# docs_fts_content

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=== Page 1 ===
From: Critical Mention <alert@criticalmention.com>
To
Subject: Robert Hadden Alert: Suzannah B. Troy artist - "Dr Robert Hadden Predator Protected by Cy Vance
Indicted Federal Grand Jury;20+yrs arrest of Jeffrey Epstein NYPD DA enablers vs my case Dr
Fagelman perjury enablers, Delita Hooks, NYPD criminals all TEFLON"
Date: Thu, 10 Sep 2020 11:40:45 +0000
Critical Mention
You're always on it with Critical Mention.
Dr. Robert Hadden Digest Search new mention
Dr Robert Hadden Predator Protected by Cy Vance Indicted
Federal Grand Jury;20+yrs arrest of Jeffrey Epstein NYPD DA
enablers vs my case Dr Fagelman perjury enablers, Delita Hooks,
NYPD criminals all TEFLON
Source Suzannah B. Troy artist
Market United States
Date Collected Sep 10, 2020 07:39 AM EDT
Author Suzannah B. Troy artist
Category Blog
Language English
MINE CITY OF NY LIED TO PROTECT ALL WRONGS city 1PP and may other powerful enablers
sound familiar? How do you think Jeffrey Epstein operated in plain sight if he didn't have powerful
enabler so I'm just wondering besides the NYPD and DA any other other enablers in common?
https://cyvanceonetermda.blogspot.com/2020/09/cy-vance-enabled-crimes-dr-andrew.html?m=11
Cy
Vance was it an accident that Dr. Robert Hadden didn't end up on the sex offender registry or like
Jeffrey Epstein Ghislaine Maxwell crimes or my case Dr Andrew Fagelman Delita Hooks + NYPD
openly breaking laws to erase crimes for their MD and to send a message to me whistle Blower of
corruption a message, like Harvey Weinstein's victims it's OK our lives don't matter but these doctors
they do so they can break laws they can have the NYPD DA
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EFTA00026618

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EFTA00026619


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Case 1:20-cr-00330-AJN Document 216 Filed 04/19/21 Page 1 of 2
USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT
ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK
DOC #:
DATE FILED: 4/19/2021
United States of America,
-v-
20-cr-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
In its April 16, 2021 Opinion, the Court denied the Defendant's motions to dismiss the S1
superseding indictment in whole or in part and granted the Defendant's motion to sever the
perjury counts for a separate trial. Dkt. No. 207. The Court will try the non-perjury counts first.
As the Court noted in its Opinion, it has not yet resolved the Defendant's two motions to
suppress evidence. See Dkt. Nos. 133, 139. The Defendant contends in those motions that the
Government obtained by subpoena documents covered by a protective order in violation of her
rights against unreasonable searches and seizures, against self-incrimination, and to due process
of law. The motions seek, at minