.
(3)
28) WHITE PAPER
(4)
29) WHITE PAPER
(5)
30) FOUR WHITE PAPERS
(6)
Barcode:
Location:
09/06/2006
Case Number: 31E-MM-108062
Owning Office: MIAMI
31E-MM-108062-185
MM12-31E-MM-108062 SEC 001 SER 1-70-000012
EFTA00023524

=== Page 10 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B5
Barcode :
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
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Printed Name:
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Date:
MM12-31E-MM-108062 SEC 001 SER 1-70-000013
EFTA00023525

=== Page 11 ===
09/06/06
ICMIPR01
19:21:34
FD-192
Page 11
Title and Character of Case:
EPSTEIN, JEFFREY
Date Property Acquired: Source from which Property Acquired:
DET
08/28/2006
345 SOUTH COUNTY ROAD
PALM BEACH FL 33480
Anticipated Disposition: Acquired By:
Case Agent:
Description of Property:
Date Entered
1B 6
1) MEDICAL SUPPLIES
PBPD 05-386 (1)
2) 727 LETTERHEAD
(2)
3) INVOICE #42700
(3)
4) AMAZON.COM
(4)
5) WHITE PAPER
(5)
6) MESSAGE FROM J.
(6)
7) MESSAGE FROM
(7)
8) WHITE PAPER 2#S
(8)
9) WHITE PAPER (917)
(9)
10) MISC. DOCUMENTS - TRASH PULL
PBPD 05-874 (1)
11) MISC. PAPERWORK - TRASH PULL
PBPD 05-878 (1)
12) TWO MAGAZINES - TRASH PULL
PBPD 05-901 (1)
13) PAPER WITH
- TRASH PULL
PBPD 05-915 (1)
14) VHS T-160 CASSETTE
PBPD 05-929 (1)
15) SONY MICRO CASSETTE
(2)
16) SONY MICRO CASSETTE
(3)
17) SONY MICRO CASSETTE
(4)
18) SONY MICRO CASSETTE
PBPD 05-937 (1)
19) SONY MICRO CASSETTE
(2)
20) SONY MICRO CASSETTE
(3)
21) SONY MICRO CASSETTE
(4)
22) MISC PAPERWORK - - TRASH PULL
PBPD 05-941 (1)
23) SONY MICRO CASSETTE
PBPD 05-942 (1)
24) SONY MICRO CASSETTE
(2)
25) MISC PAPERS - TRASH PULL
PBPD 05-943 (1)
26) CLEAR PIECE OF PLASTIC
PBPD 05-944 (1)
27) MISC PIECES OF PAPER - TRASH PULL
(2)
28) SONY MICRO CASSETTE
PBPD 05-945 (1)
29) SONY MICRO CASSETTE
(2)
Barcode:
Location:
09/06/2006
Case Number: 31E-MM-108062
Owning Office: MIAMI
31E-MM-108062-182 31E- MM-
MM12-31E-MM-108062 SEC 001 SER 1-70-000014
EFTA00023526

=== Page 12 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B6
Barcode :
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/200 6. 11:00am
Accepted By:
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WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
MM12-31E-MM-108062 SEC 001 SER 1-70-000015
EFTA00023527

=== Page 13 ===
09/06/06
ICMIPR01
19:21:34
FD-192
Page 13
Title and Character of Case:
EPSTEIN, JEFFREY
Date Property Acquired: Source from which Property Acquired:
DET
08/28/2006
345 SOUTH COUNTY ROAD
PALM BEACH FL 33480
Anticipated Disposition: Acquired By:
Case Agent:
Description of Property:
Date Entered
1B 7
1) SONY MICRO CASSETTE
PBDP 05-972 (1)
2) SONY MICRO CASSETTE
(2)
3) SONY MICRO CASSETTE
(3)
4) MISC PAPERWORK - TRASH PULL
PBPD 05-1005 (1)
5) THREE FLOOR PLANS
PBPD 05-1023 (1)
6) DRAWING
PBPD 05-1025 (1)
7) MISC PHONE MESSAGES - TRASH PULL
PBPD 05-1027 (1)
8) T-160 VIDEO CASSETTE
PBPD 05-1052 (1)
9) SONY MICRO CASSETTE
(2)
10) SONY MICRO CASSETTE
PBPD 05-1064 (1)
11) THREE EMAIL FROM DMV/DL
(2)
12) VHS VIDEO CASSETTE
PBPD 05-1069 (1)
13) VHS VIDEO CASSETTE
(2)
14) CD
PBPD 05-1079 (2)
15) MINI DV TAPE
PBPD 05-1080 (1)
16) VHS VIDEO TAPE...
(2)
17) MINI DV TAPE
(3)
18) SONY MICRO CASSETTE
PBPD 05-1087 (1)
19) SONY MICRO CASSETTE
PBPD 05-1090 (1)
20) SONY MICRO CASSETTE
PBPD 05-1092 (1)
21) PHOTO LINE-UP
(2)
22) SONY MICRO CASSETTE
PBPD 05-1203 (1)
Barcode:
Location:
09/06/2006
Case Number: 31E-MM-108062
Owning Office: MIAMI
ly
31E- MM-108062-1137
MM12-31E-MM-108062 SEC 001 SER 1-70-000016
EFTA00023528

=== Page 14 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B7
Barcode :
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
Printed Name:
Signature:
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WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
MM12-31E-MM-108062 SEC 001 SER 1-70-000017
EFTA00023529

=== Page 15 ===
09/06/06
ICMIPR01
19:21:34
FD-192
Page 15
Title and Character of Case:
EPSTEIN, JEFFREY
Date Property Acquired: Source from which Property Acquired:
DET
08/28/2006
345 SOUTH COUNTY ROAD
PALM BEACH FL 33480
Anticipated Disposition: Acquired By:
Case Agent:
Description of Property:
Date Entered
1B 8
1) VHS TAPE OF SURVEILLANCE
PBPD 05-1205 (1)
2) VHS TAPE OF SURVEILLANCE
(2)
3) VHS TAPE
(3)
4) VHS TAPE
(4)
5) VHS TAPE
(5).
6) VHS TAPE
(6)
7) VHS TAPE
(7)
8) SIXTEEN DVD-R DISCS PBSO
PBPD 05-1219 (1)
9) CINGULAR ENVELOPE WITH SUBPOENA INFO
PBPD 05-1245 (1)
10) CINGULAR WIRELESS CD
(2)
11) SONY MICRO CASSETTE
PBPD 06-21 (1)
12) GREEN FOLDER A.
PBPD 06-24 (1)
13) SONY MICRO CASSETTE
PBPD 06-39 (1)
14) SONY MICRO CASSETTE
PBPD 06-59 (1)
15) SONY MICRO CASSETTE
PBPD 06-95 (1)
16) T-160 VIDEO CASSETTE
PBPD 06-120 (1)
17) SONY MICRO CASSETTE
PBPD 06-182 (1)
18) SONY MICRO CASSETTE
PBPD 06-348 (1)
19) CD
PBPD 06-397 (1)
Barcode:
Location:
09/06/2006
Case Number: 31E-MM-108062
Owning Office: MIAMI
En
31E-MM-108062-1B8
MM12-31E-MM-108062 SEC 001 SER 1-70-000018
EFTA00023530

=== Page 16 ===
Chain of Custody FD-192
Case ID * : 31E-MM-108062
1B8
Barcode :
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
Printed Name:
Signature:
Reason:
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WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
MM12-31E-MM-108062 SEC 001 SER 1-70-000019
EFTA00023531


c1: EFTA00027069
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00027069.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
]"
Subject: RE: Epstein Image/Video File Review Protocol
Date: Mon, 19 Oct 2020 21:28:29 +0000
Thanks very much. 1pm works. 3:30 would be tough for me.
From:
Sent: Monday, October 19, 2020 5:25 PM
To:
Subject: RE: Epstein Image/Video File Review Protocol
I'm thinking we actually push this back to tomorrow afternoon. It looks as though a few of the reviewers have already
logged off and I want to make sure they have time to read and review the protocol and warrant. I'm going to propose
tomorrow at either 1:00 or 3:30 if that works.
From:
Sent: Monday, October 19, 2020 4:40 PM
To:
Subject: RE: Epstein Image/Video File Review Protocol
Thanks very much. 10am tomorrow works for me.
From:
Sent: Monday, October 19, 2020 4:22 PM
To:
Subject: RE: Epstein Image/Video File Review Protocol
I'm going to relay this to our assembled team. Rather than ask all of them what time works it would be easier to propose a
couple times and go from there. Would tomorrow morning around 10:00 be an okay time to propose? I don't want to
schedule a time that would conflict with anything you have going on.
From:
Sent: Monday, October 19, 2020 4:08 PM
To:
is
is
is
is
Cc:
is
Subject: Epstein Image/Video File Review Protocol
All,
Attached please find the review protocol for the image and video files from Epstein's devices. The protocol asks that all
reviewers read the warrant and supporting affidavit, which are both attached here as well. I am also attaching a copy of
the Maxwell indictment, which contains a photograph of Epstein and Maxwell.
Once the USAO and FBI review teams are assembled, please let me know when would be a good time for me to have a
call with them to talk through the review and answer any questions.
In the first instance, we would ask that the FBI team review the following devices:
EFTA00027069

=== Page 2 ===
NYC024363
NYC024394
NYC024326
NYC024368
NYC024390
NYC024334
NYC027910
NYC024323
NYC024355
NYC027908
Depending on how quickly the FBI and USAO teams move through the review, we may reassign some devices between the
teams.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00027070


c1: EFTA00024830
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024830.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Epstein
Date: Wed, 19 Dec 2018 18:05:42 +0000
Importance: Normal
I'm in white Plains already. I just tried
Feel free to call my cell
Sent from my iPhone
On Dec 19, 2018, at 12:58 PM,
(USANYS)
wrote:
Let me know if you have two minutes before you go to WP?
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaz
EFTA00024830


c1: EFTA00024442
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024442.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: SDNY investigation
Date: Tue, 07 Jul 2020 18:04:14 +0000
Attachments: 2020-06-29,_subpoena_to_UBS.pdf
Mr. Wills,
I'm reaching out in connection with the attached subpoena, which was served on UBS last week. If possible, we would
like to speak with someone in your compliance department to discuss expediting these materials. This matter is time
sensitive, and if possible, we would very much appreciate being able to speak with someone this afternoon. I'm also
copying Mr. Ryan, who I understand has assisted with prior productions to our office in connection with this same
investigation.
I can be reached at
at any time, and I'm copying my colleagues,
and
who
can be reached at
and
respectively.
Thank you,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10
EFTA00024442


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=== Page 1 ===
CG
COHEN & GRESSER LLP
Mark S. Cohen
Christian R. Everdell
March 15, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we will be filing the following reply
memoranda with accompanying exhibits:
1. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for
Breach of the Non-Prosecution Agreement
2. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of
the Superseding Indictment as Time-Barred
3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress
All Evidence Obtained from the Government's Subpoena to
and to
Dismiss Counts Five and Six
4. Reply Memorandum in Support of Motion to Dismiss Counts Five and Six of the
Superseding Indictment Because the Alleged Misstatements Are Not Perjurious as a
Matter of Law
5. Reply Memorandum in Support of Motion for a Severance of and Separate Trial on
Counts Five and Six of the Superseding Indictment
6. Reply Memorandum in Support of Motion to Strike Surplusage from the Superseding
Indictment
7. Reply Memorandum in Support of Motion to Dismiss Counts One Through Six of the
Superseding Indictment for Pre-Indictment Delay
8. Reply Memorandum in Support of Motion to Dismiss Either Count One or Count
Three of the Superseding Indictment as Multiplicitous
9. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment as
It Was Obtained in Violation of the Sixth Amendment
10. Reply Memorandum in Support of Motion for a Bill of Particulars and Pretrial
Disclosures
EFTA00024023

=== Page 2 ===
The Honorable Alison J. Nathan
March 15, 2021
Page 2
11. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell,
and the Fifth Amendment to Suppress All Evidence Obtained from the Government's
Subpoena to
and to Dismiss Counts Five and Six
12. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of
the Superseding Indictment for Lack of Specificity
Several of the reply memoranda reference or discuss Confidential Information produced
in discovery and are therefore redacted pursuant to paragraph 15 of the Protective Order (Dkt.
36). In order to give the government the chance to review the proposed redactions, we will not
file on the public docket any reply memoranda that contain redactions until we are instructed to
do so by the Court. 1
The remaining reply memoranda do not contain any redactions. However, we are
mindful of the fact that the government's Omnibus Memorandum in Opposition to the
Defendant's Pre-trial Motions, to which the reply memoranda respond, has not yet been filed on
the public docket. Accordingly, we will also refrain from filing the reply memoranda that do not
contain redactions on the public docket until we are instructed to do so by the Court.
Instead, we will submit by email to the Court and the government all of the reply
memoranda and exhibits pursuant to Rule 2(B) of the Court's individual rules of criminal
practice. For the reply memoranda and exhibits that contain redactions, we will submit two
versions - an unredacted original to be kept under seal and a version for public filing with
proposed redactions.
Please contact us with any questions. Your consideration is greatly appreciated.
Respectfully submitted,
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER
cc:
All counsel of record (via email)
I
For documents that the government has designated as "Confidential," we have preliminarily indicated that they be
filed under seal, as required by paragraph 15 of the Protective Order. However, because some of the exhibits are
"judicial documents," we intend to propose that those "Confidential" designations be amended consistent with our
March 9, 2021 letter to the Court.
EFTA00024024


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
October 8, 2020
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
We write in response to your letters dated September 21, 2020 and October 1, 2020
regarding the above-referenced case.
1. The Government Has Met Its Discovery Obligations
As an initial matter, you repeatedly assert that the Government "has not met its discovery
obligations." (Sept. 21, 2020 Ltr. at 4; Oct. 1, 2020 Ltr. at 1, 3). The Government respectfully
disagrees. The deadline for the production of Rule 16 discovery set by the Court, including but
not limited to "electronic materials" is November 9, 2020, which is more than a month away. (Dkt.
25). The deadline for "initial non-electronic discovery, generally to include search warrant
applications and subpoena returns," was due on August 21, 2020, and, as you are aware, the
Government in fact made a substantial initial production before that deadline. (Id. (emphasis
added)).
The Government has also made substantial efforts to ensure that copies of the discovery
produced to defense counsel are also available to the defendant at the Metropolitan Detention
EFTA00026813

=== Page 2 ===
Page 2
Center ("MDC"). And while there have been technical difficulties with certain of the productions
made to the defendant, the Government understands that defense counsel is able to access all of
the material, and, as detailed herein, we have worked promptly to address each concern you have
raised with respect to productions made directly to the defendant. In sum, your claim that the
Government has not met its discovery obligations because of the delay caused by your requests to
reformat and reburn the discovery is simply inaccurate. The Government has met its discovery
obligations and will continue to do so in the remaining month prior to the relevant discovery
deadline.
In addition, as set forth below, the Government has conferred with MDC counsel regarding
the various complaints you have raised in your September 21 and October 1 letters in order to
accommodate your requests and in order to ensure that the defendant can timely review discovery.
2. The Government's Extensive Efforts to Ensure the Defendant Can Review
Discovery at MDC
The Government has taken considerable efforts to address the defendant's complaints
about her access to discovery in this case. As an initial matter, when making its productions, the
Government had no reason to believe the defendant would be unable to review any of the discovery
materials at the MDC. Indeed, the Government notes that it followed the same procedure in
producing discovery to defense counsel as it did to the defendant. Nor could the Government
possibly have anticipated which of the hundreds of thousands of files produced to date the
defendant would be unable to view using the computer provided to her by the MDC. However, as
soon as defense counsel notified the Government on August 27, 2020 that the defendant could not
access a portion of the discovery materials, the Government worked with its paralegal and
Information Technology staff to create new copies of the discovery materials you identified in a
new format. Due to the volume of files requiring review and reprocessing, that process took
several days. Once the files were reformatted, the Government loaded them onto a new drive,
which it sent to the MDC on September 3, 2020.
Subsequently, your September 21, 2020 letter identified a portion of the Government's first
three productions that the defendant was unable to view at the MDC. The Government notes that
even without being able to view those files, the defendant was still able to review tens of thousands
of pages of discovery while awaiting correction of the technological problem, and the Government
understands, as noted, that defense counsel has been able to view the entirety of the productions.
Since learning from you that the defendant was experiencing difficulty viewing certain files, the
Government has taken several steps to ensure that the defendant has access to every file.
First, the Government has worked with its paralegal and Information Technology staff to
create new copies of the discovery materials you identified in your September 21, 2020 letter. That
process involved converting certain files into new formats, changing the names of certain files,
and providing software programs to help run certain files. Due to the extent of this review and
reprocessing, these steps took several days. Once the files were reformatted, the Government
loaded them onto a new drive, which it sent to the MDC on October 2, 2020. The cover letter
accompanying that production included instructions for how the defendant may access the files
she previously had difficulty viewing.
EFTA00026814

=== Page 3 ===
Page 3
Second, the Government has asked MDC legal counsel to send an MDC Information
Technology ("IT") staff member to examine the computer the defendant is using to review her
discovery at the MDC. The Government has asked that the IT staff member load any software
necessary to view the files that the defendant has had difficulty accessing onto her MDC computer.
The Government understands from MDC legal counsel that an IT staff member has completed
such a review of the defendant's computer at the MDC. Should the defendant have difficulty
accessing files on the MDC computer in the future, she should alert MDC staff and request another
review of the computer by IT staff.
The Government also asked MDC legal counsel to ensure that the defendant has a writing
surface on which to take notes while reviewing discovery. MDC legal counsel has informed the
Government that MDC staff has repositioned the items on the table at which the defendant reviews
discovery such that she can use the table as a writing surface. MDC legal counsel has also
informed the Government that the defendant has access to a privacy screen to use when reviewing
discovery on the MDC computer. MDC legal counsel further noted that the defendant currently
has more access to discovery than any other inmate in the facility.
Third, as a stopgap while completing the above processes, the Government reminded
defense counsel that counsel is permitted to bring a laptop containing copies of any discovery
materials produced to date into the MDC to review with the defendant. The Government
understands from MDC legal counsel that that defense counsel is aware of this permission and has
been able to visit the defendant in person at the MDC on multiple occasions.
Taken together, these steps should ensure that the defendant has access to the discovery
productions made to date and with many months left to review those productions before trial. The
Government will continue to work with defense counsel and the MDC to address any issues that
may arise regarding the defendant's access to discovery.
3. The Government's Efforts to Ensure that the Defendant Can Review Highly
Confidential Materials
Since receiving your request for your client to review Highly Confidential discovery
material in the FBI's possession, the Government has taken several steps to address your request.
Due to the ongoing pandemic, the United States Marshals Service ("USMS") will not produce a
defendant from the MDC to the courthouse for any reason other than a court appearance.
Accordingly, the Government cannot take the usual step of requesting the USMS to produce the
defendant to a proffer room in the courthouse where she can review the Highly Confidential
materials with defense counsel present.
As an alternative, the FBI has agreed to assign two agents to bring a secure laptop
containing the Highly Confidential materials to the MDC, where defense counsel and the
defendant may review the Highly Confidential materials together. So long as defense counsel
submits to a search to ensure that no electronic devices or electronic storage media is being brought
into the attorney visiting room, the agents will permit defense counsel and the defendant to review
the computer alone while the agents wait outside the room. The FBI has loaded the secure laptop
EFTA00026815

=== Page 4 ===
Page 4
with all of the approximately 43,500 images that were seized from Jeffrey Epstein's residences in
New York and the Virgin Islands. Accordingly, the FBI is prepared to facilitate the review of
these items as soon as the MDC will permit such a visit. The FBI understands that defense counsel
and the defendant may require multiple meetings to review all of the images and is accordingly
prepared to bring the secure laptop to the MDC on multiple dates.
The Government has asked MDC legal counsel to authorize the FBI to bring the Highly
Confidential materials into the facility for defense counsel and the defendant to review. In
response, MDC legal counsel indicated that such visits require authorization from the Warden.
The Government urged MDC legal counsel to approve the proposed visits as quickly as possible,
and today, the Government learned that the Warden has approved this proposal. The FBI and
MDC can accommodate a visit next week, and the Government will coordinate with defense
counsel, the FBI, and the MDC to assist with scheduling this first and any subsequent visits.
Additionally, as the Government has repeatedly informed you, defense counsel may
schedule a time to come to the FBI offices in Manhattan to review the above-referenced 43,500
images, as well as any other physical items referenced in the discovery productions. Those
appointments can be made with much less notice because they do not require arranging the
logistics of providing Highly Confidential images to an incarcerated defendant.
Finally, the Government is still processing the 40,000 of the above-referenced images that
do not contain nudity for production to counsel and to the defendant at the MDC. Due to the
volume of those images, that process has taken multiple weeks. The Government expects that the
images will be ready to produce within approximately one week.
4. Conditions of Confinement
Since receiving your September 21, 2020 letter, the Government has consulted with MDC
legal counsel regarding the defendant's conditions of confinement. As discussed on our September
22, 2020 call, immediately after receiving your letter, the Government contacted MDC legal
counsel, and within approximately 24 hours, the Government had answers to several of the
concerns raised in the letter, which the Government conveyed to you over the phone. Over the
next two weeks, the Government awaited responses regarding the other complaints raised in your
September 21, 2020 letter from the MDC. The Government has now received responses from
MDC legal, which are incorporated herein.
First, MDC legal counsel indicated that the staff assigned to the defendant have worked to
minimize the delays identified in your September 21, 2020 letter. As a result, the defendant should
have up to thirteen hours per day of access to discovery, though she may also use that time for
other activities, such as attorney visits, calls, recreation, and personal hygiene. That amount of
time far exceeds the discovery access any other MDC inmate currently enjoys. MDC legal counsel
1
Of those 43,500 images, approximately 3,500 contain nude or partially nude images, and
approximately 40,000 do not contain nudity. Per your request, the FBI has loaded all 43,500
images together onto a laptop so that defense counsel and the defendant may review all of the
seized images at the same time.
EFTA00026816

=== Page 5 ===
Page 5
also confirmed that staff will not put their fingers into the defendant's mouth for any searches.
The Government inquired of MDC legal counsel whether the defendant could be permitted to sleep
in the rec room where her computer and shower are located instead of the isolation cell. In
response, MDC legal counsel indicated that the defendant will be required to sleep in the isolation
cell. According to MDC legal counsel, the Bureau of Prisons ("BOP") and MDC still feel that this
is the most appropriate placement for the defendant, both for her safety and the security of the
institution.
Second, the Government inquired of MDC legal counsel whether it would be possible to
reduce the number of body scans conducted on the defendant. In response, MDC legal counsel
indicated that the defendant will be required to undergo weekly body scans. According to MDC
legal counsel, the BOP and MDC believe these scans are necessary for the security of the
institution.
Third, MDC legal counsel has informed the Government that the defendant has the same
access to commissary as any other inmate at the facility. As noted during our September 22, 2020
call, the defendant was provided with two different sizes of sports bras to choose from, and MDC
legal counsel understands that at least one of those sizes was acceptable to the defendant.
Fourth, as referenced during our September 22, 2020 call, the Government has been
assured by MDC legal counsel that the defendant is receiving three meals per day. According to
MDC legal counsel, MDC staff now wait until later in the day to pick up the defendant's meals for
each day, thereby ensuring that every portion of the meal (including side dishes and vegetables) is
included. MDC legal counsel has also assured the Government that MDC staff keep the
defendant's meals in a refrigerator to ensure that her food remains fresh. Additionally, if the
defendant misses a meal due to a legal visit or other appointment, MDC staff will leave the meal
for the defendant to eat upon her return. MDC legal counsel also noted that the defendant has
purchased and received a number of supplemental food items from commissary, including, among
other items, granola, mackerel, cheese, nutrition bars, soup, tortillas, crackers, honey buns,
sausage, eggplant parmesan, and nuts. Further, MDC legal counsel has informed the Government
that the defendant is seen by medical staff once per week. At those appointments, the defendant
is weighed and told her weight.
Fifth, as noted during our September 22, 2020 call, MDC legal counsel has indicated that
the defendant has received all mail that the MDC has received addressed to her and in compliance
with BOP regulations. MDC legal counsel confirmed that letters sent on colored paper do not
comply with BOP regulations and would be rejected. If a letter is rejected, the defendant will
receive a notification of the rejection. MDC legal counsel further indicated that inmates are not
permitted to receive care packages of food or other items from outside vendors, but the defendant
can purchase legal pads and pens from commissary. MDC legal counsel further informed the
Government that the MDC has not received any copies of The New York Times addressed to the
defendant.
...
EFTA00026817

=== Page 6 ===
Page 6
In sum, the Government has met and will continue to meet its discovery obligations, and
has worked expeditiously to address all of the concerns you have raised regarding the defendant's
access to discovery and conditions of confinement. We remain available and willing to address
any questions or concerns that may arise.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
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=== Page 1 ===
Event: Accepted: Epstein Call
Start Date: 2020-05-22 17:00:00 +0000
End Date: 2020-05-22 18:00:00 +0000
Location:
8146826
Class: X-PERSONAL
Comment:
Date Created: 2020-05-21 14:21:18 +0000
Date Modified: 2020-05-21 14:21:18 +0000
Priority: 5
DTSTAMP: 2020-05-21 13:57:31 +0000
Attendee:
(USANYS) [Contractor]
EFTA00026539


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein Pros Memo
Date: Wed, 14 Aug 2019 17:45:24 +0000
Attachments: 2019-06-17,_JE,_prosecution_memo.docx; 2019-06-
19,_JE,_status_memo_for_ODAG.docx; 2019-06-24,_JE_urgent_matter_report.docx
Sure, attached. Depending on what exactly you're looking for, the ODAG memo and UMR from when we were charging,
also attached, may also be useful.
From:
(USANYS)
Sent: Wednesday, August 14, 2019 13:15
To:
)
is
)
>;
)
Subject: Epstein Pros Memo
Can you send it to me?
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00024399


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
(NY) (FBI)"
(NY) (OGA) (FBI)"
Subject: RE: Image/Video file review for Maxwell case
Date: Mon, 19 Oct 2020 16:03:47 +0000
Thanks
I'll touch base with
today.
From:
(NY) (FBI)
Sent: Monday, October 19, 2020 10:02 AM
To:
)
Cc:
(NY) (FBI)
is
(NY) (OGA) (FBI)
Subject: Re: Image/Video file review for Maxwell case
Hi
I was out of the office when you sent this email. I also will be out of the office this full week. I know
and
are both back now but am happy to give you call to discuss logistics, as I will be helping on this when I'm
back.
Thanks,
From:
Sent: Friday, October 16, 2020 4:51 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
is
(NYPD)
is
i
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Image/Video file review for Maxwell case
Following up on this, I'll be working this evening and all weekend, so I'm happy to have a call whenever works for you in
that timeframe. Ideally, I'd like to touch base before Monday so that we can hit the ground running with the review first
thing Monday morning.
Thanks very much,
From:
Sent: Friday, October 16, 2020 1:45 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
is
(NYPD)
is
is
(USANYS)
Subject: Image/Video file review for Maxwell case
EFTA00024729

=== Page 2 ===
Hi
My supervisors gave me your name as the point of contact at the FBI to help coordinate the review of images and videos
from Jeffrey Epstein's devices for discovery in the Ghislaine Maxwell case. Thank you so much for being willing to help out
with this while
and
are traveling.
I've spoken with
about some of the logistics, and it would be great if you and I could have a call to talk about
next steps. Is there a time this afternoon when you would be free for a call?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
)"
To: Christian Everdell <CEverdell@CohenGresser.com>
Cc:
)"
(USANYS)"
>, "Mark S. Cohen" <mcohen@CohenGresser.com>, "Laura
Menninger" <Imenninger@hmflaw.com>, Jeff Pagliuca <jpagliuca@hmflaw.com>, "Bobbi
Sternheim (bcsternheim@mac.com)" <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - discovery production
Date: Tue, 20 Oct 2020 13:49:25 +0000
Attachments: 2020.10.20_Maxwell_Discovery_Letter.pdf
Chris,
Your drive is ready for pickup at 1 St. Andrews, and Ms. Maxwell's drive has been sent to the MDC. Attached please find
the accompanying letter.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, October 19, 2020 5:47 PM
To: Christian Everdell <CEverdell@CohenGresser.com>
Cc:
>;
(USANYS)
>; Mark S. Cohen
<mcohen@CohenGresser.com>; Laura Menninger <lmenninger@hmflaw.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>;
Bobbi Sternheim (bcsternheim@mac.com) <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - discovery production
Chris,
We have received the drives, thank you. They are being loaded, and I will let you know when yours is ready for pickup and
when your client's has been sent to the MDC.
I will have the agents plan for Friday from 8am to 3pm.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00025508

=== Page 2 ===
1 St. Andrew's Plaza
New York, NY 10007
From: Christian Everdell <CEverdell@CohenGresser.com
Sent: Monday, October 19, 2020 1:33 PM
To:
Cc:
is
(USANYS)
>; Mark S. Cohen
<mcohen@CohenGresser.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>;
Bobbi Sternheim (bcsternheim@mac.com) <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - discovery production
-
The hard drives were delivered just after 1pm. Please confirm receipt.
Also, we have asked for a prison visit from 8am-3pm on Friday for the review of the secure laptop. I will let you know
when we receive confirmation. Please have the agents plan for Friday.
Thanks,
Chris
From:
)
[mailto:
Sent: Sunday, October 18, 2020 11:34 PM
To: Christian Everdell
Cc:
);
(USANYS); Mark S. Cohen; Laura Menninger; Jeff Pagliuca; Bobbi Sternheim
(bcsternheim@mac.com)
Subject: RE: US V. Maxwell - discovery production
Chris,
Thanks very much, I'll be in the office and available to receive the drives.
The agents can make themselves available Thursday or Friday. Please let me know what date and time you end up
scheduling with the MDC.
Best,
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Sunday, October 18, 2020 10:47 PM
To:
Cc:
is
(USANYS)
>; Mark S. Cohen
<mcohen@CohenGresser.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>;
Bobbi Sternheim (bcsternheim@mac.com) <bcsternheim@mac.com>
Subject: Re: US V. Maxwell - discovery production
-
We will deliver two drives to you tomorrow. I will let you know when the drives have been dropped off.
EFTA00025509

=== Page 3 ===
Also, we are going to have to move the day that Ms. Maxwell reviews the secure laptop until later in the week. Are the
agents free on Thursday or Friday?
Sent from my iPhone
On Oct 18, 2020, at 12:33 PM,
wrote:
Chris,
We expect to have another discovery production ready to load tomorrow, October 19, 2020. Would you please provide
us with two more drives (one for you and one for your client) onto which we can load the production?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: Call with Katya Jestin
Date: Wed, 12 May 2021 01:04:17 +0000
Today I spoke with Katya Jestin. Katya had previously indicated that she represents a wealthy, anonymous client who
wishes to provide financial assistance to victims of Jeffrey Epstein. Katya had asked whether our office could connect her
with attorneys who represent Epstein victims. Previously, I had told Katya I would get back to her.
During today's call, I indicated that our team could not and would not play any role in connecting Katya's client with
Epstein victims. I indicated that we could not provide any information regarding the names or contact information of any
victim attorneys. I explained that we could not be involved in any way in conveying funding from Katya's client to any
potential witnesses in our case. To date, I have not conveyed any information about Katya's request to any witnesses or
witness counsel in this case.
Katya indicated that she understood our position and appreciated our team's consideration.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
)"
To:
Subject: Next tranche of MILs
Date: Sat, 23 Oct 2021 23:27:17 +0000
Attachments: Exhibits_v2.docx; Suppress_ID_v2.docx; Irrelevant_mots_v1.docx
Hi team,
Attached are (1) the various responses on the things we're not doing, (2) a response on the three exhibits motion, and (3)
a response on the motion to suppress MV-4's ID. I've copied
who I think should look at (2) and (3).
whenever you're getting ready to look at them, maybe send us all an email so you can get the latest version?
This leaves two motions, precluding reference to "victims" and precluding reference to "rape," which I'll get you tonight.
Thanks!
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: FW: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Thu, 11 Jul 2019 02:07:13 +0000
Importance: Normal
I'm at my desk if you want to have a call.
From: Roberta Kaplan
Sent: Wednesday, July 10, 2019 10:06 PM
To:
is
Conlon
>; Jenna Dabbs
>; Alexandra Elenowitz-Hess
Cc:
is
Subject: Re: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Can you talk?
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
New York, New York 10118
(212) 763-0883
From:
Sent: Wednesday, July 10, 2019 5:56:39 PM
To:
Conlon; Roberta Kaplan; Jenna Dabbs; Alexandra Elenowitz-Hess
Cc:
);
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hi all,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has
the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving
release. Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's
rights-under that statute, to see whether your client would like to be heard in any fashion, whether through a
submission, a representation that we can include in our bail submission due Friday, or some other form. Of course no
requirement or obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that while I don't want to prejudge the
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make
myself available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00026683

=== Page 2 ===
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
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April 21, 2021 Call with Dr.
Dr. Rocchio's training is over the course of her career, not just in graduate school. The
topics included traumatic stress (the effects of trauma), and clinical as well as forensic
psychology.
Dr. Rocchio has written about, presented, and conducted numerous trainings on the
assessment and treatment of trauma.
Dr. Rocchio also trains psychiatric residents at Brown in treating trauma survivors.
Dr. Rocchio's testimony is based on her education as well as her training, experience, and
research.
Saying that victims are "susceptible" puts the onus on victims. It is more accurate to say
that individuals or victims are "targeted."
Sexual abuse of minors frequently occurs through the use of manipulation or coercion in
the context of an established relationship that is developed over time rather than through
the use of forcible rape.
It's not fair to say that the presence of women can "especially" facilitate the sexual abuse
of minors. Abusers might use all sorts of other people.
Victims are often subject to a strategic pattern of behaviors that can take a variety of forms
and function to obscure the nature of the abuse and to build trust and attachment with their
abuser. That relationship of trust and attachment, in turn, can prevent victims from being
aware that what they are experiencing is abuse and can prevent disclosure. Minor victims
may therefore not identify what's happening as abusive at the time or during the course of
the abuse and may not recognize the consequences of that abuse until adulthood.
Most sexual assaults go unreported and disclosures are often made long after the incident.
Nondisclosure, incremental disclosure, and secrecy are common among victims of sexual
abuse for a variety of reasons, which can include fear, shame, humiliation, fear of not being
believed, and fear of retaliation.
Re memory: memory for and disclosure of traumatic/abusive events is impacted by a
number of factors. Dr. Rocchio can testify about the research regarding the various factors
that go into how people can remember abuse-what's encoded to begin with, which pieces
are remembered. That can include the circumstances surrounding the trauma, but also other
things. The remembering process can be a piece, but just one piece.
Repeated exploitation/abuse can increase the likelihood of victimization later in life and
has been shown to result in long-term traumatic and psychological consequences, including
the ways in which the victim interacts with the legal system.
Numerous scientific studies show the significant psychological harm that can result from
childhood sexual victimization.
Complex trauma is significant for repeated episodes of repeated childhood sexual abuse.
It's associated with more harmful outcomes than PTSD.
Complex trauma = trauma that involves repetitive or prolonged exposure to or
experiences of multiple traumatic stressors, involves harm or abandonment by
3502-005
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EFTA00026937

=== Page 2 ===
caregivers or other trusted adults, and occurs at developmentally vulnerable times
in a person's life, especially during childhood.
When childhood sexual abuse occurs under those conditions, it can be considered
complex trauma
The prolonged nature of complex trauma and the resulting disruption to an
individual's psychological development can result in profound dysregulation in
emotional control, problems with attention/concentration, distorted perceptions of
self/the perpetrator/others, severe traumatic/medical problems, and difficulties with
identity/relationships/suicidality/behavioral control.
Distorted perceptions of the perpetrator: may view the perpetrator as
someone who has been particularly loving, all powerful or all malevolent,
someone who intended to do good, etc. Different ways, but it impacts how
the victim view that person.
Dr. Rocchio's testimony relies on her education and training on psychological trauma,
traumatic stress, interpersonal violence, and childhood sexual abuse. (That includes her
knowledge of the literature.) She has also provided education and training, not just
received it.
Dr. Rocchio also has a forensic practice conducting forensic psychological evaluations of
people who have experienced sexual abuse and trauma.
Dr. Rocchio is also a member of the APA Ethics Committee.
Dr. Rocchio's practice involves supervising 7 other employees
3502-005
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BUT
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
United States Courthouse
300 Quarropas Street
White Plains, New York 10601
January 8, 2020
BY ECF
The Honorable Kenneth M. Karas
United States District Judge
Southern District of New York
300 Quarropas Street
White Plains, NY 10601
Re:
United States v. Nicholas Tartaglione, S4 16 Cr. 832 (KMK)
Dear Judge Karas:
The Government respectfully submits this letter to provide a further update to the Court
regarding the defense's request for video footage from outside the defendant's cell at the
Metropolitan Correctional Center ("MCC") on July 22 - July 23, 2019 (the "Requested Video").
On or about December 19, 2019, the Government informed the Court and defense counsel that it
had confirmed with MCC staff that the Requested Video had been preserved, and that the
Government was working to obtain a copy from MCC. As set forth in greater detail below, the
Government has learned that the MCC inadvertently preserved video from the wrong tier within
the MCC, and, as a result, video from outside the defendant's cell on July 22 - 23, 2019 no longer
exists.
On or about July 23, 2019, at approximately 1:27 a.m., MCC corrections officers responded
to the cell ("Cell-1") that the defendant shared with Jeffrey Epstein. On or about July 25, 2019,
defense counsel requested that MCC preserve video footage from outside the defendant's cell from
July 22, 2019 at 11:00 p.m. through July 23, 2019 at 4:00 a.m. From speaking with MCC legal
counsel, the Government understands that in response to this request, MCC legal counsel looked
up the defendant's cell in the MCC computer system and thereafter requested that MCC staff
preserve video from outside of the cell for the requested time period. An MCC staff member
confirmed that the video had been preserved.
On or about January 3, 2020, the Government obtained a copy of the Requested Video
from the MCC, and converted it into a playable format. After reviewing the video, it appeared to
the Government that the footage contained on the Requested Video was for the correct date and
time, but captured a different tier than the one where Cell-1 was located because the Requested
Video did not show corrections officers responding to any of the cells seen on the video. After
speaking with MCC legal counsel, the Government understands that the MCC computer system
incorrectly listed the defendant's cell for the time period in question ("Cell-2"). Therefore, when
EFTA00026545

=== Page 2 ===
January 8, 2020
Page 2 of 2
MCC legal counsel asked that the video outside of the defendant's cell be preserved, the MCC
preserved video outside of Cell-2 instead of Cell-1.
The Government understands from speaking with MCC legal counsel that the only other
source of video from outside of Cell-1 would be on the DVR system that housed all video for the
Special Housing Unit (the "SHU"). Following the death of Jeffrey Epstein at the MCC on or about
August 10, 2019, the Federal Bureau of Investigation ("FBI") seized the DVR. The Government
understands from speaking with an FBI agent that the FBI seized two DVR systems: one that
captured video from the common area of the SHU, and one that captured the SHU tiers (the "Tier
DVR"), including the tier where Cell-1 is located. The Government further understands that the
FBI has determined that, on or about July 29, 2019, the Tier DVR suffered a system failure. As a
result, the FBI been unable to recover any footage from the Tier DVR, and is unlikely to recover
any video.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorneys
Cc:
Counsel of record (by ECF)
EFTA00026546


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From:
Cc:
)"
)"
,
Subject: Severance opp
Date: Sun, 21 Feb 2021 22:42:32 +0000
Attachments: Severance_draft_v7.docx;Memo_of_Law_ISO_Motion_for_Severance.pdf
Hi
Attached for your review is a draft of the opposition to Maxwell's motion to sever the perjury counts, along with a copy of
that motion.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00026594


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Epstein search warrant documents
Date: Tue, 07 Jul 2020 18:35:08 +0000
Hey thanks - unfortunately the agents don't know anything about this (and definitely don't have a hard drive with 39
devices) so I called and texted
to see what the deal is. Will circle back as soon as I hear back.
From:
Sent: Tuesday, July 07, 2020 14:26
To:
is
Subject: FW: Epstein search warrant documents
I'm in the office today if you want me to go pick anything up.
From:
(USANYS)
Sent: Tuesday, July 7, 2020 1:36 PM
To:
Cc:
is
Subject: RE: Epstein search warrant documents
Did we get the 39 devices that were ready for us as of yesterday?
From:
Sent: Tuesday, July 7, 2020 10:52 AM
To:
(USANYS)
Cc:
is
Subject: RE: Epstein search warrant documents
Exactly - I think that was the number we had at the time we asked for the estimate, which was then slightly revised
(we've gotten different info from the FBI over time). But very easy to update with Tom and I'm sure it wouldn't change
the estimate significantly.
From:
(USANYS)
Sent: Monday, July 06, 2020 08:50
To:
Cc:
is
Subject: RE: Epstein search warrant documents
Just to confirm, this estimate is for everything from both SWs, right? It looks like the attached email contemplates 57
devices, and it sounds like we're just over 60 at this point, but I assume that's an issue we could resolve with Tom pretty
easily if need be?
From:
Sent: Thursday, July 2, 2020 5:11 PM
To:
(USANYS)
Cc:
(USANYS)
is
is
EFTA00024566

=== Page 2 ===
)
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI - they are now well over a month
later than their estimate from April on when we would get the New York materials, they're also past their estimate of
getting us the New York materials from just this Monday, and we don't have anything close to an estimate on the USVI
materials, which constitute the overwhelming majority of the data and are vastly more voluminous than the New York
devices. We have kept pushing the timeline back for this option, hoping that CART will finalize, but I think at this point we
should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-friendly
format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very effective and
efficient, and they get the materials we need. And most importantly, they estimate they can do it all in less than a
month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
From:
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
i
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
V.
)
is
>;
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
(USANYS)
y.
(NY) (FBI)
>;
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
is
in
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
EFTA00024567

=== Page 3 ===
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll be
able to see how many items to export, so we'll have a better sense of when we'll get those?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
in
Cc:
(USANYS)
i
(NY) (FBI)
>;
i
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
i
(NY) (FBI)
i
)
i
)
in
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how many
items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
EFTA00024568

=== Page 4 ===
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI materials?
I
think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and USVI?
thanks,
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
in
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per my
discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as 1 item in
particular has over 500,000 emails. We will be able to provide discovery once Defense Council has provided
drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let you know when
everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could you
please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as early as this
week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything that
was collected (including reproducing the materials that you previously gave us, but which are not searchable), or have you
and
figured out a way to categorize the prior productions so they're useful for us? We would strongly prefer to just
get everything at once in a usable format, but please let us know if you expect to produce materials differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
in
-
Cc:
(USANYS)
is
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
EFTA00024569

=== Page 5 ===
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
is
(USANYS)
in
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what
the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go from
there.
EFTA00024570

=== Page 6 ===
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in searchable
format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to specific devices -
so if we're able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to
get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
>
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
EFTA00024571

=== Page 7 ===
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
is
(USANYS) [Contractor]
Cc:
is
is
EFTA00024572

=== Page 8 ===
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
)
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
is
(USANYS) [Contractor]
EFTA00024573

=== Page 9 ===
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
EFTA00024574

=== Page 10 ===
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
EFTA00024575

=== Page 11 ===
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
BYRNE,
is
>; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
)
>;
(NY) (FBI)
y.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
BYRNE,
is
>; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
BYRNE,
is
>; Young, Amanda N. (NY)
EFTA00024576

=== Page 12 ===
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
BYRNE,
is
>; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
>; BYRNE,
is
>; Young, Amanda N. (NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
EFTA00024577

=== Page 13 ===
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
BYRNE,
is
>; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
BYRNE,
i
>; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
EFTA00024578

=== Page 14 ===
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
>;
(USANYS)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
BYRNE,
is
>; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
EFTA00024579

=== Page 15 ===
Senior Forensic Examiner
(office)
(cell)
From:
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
>;
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
>; BYRNE,
is
>; Young, Amanda N. (NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
in
)
>;
(NY) (FBI)
y.
(USANYS)
Cc:
(USANYS) [Contractor]
>;
is
BYRNE,
V.
>; ; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
is
BYRNE,
is
>; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
EFTA00024580

=== Page 16 ===
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
BYRNE,
i
>; Young, Amanda N. (NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
EFTA00024581

=== Page 17 ===
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
>; Young, Amanda N. (NY) (FBI)
Cc:
(USANYS) [Contractor]
>; BYRNE,
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00024582


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c7: images
c0:
=== Page 1 ===
From:
"
(USANYS) 1"
To:
)"
Subject: RE: Sentencing with Berman
Date: Tue, 05 May 2020 18:48:38 +0000
He is out of control.
From:
Sent: Tuesday, May 5, 2020 12:33 PM
To:
(USANYS) 1
Subject: FW: Sentencing with Berman
From:
Sent: Tuesday, May 05, 2020 12:32
To:
is
Subject: Fwd: Sentencing with Berman
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: May 5, 2020 at 12:26:14 PM EDT
To:
)"
Subject: Sentencing with Berman
Sua sponte talking right now about how he thinks Barr hasn't done a satisfactory investigation about Epstein's death and
BOP generally in the wake of his death.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
EFTA00025481


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein defense bail submission due
Start Date: 2019-07-11 16:00:00 +0000
End Date: 2019-07-11 16:30:00 +0000
Organizer:
)
Location: Berman
Class: X-PERSONAL
Comment:
Date Created: 2019-07-10 05:55:53 +0000
Date Modified: 2019-07-10 05:55:53 +0000
Priority: 5
DTSTAMP: 2019-07-10 05:50:03 +0000
EFTA00026652


c1: EFTA00023750
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023750.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Jack Scarola
Cc:
)"
(USANYS)"
Subject: RE: 12/04/09
VS Epstein Deposition Transcript
Date: Tue, 22 Sep 2020 20:51:53 +0000
Jack,
Thanks for speaking with me earlier today. The attorneys I mentioned are Marc Weinstein and Andrew Tomback, who
represent the executors of Epstein's estate. I've provided them with your contact information, and as we discussed, they
will likely be in touch to discuss whether you have any objections to them providing the transcript to us.
On this subject, I wanted to let you know that our communications with the estate's attorneys about your client have
been limited to our request for the transcript. We have not shared any details regarding your client or her cooperation
with our investigation.
Thank you,
From: Jack Scarola
Sent: Tuesday, September 22, 2020 11:55 AM
To:
Cc:
is
(USANYS)
Subject: Re: 12/04/09
VS Epstein Deposition Transcript
I am available right now.
Sent from my iPad
On Sep 22, 2020, at 11:41 AM,
)
wrote:
Hi Jack,
Do you have a moment for a brief call about this today or tomorrow?
Thanks,
Sent from my iPhone
On Sep 14, 2020, at 2:35 PM, Jack Scarola
wrote:
I am unaware of any protective order relating to the CMA case.
On Sep 14, 2020, at 12:10 PM,
wrote:
EFTA00023750

=== Page 2 ===
Jack,
Are you able to tell us whether there was a protective order entered in the civil suit, or any other type of agreement
that would govern disclosing materials from the civil case with us? When you shared the deposition, we assumed
there were no such restrictions, but I wanted to check.
Thanks,
From: Jack Scarola
Sent: Thursday, September 10, 2020 3:46 PM
To:
Cc:
is
(USANYS)
Subject: Re: 12/04/09
vs Epstein Deposition Transcript
Please let me know if you are able to locate the transcript.
On Sep 10, 2020, at 11:30 AM,
)
wrote:
Jack,
Thanks for your email. We will likely reach out to your adversary in the deposition to ask for a copy, but I wanted to
check to see whether you had already done so.
Thanks,
From: Jack Scarola
Sent: Wednesday, September 9, 2020 9:53 AM
To:
is
V.
(USANYS)
Subject: Fwd: 12/04/09
vs Epstein Deposition Transcript
The email exchange below confirms our inability to locate the first volume of
deposition. However, attached
are fairly detailed notes of Paralegal/Investigator Mike Danchuk, who attended the deposition and recorded these
notes contemporaneously.
appears to have held nothing back, and the notes certainly paint a picture of the
kind of troubled young women who were particularly susceptible to Epstein's pattern of recruitment, grooming and
victimization.
Sent from my iPad
Begin forwarded message:
From: "Chris R. Rodgers"
Date: September 8, 2020 at 3:30:51 PM EDT
To: Jack Scarola
Cc: Mary McCann
>, "Wendy P. Calvet"
"cmavsepsteinetalz6385257@projects.filevine.com" cmavsepsteinetalz6385257@projects.filevine.com
Subject: FW: 12/04/09
- vs Epstein Deposition Transcript
EFTA00023751

=== Page 3 ===
Jack, below is the "Unable to locate" response from Prose Court Reporting. Visual Evidence, the
videography service used, also confirmed on Friday that a copy of the video is no longer available. I have
attached Mike Danchuk's notes from that deposition.
From: toni proseflorida.com
Sent: September 7, 2020 7:03 AM
To: Chris R. Rodgers
Subject: RE: 12/04/09
vs Epstein Deposition Transcript
Chris,
I have searched our records and archives and I am unable to locate Volume I of this deposition from
2009.
Sincerely,
Toni
** I Privileged and Confidential I Electronic communication is not a secure mode of communication and may
be accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney
Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18
U.S.C. S2510-2521. The information contained in this E-mail message is privileged and confidential under
Fla. R. Jud. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the
reader of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution, or copy of this communication is strictly prohibited. Personal messages express views solely of
the sender and shall not be attributed to the law firm. If you received this communication in error, please
notify the sender immediately by e-mail or by telephone at (800) 780-8607 and destroy all copies of the
original message. Thank you.
**
EFTA00023752


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=== Page 1 ===
Event: Accepted: Epstein Call
Start Date: 2020-05-22 17:00:00 +0000
End Date: 2020-05-22 18:00:00 +0000
Location: 877-720-9282 - 8146826
Class: X-PERSONAL
Comment:
Date Created: 2020-05-21 14:04:21 +0000
Date Modified: 2020-05-21 14:04:21 +0000
Priority: 5
DTSTAMP: 2020-05-21 13:36:13 +0000
Attendee:
EFTA00026537


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c0:
=== Page 1 ===
From:
To:
Subject: 2020-04-28, Maxwell, draft indictment.docx
Date: Wed, 29 Apr 2020 16:06:08 +0000
Attachments: 2020-04-28,_Maxwell_draft_indictment.docx
See what you think of this, and then let's chat??
EFTA00025354


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c0:
=== Page 1 ===
From:
"
)"
To:
"
(NY) (FBI)"
Cc:
"
(
)"
)"
,
)"
Subject:
Date: Tue, 31 Dec 2019 15:02:26 +0000
Attachments:
pdf
Hi
Attached is the deposition transcript for
It's Rule 6(e) material. If this doesn't end up satisfying the
criteria for victim services, please let us know and we'll sort something out.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00024514


c1: EFTA00026620
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026620.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: quick Epstein update?
Date: Wed, 03 Apr 2019 15:26:02 +0000
Importance: Normal
Yup
Sent from my iPhone
On Apr 3, 2019, at 11:25 AM,
wrote:
Works for me if that's good for
From:
Sent: Wednesday, April 03, 2019 11:17
To:
is
Subject: RE: quick Epstein update?
Just finishing up a SW. Would 11:30 work?
From:
Sent: Wednesday, April 3, 2019 11:16 AM
To:
is
Subject: quick Epstein update?
Could I grab you guys for just 5-10 minutes on Epstein sometime today? I'm free now until noon, and then in and out of
proffers / meetings but generally around. No emergency at all just want to run a few things by you.
Assistant U.S. Attorney
Southern District of New York
EFTA00026620


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024175.pdf
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c0:
=== Page 1 ===
Exhibit B
EFTA00024175

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Check for updates
Review Manuscript
TRAUMA, VIOLENCE & ABUSE
2019, Vol. 20(2) 260-283
Facilitators and Barriers to Child Sexual
© The Author(s) 2017
oe
Abuse (CSA) Disclosures: A Research
Article reuse guidelines:
sagepub.com/journals-permissions
Update (2000-2016)
DOI: 10.1177/1524838017697312
journals.sagepub.com/home/tva
SAGE
Ramona Alaggia', Delphine Collin-Vézina², and Rusan Lateef'
Abstract
Identifying and understanding factors that promote or inhibit child sexual abuse (CSA) disclosures has the potential to facilitate
earlier disclosures, assist survivors to receive services without delay, and prevent further sexual victimization. Timely access to
therapeutic services can mitigate risk to the mental health of survivors of all ages. This review of the research focuses on CSA
disclosures with children, youth, and adults across the life course. Using Kiteley and Stogdon's literature review framework, 33
studies since 2000 were identified and analyzed to extrapolate the most convincing findings to be considered for practice and
future research. The centering question asked: What is the state of CSA disclosure research and what can be learned to apply to
practice and future research? Using Braun and Clarke's guidelines for thematic analysis, five themes emerged: (I) Disclosure is an
iterative, interactive process rather than a discrete event best done within a relational context; (2) contemporary disclosure
models reflect a social-ecological, person-in-environment orientation for understanding the complex interplay of individual,
familial, contextual, and cultural factors involved in CSA disclosure; (3) age and gender significantly influence disclosure; (4) there
is a lack of a life-course perspective; and (5) barriers to disclosure continue to outweigh facilitators. Although solid strides have
been made in understanding CSA disclosures, the current state of knowledge does not fully capture a cohesive picture of dis-
closure processes and pathways over the life course. More research is needed on environmental, contextual, and cultural factors.
Barriers continue to be identified more frequently than facilitators, although dialogical forums are emerging as important facil-
itators of CSA disclosure. Implications for practice in facilitating CSA disclosures are discussed with recommendations for future
research.
Keywords
sexual abuse, child abuse, cultural contexts
Introduction
the same time global trends from systematic reviews and meta-
analyses have found concerning rates of CSA, with averages of
Timely access to supportive and therapeutic resources for child
18-20% for females and of 8-10% for males (Pereda, Guilera,
sexual abuse (CSA) survivors can mitigate risk to the health
Forns, & Gómez-Benito, 2009). The highest rates found for
and mental health well-being of children, youth, and adults.
girls is in Australia (21.5%) and for boys in Africa (19.3%),
Identifying and understanding factors that promote or inhibit
with the lowest rates for both girls (11.3%) and boys (4.1%)
CSA disclosures have the potential to facilitate earlier disclo-
reported in Asia (Stoltenborgh, van IJzendoorn, Euser, &
sures, assist survivors to receive services without delay, and
Bakermans-Kranenburg, 2011). These findings point to the
potentially prevent further sexual victimization. Increased
incongruence between the low number of official reports of
knowledge on both the factors and the processes involved in
CSA disclosures is timely when research continues to show
high rates of delayed disclosures (Collin-Vézina, Sablonni,
Palmer, & Milne, 2015; Crisma, Bascelli, Paci, & Romito,
Factor-Inwentash Faculty of Social Work, University of Toronto, Toronto,
Ontario, Canada
2004; Easton, 2013; Goodman-Brown, Edelstein, Goodman,
2 Centre for Research on Children and Families, School of Social Work, McGill
Jones, & Gordon, 2003; Hershkowitz, Lanes, & Lamb; 2007;
University, Montreal, Qubec, Canada
Jonzon & Lindblad, 2004; McElvaney, 2015; Smith et al.,
2000).
Corresponding Author:
Incidence studies in the United States and Canada report
Ramona Alaggia, Factor-Inwentash Chair in Children's Mental Health, Factor-
Inwentash Faculty of Social Work, University of Toronto, 246 Bloor St. West,
decreasing CSA rates (Fallon et al., 2015; Finkelhor, Shattuck,
Toronto, Ontario, Canada M4KIWI.
Turner, & Hamby, 2014; Trocmé et al., 2005, 2008), while at
Email: ramona.alaggia@utoronto.ca
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Alaggia et al.
261
CSA to authorities and the high rates reported in prevalence
disclosure research, through various mixed methods, to high-
studies. For example, a meta-analysis conducted by Stolten-
light the most convincing findings that should be considered for
borgh, van IJzendoorn, Euser, and Bakermans-Kranenburg
future research, practice, and program planning. This review
(2011) combining estimations of CSA in 217 studies published
centered on the question: What is the state of CSA disclosure
between 1980 and 2008 revealed rates of CSA to be more than
research and what can be learned to apply to future research
30 times greater in studies relying on self-reports (127 in 1,000)
and practice? By way of clarification, the term systematic
than in official report inquiries, such as those based on data
refers to a methodologically sound strategy for searching liter-
from child protection services and the police (4 in 1,000) (Jil-
ature on studies for knowledge construction, in this case the
lian, Cotter, & Perreault, 2014; Statistics Canada 2013). In
CSA disclosure literature, rather than intervention studies. The
other words, while 1 out of 8 people retrospectively report
years spanned for searching the literature were 2000-2016,
having experienced CSA, official incidence estimates indicate
building on previous reviews without a great deal of overlap.
only I per 250 children. In a survey of Swiss child services,
Retrieval of relevant research was done by searching interna-
Maier, Mohler-Kuo, Landholt, Schnyder, and Jud (2013) fur-
tional electronic databases: PsycINFO, PsycARTICLES, Edu-
ther found 2.68 cases per 1,000 of CSA disclosures, while in a
cational Resources Information Center, Canadian Research
recent comprehensive review McElvaney (2015) details the
Index, International Bibliography of the Social Sciences, Pub-
high prevalence of delayed, partial, and nondisclosures in
lished International Literature on Traumatic Stress, Sociologi-
childhood indicating a persistent trend toward withholding
cal Abstracts, Social Service Abstracts, and Applied Social
CSA disclosure.
Science Index and Abstracts. This review searched peer-
It is our view that incidence statistics are likely an under-
reviewed studies. A search of the gray literature (unpublished
estimation of CSA disclosures, and this drives the rationale for
literature such as internal agency documents, government
the current review. Given the persistence of delayed disclosures
reports, etc.) was beyond the scope of this review because
with research showing a large number of survivors only dis-
unpublished studies are not subjected to a peer-review process.
closing in adulthood (Collin-Vézina et al., 2015; Easton, 2013;
Keyword search terms used were child sexual abuse, childhood
Hunter, 2011; McElvaney, 2015; Smith et al., 2000), these
sexual abuse, disclosure, and telling.
issues should be a concern for practitioners, policy makers, and
A search of the 9 databases produced 322 peer-reviewed
the general public (McElvaney, 2015). The longer disclosures
articles. Selected search terms yielded 200 English publica-
are delayed, the longer individuals potentially live with serious
tions, 1 French study, and 1 Portuguese review. The search was
negative effects and mental health problems such as depres-
further refined by excluding studies focusing on forensic inves-
sion, anxiety, trauma disorders, and addictions, without receiv-
tigations, as these studies constitute a specialized legal focus on
ing necessary treatment. This also increases the likelihood of
interview approaches and techniques. As well, papers that
more victims falling prey to undetected offenders. Learning
focused exclusively on rates and responses to CSA disclosure
more about CSA disclosure factors and processes to help
were excluded, as these are substantial areas unto themselves,
advance our knowledge base may help professionals to facil-
exceeding the aims of the review question. Review articles
itate earlier disclosures.
were also excluded. Once the exclusion criteria were applied,
Previous literature reviews examining factors influencing
the search results yielded 33 articles. These studies were sub-
CSA disclosure have served the field well but are no longer
jected to a thematic analysis as described by Braun and Clarke
current. Important contributions on CSA disclosures include
(2006). This entailed (1) multiple readings by the three authors;
Paine and Hansen's (2002) original review covering the liter-
(2) identifying patterns across studies by coding and charting
ature largely from the premillennium era, followed by London,
specific features; (3) examining disclosure definitions used,
Bruck, Ceci, and Shuman's (2005) subsequent review, which
sample characteristics, and measures utilized; and (4) major
may not have captured publications affected by "lag to print"
findings were extrapolated. Reading of the articles was initially
delays so common in peer-reviewed journals. These reviews
conducted by the authors to identify general trends in a first
are now dated and therefore do not take into account the
level of analyses and then subsequently to identify themes
plethora of research that has been accumulated over the past
through a deeper second-level analyses. A table of studies was
15 years. Other recent reviews exist but with distinct contribu-
generated and was continuously revised as the selection of
tions on the dialogical relational processes of disclosure (Reit-
studies was refined (see Table 1).
sema & Grietens, 2015), CSA disclosures in adulthood (Tener
& Murphy, 2015), and delayed disclosures in childhood (McEl-
vaney, 2015). This literature review differs by focusing on CSA
Key Findings
disclosures in children, youth, and adults from childhood and
First-level analysis of the studies identified key study charac-
into adulthood-over the life course.
teristics. Trends emerged around definitions of CSA disclosure,
study designs, and sampling issues. First, in regard to defini-
tions, the term "telling" is most frequently used in place of the
Method
term disclosure. In the absence of standardized questionnaires
Kiteley and Stogdon's (2014) systematic review framework
or disclosure instruments, telling emerges as a practical term
was utilized to establish what has been investigated in CSA
more readily understood by study participants. Several
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262
Table I. Ch di Sexua Abuse (CSA) D SC osure Stud es: 2000-2016.
Study
Purpose
Des gn
Samp e
Fnd ngs
Summary
Gagn er and Co n-
To exp ore di SC osure
Phenomeno og ca
17 men ranged n age
The major ty of the men n the study wa ted
A part C pants had SC osed and
Véz na (2016)
processes for ma e
methodo ogy used to
from 19 to 67-
unt adu thood to di SC ose the r abuse,
rece ved serv ces before
ct ms of CSA
nterv ew ma e CSA
average age 47.
W th negat ve stereotypes contr but ng
part C pat n the study. Member
surv vors. The Long
Purpos ve samp ng
to the r de ayed di SC osures. Negat ve
check ng cou di not be done W th
Interv ew Method
strategy was used
stereotypes contr buted to de ayed
the part C pants to check themes.
(LIM) gu ded data
di SC osure W th try ng to forget. Break ng
Sma but suff C ent S ze for a
CO ect on and
so at on was C ted as a mot vator to
qua tat ve nqu ry. Otherw se,
ana yses.
di SC osure a ong W th the a di of var ous
h gh eve of r gor n estab sh ng
forms of med a on di SC osure. Important
trustworth ness of the data and
contextua ssues such as negat ve
ana ys S. Retrospect ve study
stereotyp ng of ma es, sexua ty, and
cou di mp y reca ssues
ms were noted. Soc a med a was
seen as a fac tator of di SC osures
Braze ton (2015)
To exp ore the mean ng
Co ect ve case study
17 Afr can Amer can
CSA onset was arge y between the ages 5
One of few stud es to focus
Afr can Amer can
des gn W th us ng
women n m d- fe
and 9. No one ever ta ked to them about
exc us ve y on Afr can Amer can
women make of the r
narrat ve trad t on
between 40 and 63
sex, so they di dn't have anguage to
women. Sma but suff C ent $ ze
traumat C exper ences
(storyboard) for data
who exper enced
SC ose. Barr ers: fear of fam y
for a qua tat ve nqu ry. Important
w th CSA and how
CO ect on and ana ys S.
ntrafam a CSA.
breakdown and remova, not want ng to
cu tura and contextua ssues
they di SC osed across
Qua tat ve
Purpos ve, snowba ng
tarn sh the fam y's name, and fear of
were brought forward.
the fe course
nterv ew ng
strategy
retr but on by fam y members f they
Retrospect ve study that may
SC osed. Pattern of st f ed and
have been affected by reca ssues.
di sm ssed di SC osures dent f ed over the
Use of a fe-course perspect ve as
fe course. A 17 part C pants dent f ed
a theoret ca ens for
sp r tua ty as a pr mary source of
understand ng CSA n the m dd e
strength throughout the fe course
to ater years of fe that shou di be
cons dered n further
nvest gat ons
Co n-Véz na, Sab onn,
To prov de a mapp ng of
Qua tat ve des gn us ng
67 ma e and fema e CSA
Three broad categor es were dent f ed as
Ha f of the part C pants had not
mer, and M ne
factors that prevent
LIM.
adu t surv vors (76%
barr ers to CSA di SC osure: Barr ers
di SC osed the r CSA exper ences
(2015)
CSA di SC osures
dent f ed as fema e and
from W nterna zed V ct m b am ng.
before the age of 19.
through an eco og ca
24% as ma e). Age
mechan sms to protect onese f, and
Retrospect ve aspect of the study
ens from a samp e of
ranges from 19 to 69
mmature deve opment at t me of abuse;
cou di mp y reca ssues. A
CSA adu t surv vors.
years (M = 44.9).
barr ers n re at on to others-v O ence
part C pants had di SC osed and
Purpos ve samp ng
and dysfunct on n the fam y. power
rece ved counse ng at some
strategy
dynam CS, awareness of the mpact of
before part C pat ng n the study.
te ng. and frag e SOC a network;
H gh eve of r gor n estab sh ng
barr ers n re at on to the SOC a wor di
trustworth ness of the data and
abe ng, taboo of sexua ty, ack of
ana ys
serv ces ava ab e, and cu ture or t me
per od.
Lec erc and Wort ey
Study object ves
Adu t ma e ch di sexua
369 adu t ma es who had
D SC osure ncreased w th the age of the
Offender generated data through
(2015)
nvest gated the
offenders were
been conv cted of a
V m: f penetrat on had occurred, f the
se f-reports cou di be subject to
factors that fac tate
nterv ewed to
sexua offense aga nst a
V ctm was re ated to the offender, f the
cogn t ve di stort ons-
EFTA00024178
CSA di SC osures
exam ne pred ctors of
ch di aged between I
was not ng W th the offender at
m zat on or exaggerat ons.
(continued)

=== Page 5 ===
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
Fndings
Summary
vctm SC osure.
and 17 years O d.
the tme of the abuse, or f the vctm
Perspect ves of offenders on
Sem structured
Major ty were Wh te,
res sted dur ng the offense. Ma e
nerab ty of n at on
nterv ews based on
uneducated, a most
and V ct ms from dysfunct ona
to SC osure cou di be important
the QID
ha f unemp oyed
backgrounds were ess ke y to di SC ose
nformat on to nform
quest onna re.
before the r arrest
intervent ons
McE vaney and Cu hane
To nvest gate the
F e reports of ch dren
Content ana ys S was
Major ty of ch dren to di the r mothers
The samp e ze S sma but W
(2015)
feas b ty of us ng ch di
seen for assessment n
comp eted on 39 f es
(43%) and peers (33%) rst. Three major
contr bute to a arge mu te
assessments as data
a ch di sexua abuse
(32 fema es and 7
themes were dent f ed as nf uenc ng the
study n Ire and. Serves as an
sources of nforma
un t n a ch dren's
ma es) based on a
di SC osure process: (I) fee ng di stressed,
important exp oratory P ot
CSA di SC osure. To
hosp ta were
cod ng framework.
(2) opportun ty to te. and (3) fears for
br ng ng forward di SC osure
assess f these reports
rev ewed
Parents were asked to
se f. Add t ona themes of be ng be eved,
themes for cons derat on
prov de substant ve
consent to have the r
shame/se f-b ame, and peer nf uence
data on di SC osures
ch d's f e rev ewed for
were a so dent f ed
the study. V ms
assessed were 12-18
years of age
Dumont, Messerschm tt,
Th $ study a med to
F e reports of ch dren
220 m nor V ct ms-
D SC osure processes were more comp ex
The re at onsh P th the
V a, Bohu, and
exp ore how the
seen for assessment n
78.2% fema e ms.
when t concerned sexua abuse
perpetrator has a $ gn cant
Rey-Sa mon (2014)
re at onsh P between
a ch di sexua abuse
41.8% aged between
comm tted by ntrafam a perpetrator:
mpact on both t m ng and
the perpetrator and
un t n a ch dren's
14 and 18 (most
60% of the V ct ms revea the facts
rec P ent of di SC osure, W th
the m, espec a y
hosp ta were
preva ent age range),
severa years after, and most often to
ntrafam a abuses ess ke y to
whether these
rev ewed
and 48.2% were
nd V dua $ outs de the fam y (78.6% of
be di SC osed prompt y and W th n
re at ons are
abused by a fam y
the di SC osures done at schoo ): on the
the fam y system
ntrafam a or
member
contrary, extrafam a di SC osures take
extrafam a, mpact
ace more spontaneous y and qu ck
CSA di SC osure
80% of the V ct ms revea the facts a few
days after, most often to the r mother or
peers
Easton, Sa tzman, and
Study focus was on
Us ng qua tat ve content
460 men W th CSA
Vast major ty of part C pants (94.6%) were
At tme of the study, th S was the
W S (2014)
dent cat on of
ana ys s, researchers
h stor es comp eted an
sexua y abused by another ma e.
argest qua tat ve data set to have
barr ers to CSA
conducted a secondary
anonymous, Internet-
Durat on of sexua abuse broke down
been ana yzed W th an exp ct
di SC osure W th ma e
ana ys $ of on ne
based survey.
nto: 30.2% ess than 6 months, 32.3% 6
focus on adu t ma e surv vors'
surv vors
survey data, the 2010
Recru ted from
months to 3 years, and 34.3% more than
percept ons of barr ers to CSA
Hea th and We -Be ng
surv vors'
3 years. Ten years o di was average age of
di SC osure. Because the samp e
Survey, that nc uded
organ zat ons. Age
CSA onset. Ten categor es of barr ers
was m ted n terms of the ow
men W th se f-reported
range of 18-84 years.
were ass fed nto three doma ns: (I)
percentage of rac a m nor t es
CSA h stor es w th an
Two th rds of
SOC opo t ca: mascu n ty, m ted
(9.3%), di SC osure di fferences
open-ended tem on
respondents reported
resources; (2) interpersona m strust of
based on race or ethn C ty were
di SC osure barr ers
C ergy-re ated abuse.
others, fear of be ng abe ed "gay," safety
not di scerned. The major ty of
Major ty of
and protect on ssues, past responses;
abuse reported was by C ergy
respondents were
and (3) persona: nterna emot ons,
wh ch m ght present a un que set
Wh te
see ng the exper ence as sexua abuse,
of barr ers to di SC osure
and sexua or entat on.
EFTA00024179
263
(continued)

=== Page 6 ===
264
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
nd ngs
Summary
Easton (2013)
Study purpose was to
Cross-sect ona survey
Purpos ve samp ng of
O der age and be ng abused by a fam y
Purpos ve samp ng of men from
descr be ma e CSA
des gn. E g b e
487 men from three
member were both re ated to de ays n
awareness ra $ ng organ zat ons
di SC osure processes
part C pants were
nat ona organ zat ons
di SC osure. Most part C pants who to di
may have attracted part cu ar
us ng a fe span
screened and
devoted to ra S ng
someone dur ng ch dhood di d not
part C pants who had a ready
approach exam n ng
comp eted an
awareness of CSA
rece ve emot ona y support ve or
di SC osed and rece ved he P.
di fferences based on
anonymous, Internet-
among men. Age
protect ve responses and the he pfu ness
Part C pants needed to have
age. A so, to exp ore
based survey dur ng
range: 19-84 years.
of responses across the fe span was
access to Internet wh ch wou di
re at onsh ps between
2010. Measures used:
Mean age for onset of
m xed. De ays n te ng were S gn f cant
have e m nated men n ower SES
di SC osure attr butes
Genera Menta Hea th
CSA was 10.3 years
per ods of tme (over 20 years).
groups and requ red prof C ency n
and men's menta
D stress Sca e and
Approx mate y one ha f of the
Eng sh wh ch wou di e m nate
hea th
Genera Assessment of
part C pants f rst to di about the sexua
certa n cu tura groups. However,
Ind V dua Needs.
abuse to a spouse/partner (27%) or a
the samp ng strategy ga ned
Quest ons re ated to
menta hea th profess ona (20%); 42% of
access to a predom nant y h dden
CSA di SC osure and
part C pants reported that the r most
popu at on. Important C n ca
supports were
he pfu di scuss on was W th a menta
recommendat ons are made W th
nc uded
hea th profess ona. However, unhe pfu
an emphas on a fe-course focus
responses caused most menta di stress.
C n ca recommendat ons nc uded
more of a fe-course perspect ve be
adopted, understand ng mpact of
unhe pfu responses and the importance
of expand ng networks for ma e
surv vors
McE vaney, Greene, and
Qua tat ve study asked
Grounded theory
Samp e of 22 young
A theoret ca mode was deve oped that
Modest but suff C ent samp e for an
Hogan (2012)
the centra research
method study.
peop e; 16 g r $ and 6
conceptua zes the process of CSA
exp oratory qua tat ve nqu ry.
quest on: "How do
Interv ews were
boys; age range: 8-18
di SC osure as one of conta n ng the
H gh eve of trustworth ness
ch dren te ?"
conducted. L ne-by-
years; 22 nterv ewed
secret: (I) the act ve W thho di ng of the
r gor. A subsamp e of random y
Object ve was to
ne open and ax a
n tota between the
secret on the part of the ch d; (2) the
se ected transcr pts was
deve op theory of how
cod ng was conducted
ages of 8 and 18. M xed
exper ence of a "pressure cooker effect"
ndependent y coded. Very young
ch dren te of the r
on verbat m
samp e of some
ref ect ng a conf ct between the W sh to
ch dren and young adu ts were
CSA di SC osure
transcr pts
endur ng ntrafam a
te and the W sh to keep the secret; and
not captured n th $ samp e.
exper ences. Parents
CSA, some
(3) the conf di ng tse f wh ch often
Transferab ty of nd ngs can on y
were nterv ewed.
extrafam a CSA, and
occurs n the context of a trusted
be made to the age range samp ed
two endured both
re at onsh P. These were der ved from
n the context of Ire and
forms
e even categor es that were deve oped
through open and ax a cod ng
Schonbucher, Ma er,
To nvest gate the
Data CO ect on was
Conven ence samp e of
Less than one th rd of part C pants
Two th rds of the samp e dd not
Moh er-Kuo, Schnyder,
process of CSA
through face-to-face
26 sexua y V ct m zed
mmed ate y di SC osed CSA to another
di SC ose r ght away. Strengthen ng
and Lando t (2012)
di SC osure W th
qua tat ve nterv ews.
ado escents. 23 gr
person. In most cases, rec P ents of both
parent-ch di re at onsh ps may be
ado escents from the
Standard zed quest ons
and 3 boys. Age range:
mmed ate and de ayed di SC osure were
one of the most important ways
genera popu at on
and measures were
15-18 years. On ne
to peers. More than one th rd of
to ncrease di SC osure to parents.
who had exper enced
adm n stered on fam y
advert sements and
part C pants had never di SC osed the
D SC osure to peers has been
CSA. How many
S tuat on,
f yers were used to
abuse to a parent. Part C pants reported
found a common trend n other
EFTA00024180
di SC osed, who di di
SOC odemograph C
recru t youth from
re uctance to di SC ose to parents so as
(continued)

=== Page 7 ===
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
nd ngs
Summary
they di SC ose to, and
data, sexua
commun ty and
not to burden them. Ear er SC osures
research and bears more
what were the r
V ct m zat on, genera,
counse ng serv ces
were re ated to extrafam a CSA, S ng
exam nat on
mot ves for di SC os ng
and menta hea th.
occurrence CSA, age of V ct at abuse
Sexua Assaut Modu e
onset, and parents who were ng
of the Juven e
together. H gher eve S of reported gu t
V ct m zat on
and shame were re ated to de ayed
Quest onna re was
di SC osures. Peers were V ewed by th S
used
samp e as more re ab e conf dants
Hunter (2011)
A m of th study was to
Narrat ve nqu
Purpos ve samp ng was
On y 5 out of 22 part C pants to di anyone
De ayed di SC osure was common n
deve op a fu er
methodo ogy. Face-to-
emp oyed. Samp e
about the r ear y sexua exper ences as
th S qua tat ve samp e. Most
understand ng of CSA
face n-depth
cons sted of 22
ch dren. Fear, shame, and se f-b ame
part C pants di di not make a
di SC osures
nterv ews were
part C pants aged 25-
were the ma n. nh b tors to SC osure.
se ect ve di SC osure unt
conducted W th
70 years; 13 women
These factors are further deta ed
adu thood. These nd ngs support
part C pants. Data
and 9 men. Part C pants
through subthemes. Te ng as a ch di and
Aagga's (2004) mode of
were ana yzed us ng
were sexua y abused
as an adu t was further expanded upon
di SC osure but a so h gh ghts the
Rosentha and F scher-
at 15 years or under
us ng A agg a's (2004) framework
importance of fe stage. Modest
Rosentha's (2004)
w th someone over
ver fy ng behav ora nd rect attempts to
but suff C ent samp e $ ze for a
method.
the age of 18.
te and purposefu di SC osure as
qua tat ve nqu ry. We -des gned
categor es. Themat C ana ys S supported
study W th deta ed ana ys $ for
that CSA di SC osure shou di be
transferab ty of nd ngs
conceptua zed and V ewed as a comp ex
and fe ong process
Schaeffer, Leventha, and
Th study a med to: (I)
Study sought to nd out f
191
nterv
ews
of
CSA
Reasons the ch dren dent ed for te ng
An nnovat ve study to try to assess
Asnes (2011)
add di rect nqu
process ssues of
V ct ms aged 3-18 over
were C ass ed nto three doma ns: (I)
f forma nvest gat ve nterv ews
about the process of a
di SC osure cou di be
a I-year per od were
di SC osure as a resu t of nterna st mu
can fac tate di SC osures of CSA.
ch d's CSA di SC osure;
dent ed n the
used for the study.
(e.g., the ch di had n ghtmares): (2)
Data were based on a arge
(2) determ ne f
context of forens C
Inc us on cr ter a
di SC osure fac tated by outs de
number of nterv ews. Deta ed
ch dren W di scuss
nterv ews. Forens C
nc uded ch dren who
nf uences (e.g., the ch di was
ana ys S produced deta ed
process that ed them
nterv ewers were
made a statement
quest oned); and (3) di SC osure due to
nd ngs support ng other study
to te and (3) descr be
asked to ncorporate
about CSA pr or to
di rect ev dence of abuse (e.g., the ch d's
f nd ngs on CSA di SC osure
factors that ch dren
quest ons about
referra, reasons for
abuse was W tnessed). The barr ers to
dent that ed them
"te ng" nto an
te ng or wa t ng to
di SC osure dent f ed fe nto f ve groups:
to te about or caused
ex st ng forens C
te, and those who
(I) threats made by the perpetrator
them to de ay CSA
nterv ew protoco.
spoke Eng sh.
(e.g., the ch di was to di she or he wou di
di SC osure
Interv ew content
Part C pants were
get n troub e f she or he to d), (2) fears
re ated to the
ch dren who were
(e.g., the ch di was afra di someth ng bad
ch dren's reasons for
nterv ewed at a ch di
wou di happen f she or he to d), (3) ack
te ng or wa t ng was
sexua abuse C
of opportun ty (e.g., the ch di fe t the
extracted, transcr bed,
74% were fema e and
opportun ty to di SC ose never
and ana yzed us ng
51% were Caucas an
presented), (4) ack of understand ng
grounded theory
(e.g., the ch di fa ed to recogn ze abus ve
method of ana ys S
behav or as unacceptab e), and (5)
re at onsh P w th the perpetrator (e.g.,
the ch di thought the perpetrator was a
EFTA00024181
fr end)
265
(continued)

=== Page 8 ===
266
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
nd ngs
Summary
A agg a (2010)
The study a med to
A qua tat ve
Purpos ve samp ng was
Themes fe nto four doma ns: (I)
The study presents a comprehens ve
dent fy factors
phenomeno og ca
emp oyed. Snowba
nd V dua and deve opmenta factors,
SOC a -eco og ca ana ys $ to CSA
mped ng or promot ng
des gn, LIM, was used
samp ng was a so used
deve opmenta factors as to whether
di SC osure h gh ght ng the
CSA di SC osures.
to nterv ew adu t CSA
to recru t more ma e
they comprehended what was
mu t faceted nf uences. Of note,
Overarch ng research
surv vors about the r
surv vors. 40 adu t
happen ng, persona ty tra ts a so had
42% had SC osed the abuse
quest on: What
di SC osure exper ences
surv vors of CSA were
some bear ng on the r ab ty to te and
dur ng ch dhood; 26% had not
nd V dua,
to prov de
nterv ewed: 36% men
ant C pat ng not be ng be eved; (2)
di SC osed because they had
interpersona,
retrospect ve accounts
and 64% women. Age
di SC osure nh b ted by fam y
repressed the memory, or the
env ronmenta, and
of CSA di SC osure and
range of 18-65 W th a
character st CS such as rg di y xed
abuse had occurred n preschoo
contextua nf uences
mean ng-mak ng of
mean age of 40.1 years.
gender ro es w th dom nat ng fathers,
years and they had di ff cu ty W th
mpede or promote
these exper ences.
Average age of abuse
chaos and aggress on, other forms of
reca . The rema nder had
CSA di SC osures.
Themat C ana ys $ was
onset was 5.3 years
ch di abuse, domest C V O ence,
attempted some form of
done through a SOC
O d. 36% of the samp e
dysfunct ona commun cat on, and SOC a
di SC osure n nd rect ways dur ng
eco og ca ens.
was non-Wh te.
so at on; (3) ne ghborhood and
ch dhood. A retrospect ve
D verse
commun ty context, that S, ack of
approach that cou di be affected by
SOC oeconom C
nterest from ne ghbors and teachers not
reca ssues
backgrounds
pursu ng troub ng behav or; and (4)
cu tura and SOC eta att tudes, med a
messages and SOC eta att tudes, fee ng
unheard as k ds, gender SOC a zat on for
ma es, and cu tura att tudes nf uenc ng
parent's react ons. Purposefu di SC osure
$ h gher than reported n other stud es
because of the samp ng attempts to
purposefu y ocate di SC osers
Fontes and Pummer
Th S exam nat on of CSA
Us pub shed terature
Data cons sted of
Cu tura and structura factors affect ng
One of the few works that adds
(2010)
SC osure exp ored
w th C n ca data, th $
pub shed terature on
CSA di SC osure are dent ed n n-depth
know edge to cu tura y
the ways cu ture
art C e conducted an
d SC osure and cu ture
deta. Recommendat ons made nc ude
contextua di SC osure
affects processes of
ana ys S to prov de a
that was tr angu ated
(I) di SC osure nterv ew ng shou di be
nterv ew ng. Un que comb nat on
CSA di SC osure and
cu tura y competent
w th C n ca case
ta ored to the ch d's cu tura context,
of terature nd ngs W th C n ca
report ng. both n the
framework for CSA
mater a
(2) quest on ng shou di a so take nto
mater a. Anecdota accounts may
Un ted States and
di SC osure quest on ng
cons derat on age and gender factors,
prec ude transferab ty of
nternat ona y
and (3) cu ture stands as an important
nd ngs. Overa adds to an
factor n a cases n wh ch ch dren are
mpover shed area of CSA
cons der ng di SC os ng or be ng asked to
di SC osure nformat on
di SC ose, and not so n cases n wh ch
ch dren are from not ceab e m nor ty
groups. Presents a comprehens ve
nterv ew framework integrat ng cu tura
cons derat ons
Ungar, Barter,
Th S study exp ored
Forms were comp eted
Exam nat on of resu ts
Youth who have been abused or W tnesses
Th $ study h gh ghts that di SC osure
McConne Tutty, and
di SC osure strateg es
by youth fo ow ng
from a nat ona samp e
to abuse emp oy ve di SC osure
$ an nteract ve ongo ng process.
Fa rho m. (2009a)
w th a nat ona samp e
part C pat on n abuse
of 1,621 eva uat on
strateg es: us ng se f-harm ng behav ors
F nd ngs end support to stud es
EFTA00024182
of youth focus ng on
prevent on
forms where youth
to $ gna the abuse to others; not ta k ng
that have dent ed S m ar y
(continued)

=== Page 9 ===
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
Fnd ngs
Summary
(I) What are the
programm ng by the
anonymous y di SC osed
at a about the abuse to prevent
nteract ve mode of di SC osure
h dden exper ences of
Canad an Red Cross
abuse exper ences.
ntrus ve intervent ons by others;
such as those deta ed by A agg a
abuse among Canad an
(RespectED).
Respondent's ages: 13
seek ng he P from peers; seek ng he P
(2004) and Sta er and Ne son-
youth? (2) What
A ser es of focus groups
and under (27%), 14-
from nforma adu t supports; and
Garde (2005). Th S m xed samp e
mpact does
and observat ons of
15 (37%), 16-17 (25%),
seek ng he P from mandated serv ce
of youth who exper enced
part C pat on n abuse
the workshops were
18 and O der (4%), and
prov ders (soc a workers and po ce).
di fferent forms of abuse and
prevent on programs
used to he P
unknown (7%)
Resu ts suggest di SC osure S an
VO ence exposure were
have on youth to
contextua ze the
interact ve process, W th expectat ons
part C pants-not m ted to CSA
express the r abuse
fnd ngs. Eva uat on
regard ng consequences to di SC osure.
surv vors
exper ences? (3) What
forms were ana yzed
Patterns of incrementa y shar ng abuse
di SC osure barr ers do
from two V O ence
exper ences are shaped by young
youth face? (4) What
prevent on programs:
peop e's interact ons W th peers,
are young peop e's
(I) It's not your fau t
educators, and careg vers. About three-
di SC osure patterns?
and (2) What's ove
quarters of fema es prev ous y di SC osed;
and (5) Who do they
got to do W th It?
S gn cant y ess ma es di SC osed
te ?
Ungar, Tutty, McConne
Th S study exp ored
Exp oratory des gn W a
Purposefu samp e of
F nd ngs suggest h gh rates of h dden abuse,
Innovat ve des gn of th $ study
Barter, and Fa rho m
abuse di SC osure
nonrepresentat ve
1,099 eva uat on forms
w th ess than one quarter of youth
prov des ns ght nto young
(2009b)
strateg es w th a
samp es. Qua tat ve
comp eted fo ow ng
report ng a di SC osure. 244 of the 1,099
peop e's percept ons of di SC osure
nat ona samp e of
ana ys $ of 1,099
Red Cross RespectED
youth who di SC osed abuse on the r
exper ences. H gh eve of r gor
Canad an youth who
eva uat on forms
V ence prevent on
eva uat on forms dent f ed spec
W th trustworth ness of the data
part C pated n O ence
comp eted fo ow ng
programm ng
nd V dua S they to di about the r abuse.
ana ys $ ensured through use of
prevent on
Red Cross RespectED
de vered between
D SC osure patterns vary th boys,
youth focus groups, nterv ews,
programm ng. One of
O ence prevent on
2000 and 2003
youth aged 14-15, V ct ms of phys ca
and observat ona data. The study
the goa $ of the study
programm ng
abuse, and those abused by a fam y
resu ts are somewhat m ted n
was to document not
de vered between
member be ng most ke y to SC ose to
the th ckness of the descr pt ons t
prev ous y dent ed
2000 and 2003. Forms
profess ona $ or the po ce. One th rd of
can offer because most of the data
exper ences of abuse
of anonymous abuse
d SC osures were di rected toward
are survey based. Reg ona
and youth att tudes
di SC osures by youth
profess ona $ and the east, 5% percent
di fferences may not have been
toward di SC osure of
part C pants of neg ect,
each, were di rected toward fr ends,
P cked up. Scope of the study $
abuse exper ences
emot ona, phys ca,
parents, and others. Part C pants were
broad and approach $ creat ve
and sexua abuse.
most ke y to di SC ose sexua abuse to
Twenty-seven
parents/fam y. profess ona S. and the
nterv ews and focus
po ce/courts, W th fewer choos ng
groups were a so done
fr ends.
to understand
Out of a 1,099 part C pants, 225 ma es and
contextua ssues and
779 fema es nd cated that they had been
engage youth and
abused. Out of those, 43 ma es and 180
program fac tators n
fema es nd cated that they had di SC osed
the interpretat on of
the abuse. Of those who had di SC osed,
nd ngs. A cod ng
on y a port on of ma es and fema es
structure was
spec f ed who they had di SC osed the
deve oped for ana ys S
abuse to ("Wh e 1,099 eva uat ons W th
to synthes ze themes
di SC osure statements were ana yzed,
EFTA00024183
across data sources
on y 22% made ment on of peop e to
267
(continued)

=== Page 10 ===
268
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
Fnd ngs
Summary
whom SC osures occurred.") More
fema es spec f ed who they di SC osed to
compare to ma es. The data show
percept ons among youth of negat ve
consequences fo ow ng di SC osure
Pr ebe and Sved n (2008)
Th $ study a med to
Part C pants comp eted
The samp e cons sted of
Of the samp e, 1,505 g (65%) and 457
Th $ study h gh ghted that sexua
nvest gate SC osure
65- tem quest onna re
4,339 h gh school
boys (23%) reported CSA. The
abuse S arge y h dden from adu t
rates and di SC osure
that nc uded quest ons
students n Sweden
di SC osure rate was 81% (g s) and 69%
SOC ety, espec a y from
patterns and exam ne
about background,
(2,324 grs and 2,015
(boys). G and boys di SC osed most
profess ona S and the ega system.
pred ctors of
consensua sex, sexua
boys). The mean age of
often to a fr end of the r own age. Few
However, t me apsed to
nond SC osure n a
abuse exper ences
the part C pants was
had SC osed to profess ona S, and even
di SC osure was not reported.
samp e of ma e and
(noncontact, contact
18.15 years. Th study
fewer had reported to the author t es.
S nce fr ends appeared to be the
fema e ado escents
or penetrat ng abuse,
used a subsamp e of
There were h gher rates of di SC osure to
ma n rec P ents of sexua abuse
w th se f-reported
nc ud ng peer abuse),
1,962 part C pants who
a profess ona W th more severe abuse
di SC osures, pract ce mp cat ons
exper ences of sexua
di SC osure of CSA,
reported CSA and
(contact abuse W th or W thout
of th S cou di be to f nd ways to
abuse
own sexua abus ve
who answered
penetrat on) for grs, but ower rates for
g ve young peop e better
behav or, sexua
di SC osure quest ons
boys The more severe the sexua abuse
nformat on and gu dance about
att tudes, and
was, the ess ke y both g r $ and boys
how to support a sexua y abused
exper ences W th
had ta ked to the r mother, father, or a
peer. A qua tat ve component to
pornography and
b ng. G r S were ess ke y to di SC ose f
the study wou di have prov ded a
sexua exp O tat on.
they had exper enced contact sexua
broader understand ng of
The quest onna re
abuse W th or W thout penetrat on, ess
di SC osure processes. Study
nc uded 6 mod f ed
frequent abuse, abuse by a fam y
m tat ons nc ude a $ gn f cant
tems from the SCL-90
member, or f they had perce ved the r
amount of boys who di di not
and 9 of 25 tems from
parents as ess car ng and ess
comp ete the quest ons regard ng
the Parenta Bond ng
overprotect ve and h gh y
di SC osure on; the tm ng of
Instrument. The data
overprotect ve. Boys were ess ke y to
di SC osures (whether they were
for g r S and boys were
di SC ose fa fam y member abused them,
de ayed or not) was not
ana yzed separate y
they were study ng a vocat ona program
measured; poss b ty of reca b as
(vs. an academ C program), ved W th
W th retrospect ve stud es based
both parents or had perce ved the r
on se f-reports; and youth
parents as ess car ng and not
part C pants may not have
overprotect ve.
understood a the quest ons
Ado escents who reported CSA perce ved
the r menta hea th as poorer compared
to ado escents W thout CSA.
Nond SC osers reported more
symptoms on the Menta Hea th Sca e
than those who had di SC osed
Sorso, K a-Keat ng. and
Study focused on
Ma e surv vors of CSA
The samp e cons sted of
Barr ers to di SC osure were found to be
S nce the vast major ty of men n the
Grossman (2008)
SC osure cha enges
were nterv ewed
16 ma e surv vors of
operant n three nterre ated doma ns:
samp e had not d SC osed n
for ma e surv vors of
about the r di SC osure
ch dhood sexua
(I) persona (e.g., ack of cogn t ve
ch dhood, they may have been
CSA to understand
exper ences. Ana ytc
abuse; II Caucas an, 2
awareness, ntent ona avo dance,
pred sposed to dent fy ng
EFTA00024184
three ssues: (I) To
techn ques nc uded
Afr can Amer can, I
emot ona read ness, and shame); (2)
barr ers to di SC osure more
(continued)

=== Page 11 ===
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
Fnd ngs
Summary
whom and n what
grounded theory
Puerto R can, I part
re at ona (e.g., fears about negat ve
read y. Retrospect ve accounts
contexts have they
method of ana ys S for
Nat ve Amer can, I
repercuss ons, so at on); and (3)
are subject to reca ssues.
SC osed these
cod ng and
Afr can Cuban: age
SOC ocu tura (e.g., ack of acceptance for
Invest gators made S gn f cant
exper ences? (2) What
deve opment of
range of 24-61 years; 9
men to exper ence or acknow edge
efforts to gather a di verse samp e.
do they have to say
conceptua y C ustered
dent ed themse ves
V zat on).
H gh eve of r gor was executed
about the r di SC osure
matr ces. Part C pants
as heterosexua, 5 as
Ony I of the 16 men n th S samp e
n the dependab ty of the data
exper ences? and (3)
comp eted two n-
homosexua, and 2 as
di SC osed the fu extent of h S sexua
and terat ve process of the
What are the r
depth, -structured
b sexua
abuse exper ences wh e he was st a
interpretat on of nd ngs was
percept ons of pos t ve
nterv ews, ast ng
ch d. The other men reported that they
conducted
and negat ve aspects of
between 2 and 3 hr
had not di SC osed, a though some
the r di SC osure,
each tak ng P ace
reported attempts to te that were
nc ud ng incent ves
approx mate y a week
nd rect or ncomp ete. Severa other
and barr ers?
apart
men di SC osed certa n exper ences or
e ements of the r abuse, but concea ed
others. By the t me of the study, many of
these men had di SC osed the r past
exper ences n a var ety of re at onsh ps,
nc ud ng those W th fam y members,
partners, therap sts, and nfrequent
fr ends. Severa had ony m ted
di scuss ons of the r sexua abuse
Hershkow tz, Lanes, and
The goa of the present
A eged V ct ms of sexua
Th rty a eged ms of
D SC osure categor es were dent f ed as
Innovat ve des gn to gather
Lamb (2007)
study was to exam ne
abuse and the
CSA; 18 boys and 12
fo ows: (I) de ayed 53% of the ch dren
di SC osure data from young
how ch di ct ms of
parents were
grs. Ch di samp e was
de ayed di SC osure for between I week
ch dren. Focus S on extrafam a
extrafam a sexua
nterv ewed. Ch dren
7- to 12-year-o ds W th
and 2 years; (2) rec P ent of di SC osure:
CSA wh ch may di ffer than
abuse di SC osed the
were nterv ewed
an average age of 9.2
47% of ch dren rst SC osed to S b ngs
di SC osure patterns of ntrafam a
abuse exper ence
us ng the NICHD
years. Twenty mothers
or fr ends, 43% frst di SC osed to the r
CSA. Two th rds of the parents
Invest gat ve Interv ew
and 10 fathers were
parents, and 10% rst di SC osed to
reg stered unsupport ve
Protoco by
a so nterv ewed for a
another adu t. 57% of the ch dren
responses wh S h gh
exper enced youth
tota of 30 parent
spontaneous y di SC osed abuse, but 43%
nvest gators.
nterv ews. A content
di SC osed on y after they were
Informat on on
ana ys S was conducted
prompted. 50% of the ch dren reported
di SC osure processes
on ch di and parent
fee ng afra d or ashamed of the r
was obta ned n the
nterv ews
parents' responses. Parents' react ons:
f rst forma nterv ew,
support ve (37%) and unsupport ve
before any po ce
(63%). There was a strong corre at on
nvest gat on or ch di
between pred cted and actua parenta
we fare ntervent on
react ons suggest ng ch dren ant C pated
the r parents' ke y react ons accurate y.
D SC osure processes var ed depend ng
on the ch dren's ages (e.g., younger
ch dren SC osed to parents). sever ty
and frequency of abuse, parents'
expected react ons, suspects' dent t es,
EFTA00024185
and strateg es used to foster secrecy
269
(continued)

=== Page 12 ===
270
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
ngs
Summary
A agg a and K rshenbaum
The object ves of the
A qua tat ve
Purpos ve samp ng was
Four major themes emerged suggest ng
Over ha f the part C pants had not
(2005)
current study were to
phenomeno og ca
emp oyed to recru t 20
that CSA di SC osure can be S gn f cant
di SC osed the abuse dur ng
dent fy a broad range
des gn-LIM-was
adu t surv vors
comprom sed when certa n fam y
ch dhood. Of the nond SC os ng
of factors, nc ud ng
used to e
between the ages of 18
cond t ons ex st: (I) r g y xed, gender
part C pants, $ X d di not di SC ose
fam y dynam CS that
SC osure
and 65 who were
ro es based on a patr archy-based fam y
because they had repressed or
contr bute to or
exper ences;
sexua y abused by a
structure; (2) presence of fam y
forgotten the memory. A most
h nder a ch d's ab ty
fac tators and
fam y member.
VO ence; (3) C osed, nd rect fam y
one th rd W thhe di di SC osure
to SC ose CSA.
barr ers; and re evant
Average age of
commun cat on patterns; and (4) SOC a
ntent ona y. More data are
C rcumstances.
part C pants was 40.1
so at on of the fam y as a who e, or
needed on ear y di SC osures to
Interv ews were
years; 60% of
spec f C members, P ayed a part n CSA
garner more nformat on on
transcr bed verbat m.
part C pants were
V ct ms fee ng they had no one safe to
fac tators of d SC osure.
ne-by- ne open
fema e and 40% ma e.
te. Fam y systems formu at ons through
Retrospect ve approach mp es
cod ng was conducted
Average age of onset
a fem st ens are important n
reca ssues. H gh eve of
to capture fam y- eve
of abuse was 6.7 years.
understand ng ch dren and fam es at
trustworth ness of the data and
factors. Ax a and
xed C n ca and
r sk of di SC osure barr ers
interpretat ons were ach eved
se ect ve cod ng
nonc n ca samp e. The
through cred b ty, dependab ty,
fac tated
major ty had rece ved
and conf rmab ty through rect
dent f cat on of
treatment for CSA at
quotes
themes
some po nt n the r
ves
A agg a (2005)
The study purpose was
Surv vors of CSA were
Purpos ve samp ng of
Three themes emerged for men that
One n a dearth of stud es that
to qua tat ve y exp ore
nterv ewed about
women and men, a ong
nh b ted or prec P tated di SC osure for
conduct gender ana ys S.
dynam CS that mpede
the r di SC osure
W th those who
reasons re ated to gender: (I) fear of
Comparat ve ana ys S draws out
or promote di SC osure
exper ences us ng LIM.
di SC osed dur ng the
be ng V ewed as homosexua (2)
important pract ce mp cat ons.
by exam n ng a range of
Ana ys $ of 30
abuse and those who
profound fee ngs of st gmat zat on or
Retrospect ve des gn of the study
factors nc ud ng
part C pant narrat ves
di not. 19 fema es and
so at on because of the be ef that boys
wh ch mp es poss b e reca
gender as a dynam -
was used for theme
II ma es; 18-65 (mean
are rare y V ct m zed; and (3) fear of
ssues. Hgh eve of
how di SC osures of
deve opment regard ng
40.1) years who were
becom ng an abuser, wh ch acted as a
trustworth ness of the data and
fema es and ma es are
mpact of gender on
sexua y abused by a
prec P tant for di SC osure. Two
interpretat ons were ach eved
S m ar and di fferent,
di SC osure. Interv ews
fam y member or a
predom nant themes W th fema e
through cred b ty, dependab ty,
and n what ways
were transcr bed
trusted adu t. Average
part C pants re ated to di ff cu t es
and conf rmab ty through di rect
gender affects CSA
verbat m for open,
age of abuse onset was
SC os ng: (I) they fe t more conf cted
quotes
di SC osure
axa, and se ect ve
5.3 years, 36% were
about who was respons b e for the abuse
cod ng. Categor es and
nonwh te, and 58% had
and (2) they more strong y ant C pated
subcategor es were
not di SC osed dur ng
be ng b amed and/or not be eved
CO apsed and ref n ng
ch dhood
nto theme areas
Co ngs, Gr ff ths, and
Study exam ned patterns
F e rev ews of a SOC a
1,737 cases of CSA
Content ana ys dent ed two broad
These resu ts nto A agg a's (2004)
Kuma o (2005).
of di SC osure n a arge
work and med ca case
reported n the North
mens ons of SC osure: (I) agency:
di SC osure framework. Through
representat ve samp e
f es for CSA V ct ms
Durban area of
ch d- n ated di SC osure versus
data ana ys S two raters coded
of South Afr can CSA
seen at the cr
KwaZu u-Nata, South
detect on by a rd party and (2)
di SC osure categor es us ng
ms. Two study
center where a cases
Afr ca, dur ng January
tempora durat on: an event versus a
author's di SC osure framework,
object ves to: (I)
of CSA reported to
2001 to December
process. These di SC osure di mens ons
wh ch proved to be both
EFTA00024186
exam ne how and
the North Durban
2003. 1,614 g and
def ned four di screte categor es of
exhaust ve and mutua y exc us ve
(continued)

=== Page 13 ===
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
Fnd ngs
Summary
when CSA V ct ms
po cng area were
123 boys; average age
SC osure: (I) purposefu SC osure
w th the percentage of interrater
di SC ose the r abuse
referred dur ng the
of V zed ch dren
(30% of cases), (2) nd rect di SC osure
agreement at 98%.
and (2) Ident fy factors
per od of January 2001
was 9.9 years. 47%
(9% of cases), (3) eyew tness detect on
Genera zab ty of th S study $
assoc ated W th
to December 2003
reports were made
(18% of cases), and (4) acc denta
m ted to ch di C ents rece ng a
di fferent patterns of
W th n 72 hr of the
detect on (43% of cases). D SC osure
cr S assessment referred
di SC osure
abuse, 31% from 72 hr
ndependent y pred cted by V ct m's age,
through a po ce report
to I month, and 22%
nature of the V ct m-perpetrator
more than a month
re at onsh p. offender's age, frequency of
after the abuse
abuse, and report ng atency. Mean age of
purposefu di SC osures (10.67) was
h gher than the mean age of nd rect
di SC osures (5.84). Exp ct forms of
di SC osure were ess ke y when the
offender was a fam y member. Shorter
report atency was more ke y W th
repeated abuse
Hershkow tz, Horow tz,
Th study a med to
Large database of
The samp e was
Overa , 65% of the 26,446 ch dren made
Overa fnd ngs nd cated that rates
and Lamb (2005).
dent fy character st CS
suspected cases of
compr sed of 26,446 of
a egat ons when nterv ewed. Rates of
of di SC osure var ed systemat ca y
of suspected ch di
phys ca and sexua
3- to 14-year-o di
di SC osure were greater for sexua abuse
depend ng on the nature of the
abuse V ct ms that are
abuse nvest gated n
a eged V ct ms of
(71%) over phys ca abuse (61%).
a eged offences, the re at onsh P
assoc ated W th
Israe between 1998
sexua and phys ca
Ch dren of a ages were ess ke y to
between a eged V ct ms and
di SC osure and
and 2002 was ana yzed.
abuse nterv ewed n
di SC ose/a ege abuse when a parent was
suspected perpetrators, and the
nond SC osure dur ng
Interv ews were a so
Israe n the 5-year
the suspected perpetrator. D SC osure
age of the suspected V ct ms.
forma nvest gat ons
conducted us ng
per od from 1998 to
rates ncreased as ch dren grew O der:
Ana yses on nvo ved cases that
standard zed NICHD
2002. 140 exper enced
50% W th 3- to 6-year-o ds, 67% of the 7-
had come to the attent on of
Invest gat ve Interv ew
tra ned youth
to 10-year-o ds, and 74% of the 11- to
off C a agenc es, mak ng t di ff cu t
Protoco. Arch va data
nvest gators
14-year-o ds SC osed abuse when
to determ ne how many of abuse
were ana yzed
conducted nterv ews
quest oned
take ace W thout ever tr gger ng
any k nd of off a nvest gat on
Jensen, Gu brandsen,
Th study nvest gated
Qua tat ve approach to
20 fam es W th a tota of
None of the ch dren to di of abuse
Ev dence for de ayed di SC osures.
Moss ge, Re che t. and
the context n wh ch
data CO ect on and
22 ch dren
mmed ate y after t occurred. Ch dren
The resu ts nd cate that
Tjers and (2005)
ch dren were ab e to
ana ys $ was used.
part C pated. A
exposed to repet t ve abuse kept th S as a
di SC osure S a fundamenta y
report the r ch di
Therapeut C nterv ews
ch dren had to about
secret for up to severa years; 17 to di
a og process that becomes
sexua abuse
o the ch dren and
exper ences that
the r mothers rst, 3 rst to di a fr end, I
ess di ff cu f ch dren perce ve
exper ences; the r
most y the r mothers
created concerns for
to di the r father, and I the r unc e.
that there $ an opportun ty to
V ews as to what made
were ana yzed through
care-g vers about CSA.
Major ty of remarks that ed to the
ta k, a purpose for speak ng and a
t ff cu t to ta k about
a qua tat ve approach.
Ch dren's ages ranged
susp C on of CSA were made n
connect on has been estab shed
abuse; what he ped
Fo ow-up nterv ews
between 3 and 16
S tuat ons where someone engaged the
to what they are ta k ng about.
them n the SC os ng
were he di I year ater
years (average age 7.5
ch di n a a ogue about what was
Strengthen ng parent-ch di
process; and the r
years); 15 g and 7
bother ng them, resu ng n a referra.
re at onsh ps $ an important
parent's percept ons of
boys. Sexua y abused
The ch dren fe t was d ff cu to nd
pract ce mp cat on
the r SC osure
by someone n the
$ tuat ons conta n ng enough pr vacy and
processes
fam y or a C ose
prompts that they cou di share the r
EFTA00024187
person to the fam y
exper ences. When the ch dren di di
271
(continued)

=== Page 14 ===
272
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
Fnd ngs
Summary
SC ose they dd t n S tuat ons where
the top C of ch di sexua abuse was n
some form addressed or act vated,
where someone recogn zed the ch d's
cues and probed further. They a so were
sens t ve to others react ons, and
whether the r di SC osures wou di be
m S interpreted. Severa of the ch dren
perce ved negat ve consequences as
major factors contr but ng to de ay ng
di SC osure. They were pr mar y
concerned about negat ve effects for the
mother. The mothers sa di they were
a so sens t ve to the ch dren's fee ngs. If
the r ch dren showed $ gns of di stress
and di di not want to ta k, the mothers
wou di change the subject or not pursue
the top C further
Sta er and Ne son-
The purpose of th S study
Secondary ana ys $ of
Samp e cons sted of 34
nd ngs are reported n three major
Th $ study prov ded a contextua
Garde (2005)
was to understand the
qua tat ve focus group
part C pants from four
doma ns: (I) se f-phase: where ch dren
exam nat on of the ent re
fu process of CSA
data. Or g na project
groups. Sess ons
come to understand V ct m zat on
di SC osure process, C oser to the
di SC osure and how
cons sted of four focus
ana yzed were
nterna y: (2) conf dant se ect on-
po nt n me when the abuse and
th $ unfo ded for
groups conducted
between 60 and 90 m n
react on phase: where they se ect a t me,
di SC osure occurred. Sma groups
preado escent and
n the context of
ong: aud otaped and
ace, and person to te and then
of preado escent and ado escent
ado escent r S.
ongo ng therapy for
ater transcr bed for
whether that person's react on was
g who had surv ved sexua
Exam ned what
grs who had
content ana ys S
support ve or host e; and (3)
abuse a so served as consu tants
fac tated and
exper enced CSA.
consequences phase: good and bad that
and were encouraged to share
h ndered di SC osure
Secondary ana ys $
cont nued to nform the r ongo ng
the r know edge for the benef t of
and subsequent
cons sted of wr tten
strateg es of te ng. The act ons and
profess ona pract t oners
consequences
narrat ve summar es of
react ons of adu ts were S gn f cant and
each sess on group ng
informed the gr s' dec $ ons. The
these conceptua y.
consequences phase was further
and exam n ng the r
subd V ded nto four aspects: (I)
nterconnectedness
goss P ng and news networks, (2)
chang ng re at onsh ps, (3) nst tut ona
responses and the after fe of te ng. and
(4) ns der and outs der commun t es
A agg a (2004)
The study sought to
The study emp oyed
Us ng purpos ve samp ng
Through ana ys $ of the nterv ew new
Th study expanded types of CSA
exam ne nf uences
LIM-a
24 adu t surv vors of
categor es of di SC osure were dent f ed
di SC osures to more fu y
that nh b t or promote
phenomeno og ca
ntrafam a abuse
to add to ex st ng types. Three
understand how ch dren and
ch dren's di SC osure of
des gn. Intens ve
between ages of 18
prev ous y dent f ed were conf rmed n
adu ts di SC ose. And under what
CSA to address gaps n
nterv ew ng that were
and 65 (average age
these data: acc denta, purposefu, and
C rcumstances. Ask ng peop e to
know edge about how,
2 hr ong on average
41.2) were recru ted
prompted/e C ted accounted for 42% of
recount events that occurred n
EFTA00024188
when, and under what
generated data for a
from agenc es and one
di SC osure patterns n the study samp e.
ch dhood $ suscept b e to
C rcumstances V ct ms
themat C ana ys S. The
un vers ty: 57% ma e
Over ha f the di SC osure patterns descr bed
memory fa ure, espec a y when
of CSA di SC ose
nterv ew gu de was
and 43% fema e:
by the study samp e di di not ft these
memor es were forgotten,
(continued)

=== Page 15 ===
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
F nd ngs
Summary
deve oped to probe
average age of abuse
prev ous y estab shed categor es. Three
de ayed, or repressed and ater
for nd V dua,
onset was 6.5 years;
add t ona di SC osure categor es
recovered. D stort on and
interpersona,
42% of the part C pants
emerged: behav ora and nd rect verba
rev $ on of events are a so
env ronmenta, and
had d SC osed the
attempts, di SC osures ntent ona y
potent a prob ems n reca H gh
cu tura factors
abuse dur ng
W thhe d, and di SC osures tr ggered by
degree of trustworth ness of the
nf uenc ng CSA
ch dhood; 58%
recovered memor es
data was ach eved and quotes
SC osure
di SC osed as adu ts
prov ded supported the
categor es
Cr sma, Basce Pac, and
The ma n goa $ of th S
In-depth te ephone
The samp e was
The ma n mped ments to di SC ose to a
Th $ study represented the f nd ngs
Rom to (2004)
study were to
(anonymous)
compr sed of 36 young
fam y member were: fear of not be ng
of a m xed samp e of surv vors of
understand
nterv ews were
peop e who
be eved, shame, and fear of caus ng
ch di sexua abuse and nt mate
mped ments that
conducted after
exper enced sexua
troub e to the fam y. The ma n
partner V O ence. The study was
prevent ado escents
informed consent was
abuse n ado escence;
mped ments for not seek ng serv ces
conducted n Ita y and t $ not
from di SC os ng CSA
exp a ned and
35 fema es and I ma e:
were: unaware of appropr ate serv ces,
C ear what sexua abuse response
and seek ng he P from
obta ned. Three
aged 12-17. Some of
sh to keep the secret, ack of
tra n ng $ ava ab e. There may
the r SOC a network
nvest gators
the samp e
awareness of be ng abused, m strust of
have been a se ect on b as as the
and/or the serv ces
exper enced n
exper enced sexua
adu ts and profess ona S. and fear of the
most di ssat sf ed surv vors
counse ng CSA
V O ence n a dat ng
consequences of di SC os ng sexua abuse.
responded to the research ca
counse ng conducted
re at onsh P
When they dd di SC ose to profess ona S.
the nterv ews wh ch
teens rece ved very m ted support as
were recorded W th
many profess ona S were not tra ned on
perm SS on. Three
sexua abuse and cou di not offer
researchers
appropr ate intervent ons to V ct ms
ndependent y scored
the nterv ews
accord ng to a cod ng
framework
Jonzon and L ndb ad
Study purpose was to
Adu t women report ng
122 adu t women
Abuse character st CS: abuse by mu t e
68% de ayed di SC osure unt
(2004)
exp ore how abuse
CSA by someone C ose
between 20 and 60
perpetrators was more common than by
adu thood. At the t me of the
tra ts, openness,
were nterv ewed
years o di (average age
a $ ng e perpetrator. Age of onset was
study, t was one of the f rst
react ons to CSA
us ng sem -structured
of 41 years) report ng
often before age of 7, th an average
stud es to focus on the nterp ay
di SC osure, and SOC a
gu des together th
exposure to ch di
durat on of 7 years. Severe y abused
between SOC a support networks
support were re ated.
quest onna res. Data
sexua abuse by
women had ta ked to more of the r
and di SC osure of ch di sexua
D fferences based on
on V ct m zat on and
someone C ose before
SOC a network, espec a y to
abuse. The study resu ts are
sever ty of abuse,
current SOC a support
the age of 18 and had
profess ona S. D SC osures: 32%
somewhat m ted by an
t ng and outcomes
were retr eved
to di someone about at
di SC osed dur ng ch dhood (before the
overrepresentat on of severe
of SC osure, SOC a
through the
east one abuse event.
age of 18) W th an average of 21 years
abused women. Retrospect ve
support, and
quest onna res, and
90% were Swed sh
de ay. Women who had di SC osed n
study and se f-report of
pred ct ng factors of
data on di SC osure and
subjects. Purpos ve
ch dhood reported more nstances of
nformat on cou di mp y reca
pos t ve and negat ve
react ons were
samp ng strategy was
phys ca abuse, mu tp e perpetrators,
ssues and thus m ts the accuracy
react ons were probed
gathered through the
used
use of V o ence, and were more ke y to
of the nformat on obta ned on
nterv ews W th
have confronted a perpetrator, and had
abuse and di SC osure
part C pants
rece ved a negat ve rst react on. Factors
character st CS. Cross-sect ona
EFTA00024189
(continued)
273

=== Page 16 ===
274
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
F nd ngs
Summary
$ gn cant y pred de ay were
des gn does not a ow for def n te
younger age at rst event and no use of
conc us ons of cause and effect on
V O ence. D SC osure outcomes: of the 26
the re at onsh ps found
women who to di n ch dhood dur ng a
per od w th ongo ng abuse, 15 women
were cont nuous y abused after
di SC osure
Kogan (2004)
The purpose of th $ study
Data were gathered from
A subsamp e of 263
Ch dren under the age of 7 were at a
Th $ study exam ned factors
was to dent fy factors
a subsamp e of fema e
ado escent fema es
h gher r sk for de ayed di SC osures.
nc ud ng di SC osures of USEs n
that nf uence the
ado escents that
between 12 and 17
Part C pants whose USE occurred
ch dhood and ado escence n a
di SC osures made by
part C pated n the
years O d, mean age of
between the ages of 7 and 13 were most
nat ona y representat ve samp e
fema e surv vors of
NSA, wh ch cons sted
15.2 years O d, who
ke y to te an adu t. Ado escents (14-
of fema e ado escents who
USE n ch dhood and
of structured phone
reported at east one
17) were more ke y to te on y peers
part C pated n the NSA. Surveys
ado escence. The
nterv ews. USEs
exper ence of
than ch dren aged 7-10 years. Ch dren
for nvest gat ons of V ct m zat on
pred ctors of both the
reported n the NSA
unwanted sexua
under II were more ke y to te an
exper ences may be b ased due to
t ng of di SC osure
were assessed us ng a
contact n the NSA.
adu t, but were at r sk for de ay ng
underreport ng. Ado escents who
and the rec P ent of the
mod f ed vers on of the
Part C pant
di SC osure beyond a month. Ch dren
refused to report or di scuss an
di SC osure were
Inc dent C ass cat on
character st CS, USE
aged 11-13 tended to SC ose W th n a
USE may represent a source of
nvest gated
Interv ew. They were
character st CS, and
month. C oser re at onsh P to the
systemat C b as and wou di make
then asked a ser es of
fam y contextua
perpetrator or a fam y member was
the resu ts genera zab e on y to
quest ons about each
attr butes were
assoc ated W th de ayed di SC osure.
ado escents who are W ng to
ep sode of unwanted
exp ored
Immed ate di SC osure was more ke
SC ose USE a survey. A though
sexua contact
W th stranger perpetrat on. Fear for
data may be retrospect ve, reca
nc ud ng event
one's fe dur ng and penetrat on were
b as may have been m n m zed n
character st CS and
assoc ated W th di SC osure to adu ts.
th $ study $ nce part C pants were
perpetrator
Fam y factors nked to d SC osure were
ado escents, and so the t me ag
character st CS
(I) drug abus ng househo di member,
between the USE and the
wh ch made surv vors more ke y to
nterv ew were presumab y
di SC ose more prompt y and (2) never
shorter than a study of adu t
ng W th both parents was assoc ated
part C pants reca ng CSA
W th nond SC osure
exper ences
Goodman-Brown,
The purpose of th S study
Case f e rev ews of data
Samp e cons sted of 218
64% di SC osed W th n a month and 29%
Th S study represents a h gher rate
Ede ste n, Goodman,
was to nvest gate
obta ned from
ch dren referred to
W th n 6 months. F ve var ab es for the
of SC osers W th n a month.
Jones, and Gordon
var ab es assoc ated
prosecut on f es, as
prosecutors' off ces
mode were tested. (I) age: ch dren who
These cases had been reported to
(2003)
w th de ay of
we as from
for a eged CSA. A
were o der took onger to di SC ose and
author t es and were n process of
di SC osure of CSA and
structured nterv ews
ch dren n the samp e
o der ch dren feared more negat ve
prosecut on wh ch may exp a n
test a mode for
w th the ch dren's
had d SC osed the r
consequences to others than younger
h gher rate of ear y d SC osures.
factors that nf uence
caretaker and
abuse n some manner.
ch dren; (2) type of abuse: V ct ms of
Lega samp e W th h gher rate of
how qu ck y ch dren
observat ons of ch di
Ch dren ranged n age
ntrafam a fam es took onger to
extrafam a abuse (52%) may a so
di SC ose sexua abuse
nterv ews. Tra ned
from 2 to 16 years at
di SC ose-v ct ms of ntrafam a abuse
account for ear er SC osures.
graduate students and
the beg nn ng of abuse;
feared greater negat ve consequences to
Mode suggests that o der
one ct advocate
3-16 years at the end
others compared to ms of
ch dren, V ms of ntrafam a
comp eted the Sexua
of the abuse, and 4-16
extrafam a abuse; (3) fear of negat ve
abuse; fe t greater respons b ty
EFTA00024190
Assau t Prof e
years at the t me of the
consequences: ch dren who feared
for the abuse, and perce ng
(continued)

=== Page 17 ===
Table I. (cont nued)
Study
Purpose
Des gn
Samp e
F nd ngs
Summary
quest onna re for ch di
po ce report;
negat ve consequences of SC osure
negat ve consequences to
character st CS, the
77% fema e, 70%
took onger to di SC ose, ch dren who
SC os ng took onger to di SC ose.
abuse and the r
Caucas an, 17%
be eved that the r di SC osure wou di
We -des gned study w th h gh
SC osure. Ch dren's
H span C. and 11%
br ng harm to others took onger to
eve of r gor. Produced a V ab e
percept on of
Afr can Amer can.
SC ose, fear of negat ve consequences
mode of SC osure for further
respons b ty and fear
Predom nant y m dd e
to the se f or the perpetrator was
nvest gat ons. However,
of negat ve
to ow SES.
unre ated to t me of di SC osure, and grs
researchers were not ab e to
consequences were
Approx mate y 47%
more than boys feared negat ve
nterv ew ch dren di rect
probed.
ntrafam a abuse
consequences to others; (4) Perce ved
Corre at ona ana yses
respons b ty: ch dren who fe t greater
were conducted W th
respons b ty for the abuse took onger
path ana yses to test
to di SC ose and O der ch dren fe t more
the hypothes zed
respons b ty for the abuse; and (5)
causa re at ons among
gender was not S gn cant corre ated
var ab es
th t me to di SC osure
Sm th, Letourneau,
The study focus was to
Structured te ephone
Two probab ty samp es.
288 (9%) reported exper enc ng at east
The t me frame of th S survey may
Saunders, K patr ck,
gather data from a
nterv ews that asted
Wave I was a random
one event that met the study's def n t on
have had contextua mp cat ons.
Resn ck, and Best
arge samp e of women
approx mate y 35 m n
samp e of 2,009
of ch dhood rape. The average age at the
The major ty of ch d rapes
(2000)
about the ength of
were used to CO ect
respondents se ected
t me of the rst rape was 10.9 years. Of
reported by th $ samp e occurred
tme women who
data us ng a computer-
from strat f ed samp es
the 288 women who reported a ch di
pr or to the arge-sca e ch di
were raped before age
ass sted te ephone
of def ned
rape, 28% stated that they had never to di
assau t prevent on educat on
18 de ayed di SC osure
nterv ew system. A
jur sd ct ons.
anyone about th S sexua assau t unt
programs that were begun n the
who they di SC osed to,
te ephone nterv ews
Random di ta da ng
spec f ca y quer ed by the nterv ewer
1980s that teach ch dren that
and var ab es that
were conducted W th
was used to so ct
for th $ study. 58% di di not di SC ose for
assau ts (nc ud ng CSA) are
pred cted di SC osure
each quest on on a
househo ds for sted
over I year and up to 5 years post-rape.
wrong and shou di be di SC osed to
w th n I month
computer screen. The
and un sted te ephone
27% di SC osed W th n a month. Among
respons b e adu ts. Th $
survey cons sted of
numbers. Second
women who di SC osed pr or to the r
nformat on may have nf uenced
severa measures
random samp e of
NWS nterv ew C ose fr ends were the
(and may current y be nf uenc ng)
des gned to e
2,000 women between
most common person to whom V ct ms
young women's di SC osure
demograph C
the ages of 18 and 34
made di SC osures, fo owed by mothers
patterns. For Wave I, compar son
informat on,
was se ected. Both
and other mmed ate fam y members.
of these data W th the popu at on
psych atr C symptoms,
Wave I and Wave 2
Fewer than 10% of V ms reported
parameters obta ned from the
substance use, and
data were we ghted to
mak ng the r nta d SC osure to SOC a
U.S. Census Bureau nd cated that
m zat on h story.
conform to the 1989
workers or aw enforcement personne.
the samp e C ose y matched the
The present study
Census stat st CS
Ony 12% of ch di rape V ct ms stated
demograph C attr butes of the
reports on data from
that the r assau ts were reported to
popu at on of U.S. women
the demograph C and
author t es at some po nt
ch di rape V ct m zat on
quest ons
Note. SCL-90 = Symptom Check List-90; SES = socioeconomic status; LM = ong interview method: CSA = chi di sexua abuse; N CHD = Nationa nstitute of Chi di Hea th and Human Deve opment; USE = unwanted
EFTA00024191
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TRAUMA, VIOLENCE, & ABUSE 20(2)
examples of this usage were found in the research questions,
being facilitated within a dialogical and relational context is
interview guides, and surveys examined: "How and when do
being more clearly delineated.
people decide to tell others about their early sexual experiences
Theme 2: Contemporary disclosure models reflect a
with adults?" (Hunter, 2011, p. 161); "Some men take many
social-ecological, person-in-environment perspective to
years to tell someone that they were sexually abused. Please
understand the complex interplay of individual, familial,
describe why it may be difficult for men to tell about/discuss
contextual, and cultural factors involved in CSA disclosure.
the sexual abuse" (Easton, Saltzman, & Willis, 2014, p. 462).
Subthemes include new categories of disclosure and a grow-
"Participants were asked a series of open-ended questions to
ing focus on previously missing cultural and contextual
elicit a narrative regarding their experiences of telling
"
factors.
(McElvaney, Greene, & Hogan, 2012, p. 1160). "Who was the
Theme 3: Age and gender are strong predictors for delaying
first person you told?" (Schaeffer, Leventhal, & Anes, 2011, p.
disclosure or withholding disclosure with trends showing
346).
fewer disclosures by younger children and boys. One sub-
There was sound consistency between studies, defining dis-
theme emerged that intrafamilial abuse/family-like relation-
closure in multifaceted ways with uniform use of categories of
ship of perpetrator has a bearing on disclosure delays or
prompted, purposeful, withheld, accidental, direct, and indi-
withholding.
rect. However, defining the period of time that would delineate
Theme 4: There is a lack of a cohesive life-course perspec-
a disclosure as delayed varied widely across studies, wherein
tive. One subtheme includes the lack of data within the 18-
some studies viewed I week or 1 month as a delayed disclosure
to 24-year-old emerging adult population.
(i.e., Hershkowitz et al., 2007; Kogan, 2004; Schönbucher,
Theme 5: Significantly more information is available on
Maier, Moher-Kuo, Schnyder, & Lamdolt, 2012). Other studies
barriers than on facilitators of CSA disclosure. Subthemes
simply reported average years of delay sometimes as long as
of shame, self-blame, and fear are uniformly identified as
from 20 to 46 years (Easton, 2013; Jonzon & Linblad, 2004;
disclosure deterrents.
Smith et al., 2000).
Second, the number of qualitative studies has increased sig-
nificantly over the last 15 years. This rise is in response to a
Disclosure as an ongoing process: Iterative and interactive in nature.
previous dearth of qualitative studies. Based on Jones's (2000)
Disclosure is now generally accepted as a complex and lifelong
observation that disclosure factors and outcomes had been well
process, with current trends showing that CSA disclosures are
documented through quantitative methods; in a widely read
too often delayed until adulthood (Collin-Vézina et al., 2015;
editorial, he recommended "Qualitative studies which are able
Easton, 2013; Hunter, 2011). Knowledge building about CSA
to track the individual experiences of children and their percep-
disclosure has moved in the direction of understanding this as
tion of the influences upon them which led to their disclosure of
an iterative and interactive process rather than a discrete, one-
information are needed to complement "
(p. 270).
time event. Since the new millennium, disclosure is being
Third, although a few studies strived to obtain representative
viewed as a dynamic, rather than static, process and described
samples in quantitative investigations (Hershkowitz, Horowitz,
"not as a single event but rather a carefully measured process"
& Lamb, 2005; Kogan, 2004; Smith et al., 2000), sampling was
(Alaggia, 2005, p. 455). The catalyst for this view originates
for the most part convenience based, relying on voluntary par-
from Summit (1983) who initially conceptualized CSA disclo-
ticipation in surveys and consent-based participation in file
sures as process based, although this notion was not fully
reviews (Collings, Griffiths, & Kumalo, 2005; Priebe & Sve-
explored until several years later. Examinations of Summit's
din, 2008; Schönbucher et al., 2012; Ungar, Barter, McConnell,
(1983) groundbreaking proposition of the CSA accommodation
Tutty, & Fairholm, 2009a). Therefore, generalizability of find-
(CSAA) model produced varying results as to whether his five
ings is understandably limited. The qualitative studies used
stages of secrecy, helplessness, entrapment and accommoda-
purposive sampling as is deemed appropriate for transferability
tion, delayed, conflicted, and unconvincing disclosures, and
of findings to similar populations. Some of those samples con-
retraction or recantation, hold validity (for a review, see Lon-
tained unique characteristics, since they were sought through
don, Bruck, Ceci, & Shuman, 2005). However, the idea of
counseling centers or sexual advocacy groups. These would be
disclosure as a process has been carried over into contemporary
considered clinical samples producing results based on disclo-
thinking.
sures that may have been delayed or problematic. This might
Recently, McElvaney, Greene, and Hogan (2012) detailed a
presumably produce data skewed toward barriers and bring
process model of disclosure wherein they describe an interac-
forward less information on disclosure facilitators.
tion of internal factors with external motivators which they
Through an in-depth, second-level analysis, this review
liken to a "pressure cooker" effect, preceded by a period of
identified five distinct themes and subthemes beyond the gen-
containment of the secret. Moreover, this and other studies
eral trends as noted earlier.
strongly suggest disclosures are more likely to occur within a
dialogical context-activated by discussions of abuse or pre-
Theme 1: Disclosure is viewed as an ongoing process as
vention forums providing information about sexual abuse
opposed to a discrete event-iterative and interactive in
(Hershkowitz et al., 2005; Jensen, Gulbrandsen, Mossige,
nature. A subtheme was identified regarding disclosure as
Reichelt, & Tjersland, 2005; Ungar et al., 2009a). The term
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277
dialogical simply means to participate in dialogue. Key dialo-
In terms of environmental factors, one study revealed that
gical vehicles identified in these studies were providing sexual
neighborhood/community conditions can hinder disclosure
abuse information through prevention programs, being asked
when there is lack of school involvement in providing a sup-
about sexual abuse, and being prompted to tell (McElvaney
portive environment, such as in following up on troubling stu-
et al., 2012; Ungar et al., 2009a).
dent behavior (Alaggia, 2010). Additionally, a child victim's
anticipation of a negative response to disclosure, especially that
they may not be believed by others outside their family such as
Contemporary models of CSA disclosure reflect a social-ecological
neighbors or other community members, has shown to deter
perspective. Knowledge on CSA disclosure has been steadily
disclosure (Collin-Vézina et al., 2015).
advancing toward a holistic understanding of the complex
Cultural factors influencing CSA disclosure have been stud-
interplay of individual, familial, contextual, and cultural fac-
ied to a much lesser degree. Despite this, a few important
tors (Alaggia & Kirshenbaum, 2005; Brazelton, 2015; Fontes
studies examining critical sociocultural factors now exist for
& Plummer, 2010). Where at one time factors examined and
better understanding CSA disclosure within a cultural context
identified were predominantly of intrapersonal factors of child
(Brazelton, 2015; Fontes & Plummer, 2010). Among these
victims, knowledge construction has shifted to fuller social-
important contributions, Brazelton's (2015) research has deli-
ecological, person-in-environment explanations (Alaggia,
neated CSA disclosure processes as "shaped by relational,
2010; Collin-Vézina et al., 2015; Easton et al., 2014; Hunter,
racial, socio-cultural, historical, and developmental factors"
2011; Ungar, Tutty, McConnell, Barter, & Fairholm, 2009b).
(p. 182). In a unique study using culturally focused research
Social-ecological explanations open up more opportunities to
literature as data triangulated with clinical case material, cul-
intervene in facilitating earlier disclosures. Alaggia (2010) pro-
turally based belief systems in many cultures have been found
poses an ecological mapping of what individual, interpersonal,
to foster family climates that can silence children from disclos-
environmental, and contextual influences impede or promote
ing abuse (Fontes & Plummer, 2010). Taboos about sexuality,
CSA disclosures based on analysis of in-depth interview data of
patriarchal attitudes, and devaluation of women are among
40 adult survivors. Subsequently, based on a sample of 67 adult
some of the cultural barriers that inhibit disclosure (Fontes &
survivors, Collin-Vézina, Sablonni, Palmer, and Milne (2015)
Plummer, 2010).
identified three broad categories, closely aligned with an eco-
Clearly, disclosure conceptualizations are being integrated
logical framework that impede CSA disclosure: (1) barriers
into a social-ecological model of individual and developmental
from within, (2) barriers in relation to others, and (3) barriers
factors, family dynamics, neighborhood, and community con-
in relation to the social world which can be aligned to intra-
text as well as cultural and societal attitudes toward better
personal, interpersonal, and contextual factors.
understanding disclosure barriers and facilitators (Alaggia,
A summary of knowledge building using a social-ecologi-
2010), although more data are needed on cultural and contex-
cal framework follows. Knowledge gained in the intrapersonal
tual factors.
domain includes expanded conceptualization of disclosure by
building on previous categories of accidental, purposeful, and
Age and gender as predictors of disclosure
prompted disclosure to also include behavioral and indirect
Age. Age is consistently found to be an influential factor in
attempts to tell, intentionally withheld disclosure, and triggered
CSA disclosure, making the life stage of the victim/survivor a
and recovered memories (Alaggia, 2004). Categories of indi-
critical consideration. Studies draw distinctions in age-groups
rect behavioral disclosure patterns have been further verified in
falling into either under or over 18 years of age. Eighteen years
follow-up research by Hunter (2011), and through an extensive
of age was the common age cutoff point that investigators chose
file review that used Alaggia's (2004) disclosure framework to
in order to distinguish child/youth populations from adult sam-
analyze their data (Collings et al., 2005) for verification.
ples. Sixteen of the studies drew on samples of children and
Interpersonal factors have also emerged in regard to certain
youth, while the other 15 studies sampled adults over the age
family characteristics as disclosure barriers. Families with
of 18, and a further two studies used mixed age-groups (refer to
rigidly fixed gender roles, patriarchal attitudes, power imbal-
Table 1). Among the child and youth samples, the age ranges
ances, other forms of child abuse and domestic violence, chao-
spanned from preschool to late adolescence (3-17 years of age),
tic family structure, dysfunctional communication, and social
with varying methodological approaches implemented across
isolation have been found to suppress disclosure (Alaggia &
age cohorts. For younger cohorts, file reviews and secondary
Kirshenbaum, 2005; Collin-Vézina et al., 2015; Fontes &
data analyses of CSA reports were typically undertaken. Ado-
Plummer, 2010). In addition, relationship with perpetrator is
lescents were most often given surveys. Sometimes children and
a factor whereby research indicates that disclosure is made
youth were interviewed as part of administering a survey or as a
more difficult when the perpetrator is a family member or close
follow-up (Crisma et al., 2004; Hershkowitz et al., 2005; Ungar
to the family (Dumont, Messerschmitt, Vila, Bohu, & Rey-
et al., 2009b). In the majority of child and adolescent samples,
Salmon, 2014;Easton, 2013; Goodman-Brown et al., 2003;
sexual abuse concerns were already flagged to investigative
Hershkowitz et al., 2005; Priebe & Svedin, 2008; Schönbucher
authorities. However, the work of Ungar, Barter, McConnell,
et al., 2012). This is especially a barrier when the perpetrator
Tutty, and Fairholm (2009a, 2009b) is one exception, whereby
lives with the victim (LeClerc & Wortley, 2015).
their survey elicited new disclosures.
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TRAUMA, VIOLENCE, & ABUSE 20(2)
Adult studies typically had a mean age between 40 and 50
for the abuse, resulting in no disclosure. Male participants in a
years. Interviews were the main data collection method with a
subsequent study also relayed that gender norms and stereotypes
few exceptions using survey designs (i.e., Easton, 2013; Kogan,
contributed to them concealing the abuse because they were
2004; Smith et al., 2000) and case file reviews (i.e., Collings
abused by a woman (Gagnier & Collin-Vézina, 2016). In the one
et al., 2005; Goodman-Brown et al., 2003). Results show a clear
study that compared male and female disclosures, investigator
trend toward increased likelihood of disclosure in older youth,
found that men's fears of being viewed as homosexual; profound
and findings from adult samples showing a preponderance of
feelings of stigmatization or isolation because of the belief that
disclosures in adulthood, with the large majority of participants
boys are rarely victimized; and fear of becoming an abuser acted
of adults reporting never having had a sexual abuse complaint
as disclosure barriers. Whereas females felt more conflicted about
filed with investigative authorities as a child or an adolescent
who was responsible for the abuse and more strongly anticipated
(i.e., Hunter, 2011; Gagnier & Collin-Vézina, 2016; Sorsoli,
being blamed and not believed (Alaggia, 2005).
Kia-Keating, & Grossman, 2008; Ungar et al., 2009b).
With children and youth under the ages of 18 distinct
Lack of a life-course perspective. Given that the study of CSA
patterns emerged. First, accidental detection, rather than
disclosure draws on age-groups ranging from samples of very
purposeful disclosure, is more likely to occur with younger
young children to retrospective studies of adult survivors, with
children. For example, in one large-scale study of over
significant developmental considerations, this area of study
1,737 file reviews, over half of the CSA-related cases were
lacks an intentional cohesive life-course perspective. Most data
identified through accidental and eyewitness detection (61%),
are derived from either cross-sectional or retrospective designs,
while less than one third were purposeful disclosures initiated
with few longitudinal studies. There are a series of sound, yet
by the child victim (Collings et al., 2005). A second pattern
disconnected, studies focusing on specific age-groups of chil-
which emerged is that rates of disclosure increase with age,
dren and adolescents, along with adult retrospective studies.
especially into adulthood, which is supported by persistent
Thus, the available knowledge base does not allow for a cohe-
findings of high rates of delayed disclosure reported later
sive picture of CSA disclosure processes and pathways over the
in the life course by adult survivors (Collings et al., 2005;
life course to emerge.
Collin-Vézina et al., 2015 Easton, 2013; Jonzon & Linblad,
The life-course perspective has long been recommended as
2004; Kogan, 2004; Leclerc & Wortley, 2015; Sorsoli et al.,
a critical lens for the study of child abuse (Browning & Lau-
2008). While gender and relationship with the perpetrator are
mann, 1997; Williams, 2003). For example, a life-course per-
considerable factors in CSA disclosure, age is consistently a
spective has been utilized to understand the immediate- and
stronger predictor of disclosure (or nondisclosure) (Hershko-
long-term effects of CSA on the developing child victim
witz et al., 2005; Leclerc & Wortley, 2015). Third, younger
(Browning & Laumann, 1997). Further, a life-course perspec-
children who disclose are more likely to do so in an interview
tive is important in terms of examining age of onset of CSA to
situation or other environment that provides prompts or
explain the differential effects of sexual victimization and
questions about sexual abuse (Hershkowitz et al., 2005;
developmental impacts in terms of understanding their ability
McElvaney, Greene, & Hogan, 2014; Schaeffer et al.,
to disclose-effects that need to be understood within a devel-
2011), but this trend can also be seen in older youth (Ungar
opmental context, especially for designing appropriate inter-
et al., 2009a, 2009b).
ventions for disclosure at critical transitions from early
childhood through to adolescence and into adulthood. In addi-
Gender. A number of studies have recently focused on CSA
tion, important "turning points" in life may facilitate disclo-
disclosures with male victims, since males have been an under-
sures. For example, entry into adulthood given that delayed
studied population (Alaggia, 2005; Easton, 2013; Easton et al.,
disclosure occurs more often in adulthood. Alaggia (2004,
2014; Gagnier & Collin-Vézina, 2016). Most investigations
2005) found that being in a committed relationship or the birth
that sampled both sexes show females outweighing male parti-
of children acted as facilitators for some survivors to disclose,
cipants. Although women are at double the risk of being sub-
especially to their spouses. These significant life events, as
jected to CSA, the ratio of women to men in most disclosure
contributing to disclosures, bear further examination.
studies has not been representative. This finding may be indi-
cative of male victims more likely delaying disclosing their
Summary of barriers and facilitators. Research over the past 15
CSA experiences, leaving male disclosure in child and youth
years continues to uncover barriers to CSA disclosure at a
samples underrepresented (Hébert, Tourigny, Cyr, McDuff, &
higher frequency than that of facilitators. As stated previously,
Joly, 2009; Ungar et al., 2009b).
this might be the result of sampling methods whereby partici-
Easton, Saltzman, and Willis (2014) have been developing
pants who volunteer for disclosure research may have had more
gender-specific modeling of disclosure examining male disclo-
negative disclosure experiences, especially since many report
sures. Their proposed model groups male disclosures into barrier
delays in disclosure. The following section outlines the major
categories as determined by individual factors, interpersonal
trends in both barriers and facilitators (see Table 2).
issues, and factors that are sociopolitical in nature. These authors
suggest that predominant gender norms around masculinity rein-
Barriers. Age and gender were found to contribute to barriers
force the tendency for male victims of CSA to blame themselves
as covered in Theme 3. Disclosures generally increase with age
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Alaggia et al.
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Table 2. Factors Influencing Child Sexual Abuse Disclosures.
Barriers
Facilitators
Age: The younger the child victim, the less likely they will purposefully
Age: Disclosures increase with age, especially in adulthood.
disclose.
Gender: Males may be less likely to disclose in childhood/adolescence,
Gender: Slight trend toward females who are older (adolescent) to
fear of being seen as homosexual and as a victim, females experience
disclose before adulthood
more self blame and anticipation of being blamed and/or not
believed
Relationship to perpetrator: If the perpetrator is a family member or in
Relationship to perpetrator: If the perpetrator is not living with the
a family like role, disclosure is less likely to happen
victim, disclosure rates increase
Internal: Shame, self blame, and fear are psychological barriers. In
Dialogical context: Opportunities to disclose through discussion,
addition, fear of negative consequences on the family and for self
therapeutic relationship, information sessions on sexuality, and
safety inhibits disclosure
sexual abuse prevention programs
Family relations: Families with a patriarchal structure, rigidly fixed
Family relations: Supportive parent-child relationship.
gender roles, dysfunctional communication, other forms of abuse
Involvement of others: Eyewitnesses coming forward and reporting:
(i.e., domestic violence), and isolation inhibit disclosure
detection through community members, professionals
Environmental and cultural context: Lack of discussion about sexuality;
Environmental and cultural context: Promotion of open discussion of
passive acceptance that unwanted sexual experiences are inevitable;
sexuality; community member involvement
not wanting to bring shame to the family by admitting sexual abuse;
lack of involvement from neighbors, school personnel; and stigma
perpetuated by societal perceptions
as children gain more developmental capacity, understanding
between men and women, parents and children, presence of
of sexual abuse as victimization, and increased independence.
other forms of child abuse and/or domestic violence, chaotic
Males are somewhat less likely to disclose, but this is often in
family structure, dysfunctional communication, and social iso-
interaction with other factors in the environment such as soci-
lation have been found to suppress disclosure (Alaggia & Kir-
etal attitudes that promote hypermasculinity as desirable, atti-
shenbaum, 2005; Collin-Vézina et al., 2015; Fontes &
tudes that perpetuate negative views of boys and men who are
Plummer, 2010). In regard to broader environmental factors,
victims, and homophobic attitudes (Alaggia, 2010; Easton
disclosure can be hindered when involved and supportive com-
et al., 2014; Gagnier & Collin-Vézina, 2016).
munity members are not available, or not trained in sensitive
Victims of intrafamilial abuse when the offender is a parent,
responses, or when child victims anticipate not being believed
caregiver, significant family member, or someone in a family-
by neighbors and other people outside the family (Alaggia,
like role are less likely to disclose immediately or at all in
2010; Collin-Vézina et al., 2015). Further, barriers in relation
childhood/adolescence because of obvious power differentials
to the social world were identified as stigmatization, the neg-
and dependency needs (Collings et al., 2005; Dumont et al.,
ative labeling of sexual abuse victims, and taboos surrounding
2014; Hershkowitz et al., 2005; Kogan, 2004; Leclerc & Wort-
sexuality and talking about sex as driven by cultural norms
ley, 2015; Paine & Hansen, 2002; Schaeffer et al., 2011).
(Collin-Vézina et al., 2015; Fontes & Plummer, 2010).
Further, the perpetrator residing with their victim(s)
Identification of cultural barriers is important recent contri-
increases the likelihood of no disclosure (Leclerc & Wortley,
bution to understanding disclosure processes-and in particular
2015).
to the obstacles. Findings related to cultural barriers included
Internalized victim-blaming, mechanisms to protect oneself
themes of children's voices not being heard leading to silen-
(such as minimizing the impact of the abuse), and developmen-
cing, the normalization of the sexualization and objectification
tal immaturity at the onset of abuse constituted internal bar-
of girls and women, and the perpetuation of hypermasculinity
riers. Further, shame, self-blame, and fear have been identified
in men-all acting as barriers in terms of stigma to disclosure
as significant factors deterring disclosure (Collin-Vézina et al.,
(Alaggia, 2005, 2010; Easton et al., 2014). Brazelton (2015)
2015; Crisma et al., 2004; Goodman-Brown et al., 2003; Hun-
similarly found that lack of discussions about sex, young age at
ter, 2011; Kogan, 2004; McElvaney & Culhane, 2015; McEl-
the onset of sexual abuse, therefore not having the language to
vaney et al., 2014). However, aspects of shame, self-blame and
express what was happening to them, and preserving the family
fear, and have not been fully explored in research. Since these
good name by not talking about abuse in the family were also
are strong predictors of disclosure suppression, they bear fur-
barriers to disclosure.
ther examination in future research to understand more fully
Finally, it may be the case that more barriers continue to be
how they operate in disclosure processes.
identified over facilitators of CSA disclosure perhaps because
In terms of interpersonal and environmental factors, family
of the methods employed in studies-particularly those draw-
dynamics can play a part in deterring disclosure. As previously
ing on adult populations who delayed disclosure. These sam-
mentioned, families characterized by rigidly defined gender
ples may not be representative of the overall population of CSA
roles, patriarchal attitudes that perpetuate power imbalances
victims, since they may have had more negative disclosure
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TRAUMA, VIOLENCE, & ABUSE 20(2)
experiences, consequently more readily identifying barriers.
(3) age and gender are significant disclosure factors; (4) there
On the other hand, these findings may speak to the actual
is a lack of a life-course perspective; and (5) barriers to disclo-
imbalance between facilitating factors and barriers for disclo-
sure continue to outweigh facilitators. Based on these themes, a
sure, the latter carrying more weight in the victims/survivors'
number of conclusions are drawn from this review. First, dis-
experiences, thus, explaining the high rates of disclosures
closure as a process is emphasized throughout contemporary
delayed until adulthood.
research. Advances have been made in understanding these
complex processes. However, the disclosure process over
Facilitators. Although fewer disclosure facilitators are identi-
time-for example, how the first detection of CSA or attempts
fied in this review, very important facilitators were nonetheless
to disclose in childhood impact later disclosures-are not well
uncovered-ones that should be noted for professionals in this
understood. This is the result of the absence of a cohesive life-
field of practice. Internal factors that facilitate disclosures
course perspective in investigations, although age consistently
include symptoms that become unbearable, getting older with
surfaces as significantly influencing CSA disclosure. Using a
increased developmental efficacy, and realizing that an offence
life-course perspective through the use of longitudinal studies
was committed (Collin-Vézina et al., 2015; Crisma et al., 2004;
is recommended
Easton, 2013; Hershkowitz et al. 2007; McElavaney, Greene,
The use of varied methodological designs, depending on the
& Hogan, 2014; Schaeffer et al., 2011). Circumstantial facil-
itators are those where the child discloses because there has
developmental stage of the victims/survivors, influences the
data generated and subsequent findings. For example, most
been evidence provided, eye-witnessing has occurred, and a
studies on children and youth are based on file reviews of cases
report has been made. Environmental factors include settings
that provide opportunities such as counseling, interviews,
that have been brought to the attention of authorities, or sur-
veys, with only a few studies using interviewing of younger
information sessions and educational forums/workshops, and
children. Therefore, there is less information available on pro-
prevention programs for children and youth to disclose.
cess issues with children and youth. In contrast, research on
To elaborate, dialogical contexts about CSA for children
adult populations largely favors the use of qualitative interview
and youth can provide opportunities for discussion that may
methods for retrospective inquiry producing important process
facilitate disclosures (Jensen et al., 2005). The research shows
findings. In addition, investigations have not yet captured the
creating open dialogue in relationship contexts, to offset the
disclosure experiences of adults in the "emerging adult" stage
power and influence of the perpetrator, can facilitate earlier
given that adult studies have failed to recognized that the age
disclosure. Among disclosure facilitators is being asked about
range of 18-24, which is now considered a developmental
abuse and given the opportunity to "tell" (McElavaney et al.,
phase defined by neurobiological developmental uniqueness.
2014); workshops on abuse and sexual abuse, in particular, can
As well, late adulthood has not been given attention as shown
facilitate disclosures (Ungar et al., 2009b); and using culturally
by the absence of participants representing this age-group in
sensitive probes and questions (Fontes & Plummer, 2010). In
Gagnier and Collin-Vézina's (2016) study, positive disclosure
current research (70+). With a swelling geriatric population in
North America, issues of historic CSA can be expected to
experiences were described by participants as those where they
surface and, with that, new disclosures. This trend is also antici-
felt that they had been listened to, were safe, were believed, and
pated due to attitudinal shifts that have presumably occurred
were not judged by the person they disclosed to. Further, family
over the last two generations about revealing such traumas and
members and friends (peers) of the child victim can act as key
supports to creating an open relational context and fostering
changing views about discussing sexual victimization.
Interview guides used in a number of studies intentionally
positive responses (Jensen et al., 2005; Priebe & Svedin, 2008;
probed for facilitators, producing notable findings. For exam-
Schönbucher et al., 2012; Ungar et al., 2009b). In particular, as
children grow older, they are more likely to disclose to a peer,
ple, one such finding focuses on the importance of creating a
contextually supportive environment to promote disclosure
as shown in a number of studies, and this is an important reality
for counselors and educators to be aware of (Dumont et al.,
across the life course. These include developing therapeutic
relational contexts for disclosure by providing information
2014; Kogan, 2004; Schönbucher et al., 2012; Ungar et al.,
about sexuality, sexual abuse, prevention programming, and
2009b).
by asking directly. Disclosures to professionals are positive
outcomes of how therapeutic contexts work; however, for for-
Discussion
ensic purposes prompting such disclosures would be viewed as
problematic in legal settings, seriously compromising testimo-
Through examination of 33 studies published since the year
nies for trial proceedings. This is one example that speaks to the
2000, this review identified five distinct themes regarding CSA
structural barriers victims and survivors run up against time and
disclosure: (1) Disclosure is best viewed as an iterative,
time again. Facilitators that show evidence to promote disclo-
interactive process rather than a discrete event done within
sure in one domain (therapeutic) are seen to work against CSA
a relational context; (2) contemporary models reflect a
survivors in another domain-such as legal settings when per-
social-ecological, person-in-environment framework for
petrators face prosecution. Defense attorneys will use this as
understanding the complex interplay of individual, familial,
evidence that the disclosure was prompted, and therefore the
contextual, and cultural factors involved in CSA disclosure;
disclosure is potentially seen as not credible. Broadcasting of
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281
the frequency of acquitted cases or rulings in favor of the
survivors continue to be systemically and structurally
perpetrator through media outlets, often sensationalized,
disadvantaged in legal proceedings.
become a further compounding barrier. Given the review find-
Health-care practitioners (i.e., child abuse pediatricians,
ings, we conclude that barriers and facilitators to CSA disclo-
family practice doctors, clinical nurse specialists, and
sures are nuanced and clearly embedded within intrapersonal,
public health nurses) should be made aware of the evi-
interpersonal, environmental, contextual, and cultural
dence in the CSA disclosure literature to create environ-
domains-often interlocked in complex ways.
ments for facilitating therapeutic disclosures.
Given that age is a stable predictor of disclosure of CSA,
more studies are needed that make use of a life-course
Limitations
perspective. More longitudinal studies are needed to
better identify trends over different life stages.
Although comprehensive in nature with its life-course cover-
The emerging young adult as a developmental age group
age, this review may be limited by its qualitative, thematic
needs specific investigation. Neuroscience research has
focus rather than providing an evaluative, quantitative account-
established that ages 18-24 is a distinct developmental
ing of CSA disclosures. However, because of the recent focus
phase. Late adulthood is another life stage that deserves
on disclosure processes, the authors chose a suitably compati-
to be researched.
ble approach-qualitative in nature. As well, a traditional
Gender needs to be more fully investigated in relation to
checklist approach in rating the studies was not employed for
impact on disclosure. Awareness that boys and girls
interrater reliability, since two of the authors hold expertise in
have unique challenges and barriers in disclosing CSA
CSA disclosure research and are well versed with the literature.
should be paramount for practitioners.
This expertise, and through closely following a systematic
Intervention planning should take note that disclosures
review framework (Kiteley & Stogdon, 2014), assures that a
increase when perpetrators no longer reside with vic-
thorough adjudication of the research literature was completed.
tims, and this finding should be heeded by policy and
law makers.
Shame, self-blame, and fear are intrapersonal factors
Implications for Research and Practice
that persistently emerge as barriers to CSA disclosures
These review findings have implications that can be useful in
and warrant more research to understand how to redress
guiding future research and practice:
these barriers for earlier disclosures.
Solid strides are being made in the use of a social-eco-
Conclusion
logical framework to underpin investigations in the CSA
disclosure investigations. Research efforts and practice
There are still a substantial number of children and youth
considerations should continue in this vein. Investigat-
who are subjected to sexual abuse, despite preventative
ing environmental factors and contextual and cultural
efforts. Just as concerning is the fact that many victims
forces is understudied, necessitating more research in
continue to suffer in silence as evidenced by the high num-
these areas to more fully fill out understanding of CSA
bers of delayed disclosure. These hidden cases should not be
disclosure from a social-ecological perspective.
overlooked, and these victims should not be forgotten.
There is good evidence that CSA disclosures are more
Despite significant progress in bringing the issue of CSA
likely to occur in a dialogical context-formal helping
to the forefront, improving facilitation of disclosure and
relationships but as well as other relationships such as
increasing positive influences on disclosure processes are
peers and trusted adults. Providing information and edu-
still critical in order to protect current and future genera-
cation on topics of sexuality in general, and sexual abuse
tions of children and youth from the grave effects of sexual
specifically, can help children and youth to disclose.
violence. Further, the focus should not be simply on
Raising awareness and prevention programs can pro-
strengthening and shoring up intrapersonal resources of vic-
mote disclosures of sexual violence committed against
tims to disclose but rather to change environmental condi-
children and youth.
tions to create a more supportive and safer context for CSA
Goals of therapeutically supported disclosures (i.e.,
victims and survivors to disclose.
through therapy) may need to take precedence over for-
ensic approaches, if well-being of child victims and
Declaration of Conflicting Interests
adult survivors is to be made paramount. Legal pro-
The author(s) declared no potential conflicts of interest with
cesses may act to facilitate disclosures but can also act
respect to the research, authorship, and/or publication of this
as barriers because of the negative outcomes experi-
article.
enced in the court process.
Practitioners need to keep in mind that the legal system
Funding
is lagging far behind in knowledge uptake of recent
The author(s) received no financial support for the research, author
evidence on CSA disclosures so that victims and
ship, and/or publication of this article.
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282
TRAUMA, VIOLENCE, & ABUSE 20(2)
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University of Toronto.
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Child Abuse Review Vol. 24: 159-169 (2015)
Published online 9 May 2015 in Wiley Online Library
(wileyonlinelibrary.com) DOI: 10.1002/car.2280
Disclosure of Child
Rosaleen McElvaney
School of Nursing and Human
Sexual Abuse: Delays,
Sciences, Dublin City University,
Dublin, Ireland
Non-disclosure and
Partial Disclosure. What
the Research Tells Us and
Implications for Practice
This paper reviews the research on disclosure of child sexual abuse with specific reference
to delays in disclosing, non-disclosure and partial disclosure of experiences of child sexual
abuse. Findings from large-scale national probability studies highlight the prevalence of
both non-disclosure and delays in disclosure, while findings from small-scale qualitative
studies portray the complexity, diversity and individuality of experiences. The possible
explanations regarding why children are reluctant to disclose such experiences have
significant implications for addressing the issue of child sexual abuse from the perspectives
of child protection, legal and therapeutic professionals. The importance of understanding
'The importance of
the dynamics of disclosure, in particular the needs of young people to maintain control over
the disclosure process, the important role that peers play in this process, the responses
understanding the
of adults in both informal and formal networks, and the opportunities to tell, is key to
dynamics of
helping young people speak more promptly about their experiences of sexual abuse.
Copyright © 2013 John Wiley & Sons, Ltd.
disclosure'
KEY PRACTITIONER MESSAGES:
Children typically delay disclosing experiences of abuse.
Asking children questions about their wellbeing gives them the opportunity to tell
when they are ready.
The challenge is to find the right questions at the right time.
Peers can be the right people to ask these questions.
Adolescents need to know about how to ask and what to do if someone tells.
'Adolescents need to
know about how to
KEY WORDS: child sex abuse; disclosure; research to practice
ask and what to do if
someone tells'
A
n issue of increasing concern in recent years is the phenomenon of
delayed disclosure of childhood sexual abuse and the need to understand
the process of how children and adults disclose their experiences of child
sexual abuse, given the implications for child protection, social justice and
*Correspondence to: Rosaleen McElvaney, School of Nursing and Human Sciences, Dublin City University,
Glasnevin, Dublin 9, Ireland. E-mail: rosaleen.mcelvaney@dcu.ie
Copyright © 2013 John Wiley & Sons, Ltd.
Accepted: 17 February 2013
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=== Page 27 ===
160
McElvaney
mental health outcomes. This paper reviews the research on disclosure patterns
'This paper reviews
of childhood sexual abuse, specifically delays in disclosure, non-disclosure
the research on
(as evident through adult retrospective studies) and partial disclosures, and
disclosure patterns of
discusses implications for practice. Literature searches of the online databases
PSYCINFO and Social Sciences Citation Index, in addition to manual searches
childhood sexual
of texts published since 2000, were conducted using the search terms "child
abuse'
sexual abuse', 'sex abuse' and 'disclosure'.
The research to date on disclosure patterns is based on two sampling
methodologies - studies of adults reporting retrospective experiences and
studies of children. The former group of studies has the benefit of drawing
on large-scale national probability samples which can be considered to be
representative of the general population. The latter group with some small
exceptions (predominantly adolescent studies) uses samples of young people
who have disclosed sexual abuse but would not be considered as representative
of all children who have been abused:
"children who decide to tell someone about being sexually abused and whose
cases therefore come to court are not representative of sexually abused children in general'
(Olafson and Lederman, 2006, p. 29).
Patterns of Disclosure: Delays and Non-disclosure
There is consensus in the research literature that most people who experience
'Most people who
sexual abuse in childhood do not disclose this abuse until adulthood, and when
experience sexual
disclosure does occur in childhood, significant delays are common. Table 1
summarises two large-scale studies to highlight the extent of delays in disclosure
abuse in childhood do
and the percentage of those who did not disclose to anyone prior to the study.
not disclose this
Kogan (2004) examined the timing of disclosure of unwanted sexual
abuse until adulthood'
experiences in childhood or adolescence in a sub-sample (n = 263 adolescent
women, aged 12 to 17) of the National Survey of Adolescents (Kilpatrick and
Saunders, 1995) in the USA - a nationally representative study. Kogan's
results can be summarised as follows: immediate disclosure (within 1 month)
43 per cent, delayed disclosure (less than 1 year) 31 per cent and non-disclosure
(disclosed only during the survey) 26 per cent. Smith and colleagues (2000)
examined a sub-sample (n = 288) of the National Women's Study in the
USA (Resnick et al., 1993, cited in Smith et al., 2000) who had reported a
childhood rape prior to the age of 18. Smith et al.'s findings can be
summarised as follows: immediate disclosure (within 1 month) 27 per cent,
delayed disclosure (more than a year) 58 per cent and non-disclosure (survey
only) 28 per cent. Those who had never disclosed prior to the survey constitute
comparable proportions in these two studies while the rates for immediate
Table 1. Patterns of disclosure delay and non-disclosure
Kogan (2004)
Smith et al. (2000)
(n 263 adolescents)
(n 288 adults)
Told within 24 hours
24%
18%
Told within 1 month
19%
9%
Told within 1 year
12%
11%
Delayed telling more than 1 year
19%
47%
Never told before survey
26%
28%
Copyright © 2013 John Wiley & Sons, Ltd.
Child Abuse Rev. Vol. 24: 159 169 (2015)
DOI: 10.1002/car
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=== Page 28 ===
Disclosure Patterns in Child Sexual Abuse
161
disclosure are higher in the adolescent study than in the adult study, a
'The rates for
reassuring finding given the increased awareness of sexual abuse in society
immediate disclosure
during the past 20 years.
Goodman-Brown and colleagues (2003) examined USA district attorney
are lower in the
files of 218 children. Their categories were slightly different from the previous
adolescent study than
two studies but in summary, immediate disclosers (within 1 month) constituted
in the adult study'
64 per cent of the sample while 29 per cent disclosed within six months.
This study is unusual insofar as the sample studied had reported their
experience of abuse to the authorities and a prosecution was in progress.
Goodman-Brown et al. also pointed out that families who participated in this
study were more likely to represent those children who experienced abuse by
someone outside the family. Research has found that delays in disclosure are
longer for those abused within the family (Sjoberg and Lindblad, 2002;
Goodman-Brown et al., 2003; Kogan, 2004; Hershkowitz et al., 2005).
Therefore, children who disclose more promptly may be overrepresented in
legal samples.
'Children who disclose
In Sweden, Priebe and Svedin (2008) conducted a national survey of 4339
more promptly may be
adolescents, of whom 1962 reported some form of sexual abuse (65% of girls
and 23% of boys). Details of the time lapse in disclosing were not available
overrepresented in
from this study. However, of those who had disclosed and answered the
legal samples'
questions on disclosure (n = 1493), 59.5 per cent had told no-one of their
experiences prior to the survey. Of those who did disclose, 80.5 per cent
mentioned a "friend of my own age' as the only person who they had told. In
this study, 6.8 per cent had reported their experiences to the social authorities
or police. A further Swedish study of 122 women who had experienced
childhood sexual abuse (Jonson and Lindblad, 2004) found that 32 per cent
disclosed during childhood (before the age of 18) while the majority told in
adulthood (68%). The delay was up to 49 years, with an average of 21 years
(SD = 12.9). Of those who told in childhood, 59 per cent told only one person.
In Ireland, the SAVI study (n = 3118, McGee et al., 2002) found that 47 per
cent of those respondents who had experienced some form of sexual assault
prior to age 17 had told no-one of this experience until the survey. McElvaney
(2002) investigated delay in a legal sample of ten adults who had made formal
complaints of childhood sexual abuse in Ireland and found delays ranging from
20 years to 50 years.
'Delays ranging from
Studies of children in the context of forensic/investigative interviews
20 years to 50 years'
where children are interviewed by professionals due to concerns that the
child has been sexually abused also point to high non-disclosure rates,
particularly striking in cases where there is corroborative evidence that
abuse has occurred - medical evidence (Lyon, 2007), or confessions from
the abuser or videotaped evidence/witness reports (Sjoberg and Lindblad,
2002). Lyon (2007) reported his findings from a review of studies
published between 1965 and 1993 of children diagnosed with gonorrhoea
where the average disclosure rate among 579 children was 43 per cent
(n = 250). In a study where the evidence for the abuse was available on videotape,
children have denied abuse when interviewed by the police (Sjoberg and
Lindblad, 2002).
In summary, significant numbers of children do not disclose experiences of
sexual abuse until adulthood and adult survey results suggest that significant
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proportions of adults have never disclosed such abuse, as evidenced by the
'High numbers of
high numbers of respondents disclosing to researchers for the first time.
respondents
Patterns of Disclosure - Partial Disclosure
disclosing to
researchers for the
Information on how children disclose over time can be obtained from studies
first time'
of children who participated in forensic/investigative interviews where
children are interviewed by professionals due to concerns that the child has
been sexually abused. The issue of partial disclosures was highlighted by
earlier studies such as those by DeVoe and Faller (1999) of five- to ten-year
olds (i.e. making detailed informal disclosures that were not replicated in
formal interviews) and Elliott and Briere (1994) of children aged eight to
15 years (i.e. disclosing only partial information until confronted with external
evidence that led to more complete disclosures).
More recently, investigators have examined the role of the interviewer and
questioning styles in the forensic interview and how this impacts on children's
disclosures and the level of detail provided in interview. Hershkowitz et al.
(2006) compared tapes of interviews with children who disclosed sexual abuse
and those who did not (but about whom there was 'substantial' reason to
believe that they had been abused). They found that interviewers behaved
'They found that
differently with the two groups, using different types of prompts with children
interviewers behaved
who presented as somewhat uncooperative, offered fewer details and gave
more uninformative responses at the beginning of the interview. It would
differently with the
appear that interviewers responded to less communicative children by
two groups'
increasing the proportion of closed questions which in turn led to children
being less forthcoming. Lamb et al. (2002) have found that the use of a
protocol that emphasises the use of prompts that elicit free narrative (e.g. 'tell
me about that') as compared with closed questions (those requiring a yes/no
response) has resulted in more detail and more accuracy in children's
accounts.
Although few studies exist that examine the phenomenon of disclosure in
informal settings (when disclosure is made to a friend or family member),
some qualitative studies have described this process. McElvaney (2008) quoted
one teenage girl who described hinting to her mother prior to disclosing the
experience: 'I didn't tell her what happened but I was saying things that made
'A parent described
her think it made her think that it happened but I didn't tell her' (p. 127). A
how her teenage son
parent described how her teenage son told her over a period of days, keeping
told her over a period of
the most difficult parts of the story until last:
days'
'He came out with like it came out over two or three days so you know he'd say well
I've something else to tell you. the bad stuff last. what hurt him most and what he's
saying what hurt him most' (p. 92)
And finally, one young person described how she told her social worker:
'I couldn't tell her most things but I just gave things to her to read I told her at first I told
her bits of it and em then just the others. I finished writing and then I gave them to her
later
I told her that it was the father as well.' (p. 93)
This young person had been abused by both a father and son in a family with
whom she was staying.
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163
In reviewing the literature on this subject, London and colleagues (2005)
noted, 'when children do disclose, it often takes them a long time to do so'
"When children do
(p. 204).
disclose, it often takes
them a long time to do
Reasons for Patterns of Delay, Partial Disclosure and Non-disclosure
so"
There are many influences on disclosure that have been identified in the
research literature to help explain why it is that children delay disclosure, are
reluctant to disclose, provide details of their experiences over time or do not
disclose at all. Age has been identified as a significant predictor of disclosure
in that younger children are less likely to disclose than older children. Children
'Younger children are
who are abused by a family member are less likely to disclose and more likely
less likely to disclose
to delay disclosure than those abused by someone outside the family (Smith
than older children'
et al., 2000; Goodman-Brown et al., 2003; Kogan, 2004). Children who do
disclose during forensic interviews compared to children who do not disclose
in such contexts (yet concerns remain that they have been abused) are more
likely to have parents (particularly mothers) who are more supportive (Lawson
and Chaffin, 1992). In Priebe and Svedin's (2008) study of young people,
parental bonding (positive relationship with parent who was not overprotective)
was identified as the most significant predictor of disclosure for both boys and
girls. However, close relationships can also act as an inhibitor to disclosure.
McElvaney (2008) found that many young people in her study were reluctant
'Many young people
to disclose due to concerns of upsetting their parents while others were concerned
in her study were
about the consequences for others of their disclosure. One 13-year-old girl
reluctant to disclose
described her concern that if she told, her uncle would go to jail and her small
cousins would be left without a father:
due to concerns of
upsetting their
'I didn't want them to grow up with no Dad and just looking at their other little friends
having their Dad holding their hand I felt like I was taking their Dad away from them' (p. 130)
parents'
Gender has been found to influence disclosure in that boys appear to be
more reluctant to disclose than girls (Goodman-Brown et al., 2003;
Hershkowitz et al., 2005; Ungar et al., 2009a). Mental health difficulties on
the part of the child have also been found to be relevant, particularly when
children experience dissociative symptoms or other post-traumatic stress
symptomatology (Priebe and Svedin, 2008).
Some studies have found that the severity of abuse (e.g. penetrative abuse)
predicts earlier disclosure while other studies have found no relationship
between different types of abuse and disclosure timing. Similarly, the relationship
between the duration of abuse - one-off incidents of abuse compared with abuse
that takes place over a significant period of time - and timely disclosure has been
investigated with mixed findings. Fear of the consequences of disclosure has been
'Fear of the
identified as a predictor of delayed disclosure and this in turn is associated with
consequences of
the age of the child (Goodman-Brown et al., 2003). Older children are more
disclosure has been
cognitively competent in terms of being able to reflect on and anticipate possible
reactions to their disclosure. This can act then as an inhibitor to disclosure,
identified as a
although as noted above, most studies have found that older children are more
predictor of delayed
likely to disclose than younger children. Fears of not being believed have been
disclosure'
described by young people as inhibiting their disclosure and these fears are often
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justified. Hershkowitz et al. (2007) interviewed children about their initial
disclosures prior to formal interview and 50 per cent of the sample (n = 30)
reported feeling afraid or ashamed of their parents' reaction. The authors reported
that parents did show a tendency to blame their children and react angrily to
the disclosure.
Recent research has highlighted the need for children to be asked direct
questions to facilitate their disclosure. Of those children who did disclose,
significant proportions disclosed following prompts rather than it being
initiated by the child (Kogan, 2004). Qualitative studies drawing on interviews
with children that focus on the disclosure process are important in
'Investigating the
investigating the precise circumstances that led to disclosures for children.
precise
McElvaney (2008) found that parents' questioning of children was prompted
circumstances that
by their concern about the young person's emotional distress. On occasion,
young people were communicating that something was not right in their world
led to disclosures for
but were not able to articulate this verbally. Signs of psychological distress
children'
were, however, evident and questions targeted at the reasons for this distress
were identified by McElvaney as a factor that helped young people to tell.
Thus, many children may not have told about their experiences of abuse
because they were not asked. McGee et al. (2002) followed up a sample of
their respondents who had disclosed childhood abuse for the first time in their
survey. When asked why they had not disclosed prior to the survey, many
respondents noted that it was because they had not been asked. Increasingly,
'Significant
research studies are finding that significant proportions of disclosure have
proportions of
been prompted by questions by caregivers, friends or others in the child's
disclosure have been
educational and social milieu that in themselves provide an opportunity for
the young person to tell (Jensen et al., 2005; Hershkowitz et al., 2007;
prompted by
McElvaney et al., 2012).
questions by
Finally, some children need time to tell. Mudaly and Goddard (2006) quote
caregivers, friends or
a 13-year-old girl: 'she (mother) helped by not making me, not rushing me
to get it out, which, um, I think it's a really stupid idea to make kids get it
others'
out A.S.A.P.' (p. 91).
Implications for Practice
The consensus in the research literature at the present time is that disclosure is
multi-determined, influenced by a complex range of factors that may influence
each child in a different way. Large-scale national probability studies confirm
that non-disclosure and delays in disclosure are significant problems facing
society and in particular for those professionals tasked with safeguarding the
wellbeing of children. Children's fears and anxieties in relation to telling need
to be understood and contained by those in their environment so that early
disclosure can be encouraged and facilitated.
'The implications of
The implications of these findings can be considered in interrelated
these findings can be
contexts: the legal context where action can only be taken if the child is able
considered in
to give a clear, credible account of his/her experiences; child protection and
therapeutic contexts where a comprehensive account is required to enable child
interrelated contexts'
protection professionals to intervene and where the psychological sequelae can
be addressed to minimise the long-term impact of the experiences; and family
and community contexts where early disclosure needs to be encouraged, and
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other family issues addressed in the aftermath of disclosure and where peers
play an important role.
Studies have confirmed the importance of professionals asking children and
young people in a sensitive, open manner about possible experiences of abuse
using non-leading questioning styles to minimise inaccurate accounts or
contaminate children's narratives. It is clearly important for professionals to
remain open to the possibility of abuse and further disclosure. It is equally
important for professionals to be able to avoid persisting with questioning
those children who are "reluctant disclosers'. Similarly, professionals engaged
with children in therapeutic work need to be open to the possibility of both
initial and further disclosures.
Contradiction in witness statements is a well-known feature of false statements
'Contradiction in
and giving additional detail to original formal statements can be interpreted
witness statements is
within child protection, therapeutic and legal contexts as a contradiction of an
earlier account. Listening to children's accounts of their experiences of disclosure
a well-known feature
helps us understand why it is that disclosure can be delayed and that when they do
of false statements'
feel ready to tell this is not an 'all or nothing' decision. As one young person in
Staller and Nelson-Gardell's (2005) study noted, 'it's never finished, never' p.
1426. This understanding in turn helps us identify those circumstances and
reactions that may encourage the child to disclose.
The importance of asking children questions, thus giving them an
opportunity to tell, has been identified. While parents, teachers and those in
daily contact with children are often reluctant to question children, it is clear
that many children do not disclose unless given this opportunity. Education
'Education and
and increased awareness are needed on how to question children in an
increased awareness
appropriate manner. McElvaney (2008) noted that questions did not need to
are needed on how to
be about sexual abuse per se, but rather questions prompted by the young
person's psychological distress, asking after the young people's wellbeing.
question children in
This questioning in effect acted as an external pressure for the young person
an appropriate
to tell his/her secret (McElvaney et al., 2012). In Ungar et al.'s (2009a) study
manner'
of Canadian youth, they found that young people used a range of disclosure
strategies ranging from less direct strategies (such as risk-taking behaviours,
not talking about the abuse) to direct strategies (such as seeking support from
peers, turning to non-professional adult supports, disclosing to formal service
providers), representing a process that relied heavily on others to "build the
bridges between the youth and formal care providers' (p. 352).
The tendency to delay disclosing and the partial nature of many disclosures
are not conducive to successful legal investigations and prosecutions. In
addition, the knowledge base that exists within the legal sphere is limited if
only a percentage of the children who experience sexual abuse engage with
this system. The disproportionately high "immediate disclosure' rate found
in Goodman-Brown et al.'s (2003) legal sample compared to Kogan's
(2004) community sample raises the question of the representation of delayed
disclosers in the legal system. Are children who delay in disclosing less likely
'Are children who
to engage with the legal system? Are delays in disclosing contributing to
delay in disclosing
decisions not to prosecute child sexual abuse crimes? In Ireland, the 1990s
saw a significant increase in the numbers of complainants coming before the
less likely to engage
courts reporting experiences of childhood sexual abuse. Many of these cases
with the legal system?'
were referred to the higher courts for judicial review proceedings to establish
whether the cases could proceed without prejudicing the accused given the
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delay in the complaint being made and giving due regard to the accused's right
to a speedy trial. Psychological expert testimony was sought as part of these
proceedings to explain the delay in disclosure in each individual case to enable
the courts to adjudicate on whether the delay in reporting was reasonable (see
McElvaney, 2002). This legal mechanism provided an opportunity to enhance
the knowledge base within the legal profession as to the complexities involved
in disclosing and formally reporting experiences of childhood sexual abuse for
adults. While one might expect that the legal system would be more
sympathetic to children's difficulties in making disclosures, it may also be
the case that the belief that 'if the child was really sexually abused, why would
they not tell?', as articulated by Summit (1983), still prevails.
'Concerns that
In addition, concerns that engagement with the legal system will lead to further
engagement with the
psychological trauma need to be considered. A prospective longitudinal study
legal system will lead
conducted by Quas et al. (2005) indicated that the consequences of legal
involvement change over the course of development and as a function of the
to further
child's reactions to and experiences during the legal case. The associations
psychological trauma
between legal involvement and outcomes varied with age. The authors
need to be considered'
suggested that although younger children may be at increased risk for some
adverse outcomes such as mental health problems, older children may be at
increased risk for other undesirable sequelae such as the negative attitudes
of others toward them. Quas and Goodman's (2011) recent review notes that
older children are more at risk in developing poor mental health outcomes.
Thus, as noted earlier, young people's fears of the consequences of disclosure
may well be justified. Raised awareness of both the prevalence of non-disclosure
of sexual abuse and the importance of supporting children to disclose may
go some way to addressing children's fears.
'Many young people
One interesting finding in recent studies is that many young people who
who delayed
delayed disclosure to an adult had told a friend. McElvaney (2008) and Ungar
et al. (2009b) identified peer influence as significant in encouraging disclosure
disclosure to an adult
among adolescents. There is some suggestion from the research that regardless
had told a friend'
of the age at the time of abuse, adolescence may be a 'critical period' for
disclosure. It may be that targeting adolescents in general (rather than those
at risk of abuse) may be a powerful prevention tool in encouraging early
disclosure. Evaluations of child abuse prevention programmes have shown
significant improvements in the levels of awareness of child abuse in children
and young people (Rispers et al., 1997; Zwi et al., 2007). It may be that the
increasing trend towards peer disclosure is a by-product of such educational
and awareness-raising programmes. There is evidence that public awareness
campaigns when implemented as part of a multi-dimensional strategy that
involves targeting children, parents and communities (see Lalor and McElvaney,
2010, for a review of child abuse prevention programmes) are an effective tool in
the prevention of child abuse.
McElvaney et al. (2012) describe the importance for young people of
containing the secret of abuse and their need for confidentiality following
'An adaptive strategy
disclosure as representing an adaptive strategy on the part of the young person
on the part of the
to contain the experience and his/her emotional reaction to it. The conflict
young person to
between wanting/needing to keep the secret and wanting/needing to tell is
mediated by what they term the "pressure cooker effect'. Young people in their
contain the experience'
study described influences from within and without that led to a build up of
pressure, ultimately leading to disclosure. They suggest that building up the
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Disclosure Patterns in Child Sexual Abuse
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pressure for young people by providing opportunities to tell may be needed to
help young people tell more promptly. However, the lack of control that young
people experience following disclosure remains an issue (Ungar et al., 2009b;
Quayle et al., 2012). This highlights the need for dissemination of information
directly to young people about the legal process, the possible consequences of
disclosure, as well as ongoing developments in legal proceedings when young
people and their families interface with the legal system.
The more recent focus on investigating those strategies that children use in
'More recent focus on
making disclosures rather than solely on identifying barriers to disclosure is
investigating those
perhaps more helpful in informing awareness-raising campaigns and
professional interventions. The author is involved in a large-scale review of
strategies that
children's files in an assessment service to ascertain those factors that helped
children use in
children tell about their experiences of sexual abuse. A pilot study has
making disclosures'
suggested that this is an appropriate methodology for gathering data on
children's experiences of informal disclosure, acknowledging the limitations
of such an approach. Ungar et al. (2009a) describe the optimal conditions for
disclosure as follows: being directly asked about experiences of abuse; having
access to someone who will listen, believe and respond appropriately; having
knowledge and language about what constitutes abuse and how to access help;
having a sense of control over the process of disclosure both in terms of their
'Having a sense of
anonymity (not being identified until they are ready for this) and confidentiality
control over the
(the right to control who knows); and effective responses by adults both in
informal and formal contexts.
process of disclosure
Ungar et al. (2009b) support recent developments in prevention programmes
both in terms of their
that target supportive formal and informal caregivers in being better able to
anonymity and
detect the possibility of abuse and support disclosures rather than focusing
on empowering children themselves in making disclosures. Their findings in
confidentiality'
relation to the importance of bridge building for young people to access formal
supports are supported by Jensen et al.'s (2005) emphasis on the dialogical
nature of disclosure, and the important role that trusted adults and peers play
in the disclosure process through noticing signs of psychological distress and
asking young people about their psychological wellbeing (Collings et al.,
2005; Jensen et al., 2005; McElvaney et al., 2012). More emphasis is therefore
needed on providing opportunities for children and young people to disclose.
The challenge for professionals and those who care for children is how to do
this in a way that protects children and promotes their wellbeing.
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EUROPEAN JOURNAL OF
CO..
PSYCHOTRAUMATOLOGY
action
PUBLISHING
CLINICAL RESEARCH ARTICLE
Predictors of delayed disclosure of rape in female
adolescents and young adults
Iva A. E. Bicanic¹*, Lieve M. Hehenkamp¹, Elise M. van de Putte²,
Arjen J. van Wijk³ and Ad de Jongh³,⁴
National Psychotraumacenter for Children and Youth, University Medical Center Utrecht, Utrecht
The Netherlands; 2Department of Paediatrics, University Medical Center Utrecht, Utrecht, The Netherlands;
³Department of Behavioral Sciences, ACTA, University of Amsterdam and VU University, Amsterdam,
The Netherlands; 4School of Health Sciences, Salford University, Manchester, United Kingdom
Background: Delayed disclosure of rape has been associated with impaired mental health; it is, therefore, important
to understand which factors are associated with disclosure latency. The purpose of this study was to compare
various demographics, post rape characteristics, and psychological functioning of early and delayed disclosers
(i.e., more than 1 week post rape) among rape victims, and to determine predictors for delayed disclosure.
Methods: Data were collected using a structured interview and validated questionnaires in a sample of 323
help seeking female adolescents and young adults (12 25 years), who were victimized by rape, but had no
reported prior chronic child sexual abuse.
Results: In 59% of the cases, disclosure occurred within 1 week. Delayed disclosers were less likely to use medical
services and to report to the police than early disclosers. No significant differences were found between delayed
and early disclosers in psychological functioning and time to seek professional help. The combination of
age category 12 17 years [odds ratio (OR) 2.05, confidence intervals (CI) 1.13 3.73], penetration (OR 2.36,
CI 1.25 4.46), and closeness to assailant (OR 2.64, CI 1.52 4.60) contributed significantly to the prediction
of delayed disclosure.
Conclusion: The results point to the need of targeted interventions that specifically encourage rape victims to
disclose early, thereby increasing options for access to health and police services.
Keywords: Adolescents; young adults; rape; sexual assault; disclosure; latency to disclosure; posttraumatic stress disorder
Responsible Editor: Rita Rosner, KU Eichstaett Ingolstadt, Germany.
*Correspondence to: Iva A. E. Bicanic, National Psychotrauma Center for Children and Youth,
University Medical Center Utrecht, P.O. Box 85090, NL 3508 AB Utrecht, The Netherlands,
Email: i.a.e.bicanic@umcutrecht.nl
For the abstract or full text in other languages, please see Supplementary files under 'Article Tools'
Received: 31 August 2014; Revised: 30 March 2015; Accepted: 13 April 2015; Published: 11 May 2015
revious studies have shown that disclosure of rape
groups (De Haas, Van Berlo, Bakker, & Vanwesenbeeck,
P
to formal agencies, such as police or mental health
2012; Tjaden & Thoennes, 2006), may not receive targeted
services, is uncommon (Fisher, Cullen, & Turner,
mental health care and may not report the crime to the
2000; Wolitzky-Taylor et al., 2011), especially when the
police (Ruch, Coyne, & Perrone, 2000).
rape has been committed on a date or by an acquaintance
For reasons of mental health and public safety, it is
and involves the victim's use of drugs and/or alcohol
important to understand the potential factors that are
(Resnick et al., 2000; Wolitzky-Taylor et al., 2011). There is
related to disclosure. Timing of disclosure may be a crucial
evidence to suggest that victims believe that professionals
factor, as early disclosers are more likely to utilize appro-
will not be helpful to them because their rape experience
priate medical care and report to the police than delayed
does not match stereotypical conceptions of rape, such
disclosers (Ahrens, Stansell, & Jennings, 2010; Ullman &
as involving a stranger, a weapon, and severe injury
Filipas, 2001). In contrast, adults who wait longer than
(Patterson, Greeson, & Campbell, 2009; Resnick et al.,
1 month to disclose the rape are more likely to suffer
2000). Accordingly, adolescents and young adults, who
from posttraumatic stress disorder (PTSD) and depres-
are more at risk to be victimized by rape than other age
sion compared to early disclosers (Ruggiero et al., 2004).
European Journal of Psychotraumatology 2015. c 2015 Iva A. E. Bicanic et al. This is an Open Access article distributed under the terms of the Creative Commons
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Iva A. E. Bicanic et al.
In addition, adolescents who disclose their rape experience
interventions that increase victims' opportunities to
at least I month after the incident took place are found
receive timely post-rape services.
to be at higher risk for major depressive disorder and
delinquency (Broman-Fulks et al., 2007) compared to those
Methods
who disclosed within 1 month.
Victim-assailant relationship is crucial in disclosure
Subjects and data collection
latency, with victims being at higher risk for delayed dis-
Rape was defined as "an event that occurred without the
closure if there is a close relation with the assailant (Kogan,
victim's consent that involved the use or threat of force in
2004; Koss, 1988; Rickert, Wiemann, & Vaughan, 2005).
vaginal, anal, or oral intercourse" (Tjaden & Thoennes,
In contrast, delayed disclosure is less common in victims
2006). The definition includes both attempted and com-
of a stereotypical rape, i.e., rape by a stranger including a
pleted rape; the term "completed" referring to vaginal,
weapon and injury (Smith et al., 2000). Victims of prior
oral, anal, or multiple penetrations. Victims who disclosed
sexual trauma are more likely to postpone disclosure of a
within 1 week were defined as "early disclosers," whereas
subsequent assault than those without prior victimization
those who disclosed at least after 1 week were defined as
(Smith et al., 2000; Ullman, 1996). This is in contrast with
"delayed disclosers." This dichotomization of the variable
the findings of Ahrens et al. (2010), who report no dif-
"disclosure latency" was based on the study of Ahrens
ference in rates of prior sexual trauma between early and
et al. (2010) and the national standard criteria for admis-
delayed disclosers. In addition, the victim's age appears
sion to a Rape Centre in the Netherlands, i.e., a maximum
to be an important variable in predicting disclosure.
of 7 days post-rape.
Evidence suggests that young children are at higher risk
The study was conducted in the Dutch National
for delayed disclosure than adolescents (Kogan, 2004;
Psychotrauma Centre, which provides psychological ser-
Schönbucher, Maier, Mohler-Kuo, Schnyder, & Landolt,
vices for rape victims aged 12-25 years and their parents.
2012). Thus, various rape and victim-related character-
Between May 2005 and December 2011, the centre re-
istics have been found to be associated with timing of
ceived 621 phone calls concerning alleged rape victims
disclosure.
from police authorities, mental health services, and self-
The majority of the aforementioned studies included
referrals. In 178 cases, the phone call did not result in
college and adult female rape victims. It is important to
admission at the centre because of age limitations, or
examine rape disclosure latency in an age and sex group
motivational reasons. In 108 cases, referrals were made to
that is most at risk for rape victimization. There is only
other institutions because the index trauma was chronic
one prior quantitative study in adolescents (those aged
childhood sexual abuse rather than rape in adolescence/
12-17 years) that identified factors that might influence
young adulthood. Of the 335 cases admitted to the centre,
disclosure latency (Kogan, 2004). He found that identity
12 were not included in this study because of male gender,
of the assailant, a familial relationship with the assailant,
resulting in a final sample of 323 females with the index
and a history of drug abuse in the household were related
trauma being single rape. Referral sources for this final
to the timing of disclosure. The results suggested that
sample included the police (33.7%), mental health services
a familial relationship with the assailant will postpone
(40.7%), and self-referrals, i.e., victims or parents (25.6%).
disclosure, whereas a history of drug abuse in the house-
hold, albeit this seems counterintuitive, makes prompt
Procedure
disclosure more likely. This study had some limitations,
During admission, all patients underwent a psychological
including the fact that the interviews were conducted by
assessment, consisting of 1) a structured interview for
telephone and that the description of the relationship with
obtaining demographic and post-rape characteristics and
the assailant was limited. Therefore, in the present study,
2) self-report questionnaires to obtain information about
we investigated a sample of female adolescent and young
mental health functioning. Information from the inter-
adult victims of rape who were admitted to a specialized
view was transcribed onto a form designed for this
mental health centre for victims of sexual assault. The first
purpose. The following variables were obtained and
aim of this study was to compare demographics, post-rape
dichotomized or categorized for the purpose of the study:
characteristics, and psychological functioning between
early and delayed disclosers in this group. The second aim,
Demographic and victim characteristics
based on the exploratory findings of Kogan (2004), was to
We asked patients about their current age, educational
determine the predictors for delayed disclosure in adoles-
level (lower, middle, or higher), and whether they were of
cents and young adults, including age, prior trauma, and
Dutch origin (i.e., in case of having parents born in the
victim-assailant relationship using logistic regression
Netherlands). Those between 12 and 17 years of age were
analyses. Insight into the predictors for delayed disclosure
defined as adolescents and those between 18 and 25 years
for adolescents and young adults may reveal not only
of age as young adults. We also asked whether the patient
potential causal mechanisms but also possible targets for
was living with their parent(s) (yes/no), and whether the
2
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Predictors of delayed disclosure of rape
family structure was complete, i.e., whether the biological
For the purpose of the study, only the total score was
parents were living together (yes/no). Patients were then
analysed.
asked to confirm the presence of prior negative sexual
experiences (yes/no), and whether they had a current
Depression
sexual relationship (yes/no).
Children Depression Inventory (CDI; Kovacs, 1992;
Timbremont & Braet, 2002) was used for participants
Rape characteristics
aged 12-17 years of age. The CDI is a 27-item ques-
Information about date and time of the rape was ob-
tionnaire, assessing cognitive, affective, and behavioural
tained to calculate the time since rape at admission. Next,
symptoms of depression. The Dutch CDI has a satisfac-
patients were requested to describe the rape. Their re-
tory internal consistency, with Cronbach's a ranging
sponse was categorized into use of penetration (yes/no),
between 0.71 and 0.89 (Timbremont & Braet, 2002).
group rape (yes/no), use of physical violence (yes/no), and
use of threats verbally and/or with a weapon (yes/no).
Behavioural problems
Also, information regarding the victim's relationship to
The Youth Self-Report (YSR; Achenbach & Rescorla,
the assailant was obtained. The assailant was defined as
2001) was used for participants aged 12-18 years. This
a stranger when the victim had never been in contact
questionnaire evaluates the teenager's perception of be-
with the assailant before the rape. Responses were used
havioural and emotional problems. YSR has shown to
to form a closeness category (yes in case of family, (boy)
be internally reliable (Cronbach's α's ranging from 0.71
friend, or mentor). Patients were also asked about the
to 0.95), and convergent and discriminant validity is
(estimated) age of the assailant (categorized into 12-17
reported to be satisfactory (Bérubé & Achenbach, 2006).
The YSR includes four broadband scales and nine
years or > 18 years), and whether the victim had used
alcohol prior to the rape (yes/no).
narrow-band scales to assess behaviour problems. For
the purpose of the study, only the total score on behaviour
problems was included in the analyses.
Post-rape characteristics
Patients were asked when they first talked about the rape.
General psychopathology
The response was used to calculate the disclosure time
The Symptom Checklist-90-R (SCL-90-R; Arrindell &
and the help-seeking time. At the end of the interview,
Ettema, 1986) was used for participants aged 12-25 years.
patients were asked whether they had reported to the
This is a 90-item self-report inventory to assess psycho-
police after the incident (yes/no), and whether they had
social distress. Patients were instructed to indicate the
received any medical care after the incident (yes/no).
amount they were bothered by each of the distress
The study was performed in accordance with the
symptoms during the preceding week. Patients rated 90
precepts and regulations for research as stated in the
distress symptoms on a five-point Likert scale with 1
Declaration of Helsinki, and the Dutch Medical Research
being "not at all" and 5 being "extremely." The state-
involving Humans Subjects Act concerning scientific
ments are assigned to eight dimensions, reflecting various
research. According to the Ethical Medical Committee
types of psychopathology: anxiety, agoraphobia, depres-
of the University Medical Centre Utrecht, this act was not
sion, somatization, insufficiency, sensitivity, hostility, and
applicable to the present study. Written informed consent
insomnia. The Global Severity Index (GSI) can be used
was obtained from both patients and parents.
as a summary of the test and reflects the severity of all
answered statements as a global measure of distress.
Measures
Cronbach's X has been found to range from 0.73 to 0.97.
For the purpose of the study, only the GSI was analysed.
Posttraumatic stress
The Children's Responses to Trauma Inventory (CRTI;
Data analyses
Alisic, Eland, & Kleber, 2006) was used for participants
To compare demographic and post-rape characteristics
aged 12-18 years. This is a 34-item questionnaire asses-
between the early and delayed disclosers, chi-square tests
sing severity of PTSD symptoms according to DSM-IV.
were used. To compare multiple continuous psychological
Patients are asked to indicate to what extent a reaction
scores, MANCOVA was used with "time since trauma" as
to a traumatic event was present during the past week.
a covariate to correct for the potential influence of time
Scores range from I to 5, with higher scores indicating
since trauma.
more symptomatology. The four subscales: Intrusion,
Delayed disclosure was used as a dependent variable.
Avoidance, Arousal, and Other Child-Specific Reactions
The strength of the univariate associations between each
consist of 7, 11, 6, and 10 items, respectively. The reli-
potential risk factor and delayed disclosure was estimated
ability of this instrument is good to excellent (Cronbach's
by calculating the odds ratio (OR) along with 95%
a 0.92 for total score, 0.79 for Intrusion, 0.77 for
confidence intervals (95% CI). To determine the strongest
Avoidance, 0.71 for Arousal; Alisic & Kleber, 2010).
risk factors for delayed disclosure, each potential risk
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Iva A. E. Bicanic et al.
factor identified in the univariate analyses with a sig-
Table 2. Victim assailant relationship (N=323) in valid
nificant OR (p <0.05) was entered as a predictor variable
percentages
into the multivariable model, using a stepwise forward
logistic regression (LR) analysis with delayed disclosure
N
%
as the outcome variable. The Hosmer-Lemeshow goodness-
Stranger
94
29.5
of-fit chi-square was used to calculate how well the
(Ex-)Boyfriend
32
10.0
data fit the model. For all statistical analyses, a p-value
Friend
33
10.3
of <0.05 was considered statistically significant.
Acquaintance
61
19.1
All statistical analyses were conducted using SPSS
Person met during nightlife
30
9.4
(IBM SPSS Statistics for Windows, Version 20.0, IBM
Second-degree relative
15
4.7
Corp., Armonk, NY).
Person seen only once
15
4.7
Person from school
14
4.4
Results
Person met on the internet
12
3.8
Colleague
10
3.1
Socio-demographic characteristics
Mentor
3
1.0
Socio-demographic characteristics of the sample are pre-
sented in Table 1. Victims' age ranged from 12 to 25
higher [t(269) = 24.297, p <0.001] compared to the gen-
years, with a mean age of 16.7 years (SD = and a
eral population (M = 118.28, SD = 32.38; Arrindell &
median age of 16.1 years. Victims' mean age at time of
Ettema, 1986). For the CDI, mean scores were in the
rape was 14.3 years (SD=2.7) and a median age of 13.9
clinical range = 17.2, SD=4.6) and rape victims
years. Penetration occurred in 79.6% of the cases. None
had significantly higher mean scores (t(230) = 15,923,
of the victims reported prior chronic child sexual abuse.
p <0.001), in comparison to previously reported data of
Data about victim-assailant relationship are presented in
the general population of adolescent girls (Timbremont,
Table 2. Victims first disclosed after a mean 20.8 weeks
Braet, & Roelofs, 2008; M = 9.01, SD = 6.45).
(SD = 56.8, range 1-624 weeks), although 58.5% of the
cases told within 1 week. First disclosure was to a friend
Differences between early and delayed disclosers
(45.8%), parent(s) (17.1%), (ex) boy-friend (9.4%), family
Fifty-nine percent of the sample consisted of early dis-
member (6.8%), professional (5.8%), or other adult
closers (disclosure within I week). No significant differ-
(15.2%). With regard to post-rape services, 53.8% of all
ences in demographic characteristics were found between
victims consulted a doctor for medical care and 51.4%
early and delayed disclosers, except that there were
reported to the police. On average, victims were admitted
more delayed disclosers in the age category 12-17 years
to the centre 59.8 weeks post-rape (SD = 93.7, range
compared to the early disclosers group (x² (1) =6.96;
1-676). The mean GSI of the rape victims on the SCL-90-
p=0.008). For rape characteristics, significant differences
R (M = 209.7, SD = 61.8) was comparable with previously
between groups were found for the use of penetration,
reported data of psychiatric populations [M =203.55,
with more victims of penetration in the delayed disclosers
SD = 61.60; t(269) = p 0.104] and was substantially
group compared to the early disclosers group (x² (1) =
5.37; p =0.02). Also, the delayed disclosers group pre-
Table 1. Demographic characteristics of rape victims
sented more victims of verbal and/or weapon threats
in valid percentages
than the early disclosers group (x² (1) = 5.35; p =0.02).
Furthermore, among the delayed disclosers more victims
N
%
identified the assailant as a close person compared to the
Dutch origin
274
84.8
early disclosers (x² (1) = 10.84; p 0.001). Alcohol was
Education levelb
used more often in the early disclosers group compared
Low
182
58.0
to the delayed disclosers group (x² (1) = 20.24; <0.001).
Medium
76
24.2
With respect to post-rape characteristics, a significantly
High
56
17.8
smaller proportion of the delayed disclosers (15.9%)
Parents divorced
102
31.9
utilized medical services following the rape compared
Lives at parental home
273
85.3
to the early disclosers (30.3%; t (1) = 5.32; p=0.02).
Current relationship
81
26.5
Similarly, a significantly smaller proportion of the delayed
Prior negative sex
46
14.8
disclosers (14.6%) compared to the early disclosers
(34.3%) reported the rape to the police (x² (1) = 16.15;
"Dutch origin was defined as being a child from parents born in
the Netherlands; Pafter 6 years of general primary school, at the
p <0.001). The time since trauma at admission was sig-
age of 12 years, students enter low (4 years), medium (5 years),
nificantly lower for early disclosers (M 41.1 weeks,
or high (6 years) secondary education level.
SD = 79.4) than for delayed disclosers (M = 82.9 weeks,
4
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Predictors of delayed disclosure of rape
SD = 103.3; t(314) 4.06, P <0.001). Mean and median
delayed disclosers were less likely to use medical services
time to seek help were 37.7 and 12.0 weeks, respectively.
and to report to the police than early disclosers
Mean time to seek help did not differ between groups
Furthermore, this study identified a number of factors
(t(309) = 2.54, p <0.48). Excluding outliers (M+3 SD,
related to the timing of rape disclosure, showing that
N = 11) did not change the outcome of this analysis. Both
delayed disclosers represented significantly more adoles-
early and delayed disclosers scored in the highest level
cents than young adults, significantly more victims of
of psychological distress when compared to previously
penetration than assault, significantly more victims who
reported norm scores (CRTI, Alisic, Eland, Huijbregts,
were threatened than not threatened, and significantly
& Kleber, 2012; CDI, Timbremont et al., 2008; YSR,
more victims who were close with the assailant.
Achenbach & Rescorla, 2001; SCL-90, Arrindell &
The finding that delayed disclosers are less likely to
Ettema, 1986), but the MANCOVA results showed that
utilize medical services and report to the police than early
when comparing multiple continuous psychological
disclosers is in line with previous studies in adult women
scores, the overall psychological functioning (posttrau-
(Ahrens et al., 2010; Ullman, 1996; Ullman & Filipas,
matic stress, depression, behavioural problems, and gen-
2001). It suggests that disclosure latency is important for
eral psychopathology) did not differ significantly between
public health and safety, as delayed disclosure may not
early and delayed disclosers (F(6,198) =0.88, p = 0.51).
only impede reception of proper medical care, such as
Table 3 shows the ORs with 95% CIs for the associa-
treating anogenital injuries and preventing the onset of
tions between potential risk factors and delayed disclosure.
STDs and unwanted pregnancy (Linden, 2011), but also
Delayed disclosers, when compared to early disclosers,
impede the forensic investigation and apprehension of the
were significantly more likely to be in the age category
assailant (Lacy & Stark, 2013).
of 12-17 years (OR = 2.10), to have experienced rape by
Three variables were identified that successfully pre-
a close person (OR = 2.35), to have been threatened
dicted delayed disclosure: age category 12-17 years,
verbally and/or with a weapon (OR = 1.75), and to have
penetration, and the assailant being a close person. The
experienced penetration (OR = 1.99). Delayed disclosers
finding that the victim's age significantly predicts disclo-
were also found less likely to have used alcohol prior to
sure latency is in line with previous research showing that
the rape (OR = 0.22). None of the other factors were
adolescents are at a greater risk for delayed disclosure
found to be significant risk factors for delayed disclosure.
when compared to their older counterparts (Kogan, 2004;
Smith et al., 2000). Adolescents may be less able to over-
Predicting delayed disclosure
come the barriers to disclose, including factors such as
A stepwise forward LR analysis was conducted to predict
assailant tactics for maintaining secrecy, stigma that often
delayed disclosure, using "age category," "close assailant,"
accompanies rape, and fear that their parents would
"use of threats," and "penetration" as predictors. Victims'
consequently limit their freedom (Crisma, Bascelli, Paci,
alcohol use was not entered in the analysis because of
& Romito, 2004). Also, as victims approach adulthood,
missing values for 33.4% of the cases. The use of threats
they may possess more information about their rights and
was not a significant predictor in the model. A test of the
options after victimization, and have more possibilities for
full model against a constant-only model was statistically
whom to disclose. In our study, most adolescents disclosed
significant, indicating that the predictors (i.e., age cate-
the rape event to peers, in line with prior research (Crisma
gory 12-17 years, close assailant, penetration) reliably
et al., 2004; Priebe & Svedin, 2008).
distinguished between early and delayed disclosers (x²
The use of penetration was found to make victims
(3) = 23.09, p <0.000). There were no significant interac-
more likely to postpone disclosure, opposite to the results
tions between the predictors. Nagelkerke's R² of 10.5%
from Priebe and Svedin (2008), but in line with an older
suggests only a modest association between the predic-
study by Arata (1998), who found that more severe forms
tors and delayed disclosure, although the model did show
of sexual abuse were associated with less disclosure.
an adequate fit to the data (Hosmer-Lemeshow x² (4) =
Penetration may influence disclosure latency through
2.77, p <0.60). In total, 62% of the respondents were
a variety of mechanisms. It could be argued that more
categorized correctly, when using the three predictors
severe rape, indicated by the use of penetration, is more
that contributed significantly to the prediction of delayed
likely to be accompanied by extensive coercive use of
disclosure: age category 12-17 years (OR 2.05, CI 1.13-
tactics to maintain the victim's silence, with fear of re-
3.73), penetration (OR 2.36, CI 1.25-4.46), and closeness
prisal possibly contributing to the finding of delayed dis-
to the assailant (OR 2.64, CI 1.52-4.60).
closure (Kogan, 2004). Also, adolescents may think that
social reactions in response to disclosure are more nega-
Discussion
tive in case of completed rape compared to assault.
The results of this study show that, although no dif-
Another factor that seems to make immediate dis-
ferences were found between delayed and early disclosers
closure of rape less likely is closeness to the assailant,
in psychological functioning and time to seek help,
as indicated by the assailant being a (boy)friend, family
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Iva A. E. Bicanic et al.
Table 3. Demographic and (post )rape characteristics by disclosure time (early VS. delayed disclosers) and odds ratios for
delayed disclosure
Early disclosure
Delayed disclosure
(N = 185)
(i.e., > 1-week post-rape), N = 131
Demographic and (post-)rape characteristics
N
%
N
%
OR
95% CI
Age category (years)
18 25
55
17.4
22
7.0
12 17
130
41.1
109
34.5
2.10
1.20 3.65*
Dutch origin
No
27
8.5
22
7.0
Yes
158
50.0
109
34.5
0.85
0.46 1.56
Living with parent(s)
No
29
9.2
16
5.1
Yes
155
49.2
115
36.5
1.35
0.70 2.59
Complete family structure
No
58
18.4
42
13.3
Yes
127
40.3
88
27.9
0.96
0.59 1.55
Current sexual relationship
No
127
41.8
97
31.9
Yes
53
17.4
27
8.9
0.67
0.39 1.14
Prior negative sexual experience(s)
No
152
49.4
110
35.7
Yes
32
10.4
14
4.5
0.61
0.31 1.19
Known assailant
No
56
17.7
36
11.4
Yes
129
40.8
95
30.1
1.15
0.70 1.88
Close to assailant
No
150
47.6
84
26.7
Yes
35
11.1
46
14.6
2.35
1.40 3.93*
Group rape
No
160
50.8
116
36.8
Yes
24
7.6
15
4.8
0.86
0.43 1.71
Age of assailant (years)
12 17
63
20.6
54
17.6
> 18
117
38.2
72
23.5
0.72
0.45 1.14
Use of penetration
No
46
14.7
19
6.1
Yes
136
43.5
112
35.8
1.99
1.10 3.60*
Use of threats
No
90
31.6
48
16.8
Yes
76
26.7
71
24.9
1.75
1.09 2.82*
Use of physical violence
No
130
42.6
82
26.9
Yes
51
16.7
42
13.8
1.31
0.80 2.14
Victim's alcohol use
No
72
33.5
69
32.1
Yes
61
28.4
13
6.0
0.22
0.11 0.44*
*p <0.05.
Seven participants were dropped from analyses due to missing disclosure time data.
member, or mentor. This finding is consistent with pre-
woman was to report this victimization to anyone (Koss,
vious studies showing that the closer the relationship
1988; Rickert et al., 2005; Wolitzky-Taylor et al., 2011).
between the victim and assailant, the less likely the young
The dynamics of intrafamilial abuse is often proposed as
6
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Predictors of delayed disclosure of rape
the explanation for delayed or non-disclosure (Kogan,
generalizable to all rape victims, because the percentage
2004; Smith et al., 2000). In the present study, however,
of victims that consulted a medical professional and
only 5% of the assailants were identified as a family
reported to the police was higher in our sample than in
member. Most close relationships referred to (boy)friends,
most studies (Hanson et al., 2003; Resnick et al., 2000;
suggesting that a significant percentage of the sample
Zinzow, Resnick, Barr, Danielson, & Kilpatrick, 2012).
experienced peer-to-peer victimization. This type of vic-
Perhaps, these differences could, at least partially, be
timization is most likely to occur during adolescence, as
explained by the fact that stranger rape, representing 30%
compared to childhood or young adulthood, and greatly
of our sample, leads to higher likelihood of help-seeking
increases the risk of revictimization (Humphrey & White,
and police reporting because of its association with higher
2000). Hence, victims of rape by peers may be a target
acknowledgment of victim status (Resnick et al., 2000;
group for interventions promoting early disclosure.
Smith et al., 2000). The fact that this is a help-seeking
Clearly, there are many variables working in tandem to
sample is critical for the reasons cited in the discussion,
affect the timing of victim's disclosure. A closer look at
but also because the generalizability of these data to rape
the final model, which identified three unique variables that
victims who never tell anyone-perhaps the group most
contributed significantly to the prediction of delayed dis-
at risk-simply cannot be known. Besides these limita-
closure, can help us to better understand the phenomenon
tions, several strengths of the current study need to be
of initial disclosure in adolescents and young adults.
noted. One strength is the unique set of adolescents and
Younger adolescent victims who are raped by a close per-
young adults who presented at a mental health care
son are more likely to delay disclosure than older victims
centre after a single rape event, but who reported no prior
of attempted rape by a stranger or acquaintance. Perhaps,
chronic sexual abuse in childhood. For 85% of the
they struggle with the notion that someone close to them
sample, the index trauma was a first time rape. Moreover,
performed such a violent act against them, which con-
data were collected at a designated referral centre for
fuses them about what might happen in terms of safety
victims of rape and, therefore, the sample is likely to
if they would disclose (or not). This finding is especially
represent the clinical population of Dutch victims in the
important in the light of the fact that approximately 80%
age group of 12-25 years.
of victims had some sort of relationship with their per-
The findings of the current study, suggesting that
petrator prior to the assault (Basile, Chen, Black, &
delayed disclosers are less able to benefit from emergency
Saltzman, 2007). With regard to rape types, it would
medical care and evidence collection, have a number of
intuitively seem that less severe forms of sexual assault
practical implications. One of the strategies to enhance
are associated with delayed disclosure and that completed
victims' willingness to disclose within the first week post-
rape would be easier to identify as clearly inappropriate
rape may be sexual education campaigns in school and
and wrong. Victims of completed rape, however, may be
media, as being uninformed is one of the reasons for them
more likely to experience negative psychological reac-
not to disclose (Crisma et al., 2004). Education may
tions, e.g., self-blame and avoidance coping. It is con-
include medical information on rape-related pregnancy
ceivable that they delay their disclosure as a result of
and STDs, as well as the need for timely emergency
rape-induced psychological distress (Starzynski, Ullman,
contraception and prophylaxis, given that these concerns
Filipas, & Townsend, 2005), not necessarily the severity
appear to be facilitators of seeking medical help (Zinzow
of the assault.
et al., 2012). Also, practical information about DNA evi-
Although the final model showed acceptable goodness
dence and how to best protect it, e.g., related to shower-
of fit, the percentage of explained variance of delayed
ing, clothing, eating, and drinking, may increase the
disclosure was modest. Thus, there must be other variables
awareness of opportunities in the early-phase post-rape.
predictive of delayed disclosure, such as the assailant's
Moreover, facts about the potential psychological impact
use of alcohol or weaker support systems, that we did not
of rape, such as PTSD and revictimization, but also in-
assess in this study. Besides this limitation, there are other
formation about evidence-based treatments (Elwood et al.,
drawbacks of this study that should be mentioned. First,
2011; Littleton & Ullman, 2013; McLaughlin et al., 2013),
a clinical sample was used with patients reporting high
may increase help-seeking behaviour in an early stage.
mean levels of psychological distress. This ceiling effect
Furthermore, efforts to encourage early disclosure must
may explain why no differences were found between
consider peer-to-peer victimization as a primary factor,
early and delayed disclosers on psychological function-
as most participants in this study experienced this type
ing, contrary to prior studies (Broman-Fulks et al., 2007;
of victimization, and may initially not have defined or
Ruggiero et al., 2004). Second, posttraumatic stress was
acknowledged the incident as rape because they rationalize
only assessed for children up to 18 years, and for young
such experiences as normal (Hlavka, 2014), leading to the
adults additional suitable measures were not used. Third,
finding of delayed disclosure.
information could have been lost due to dichotomizing
In conclusion, the results of the present study suggest
the variable disclosure latency. Fourth, results may not be
that adolescent victims of rape with penetration by
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Iva A. E. Bicanic et al.
someone close are at increased risk for delayed disclosure,
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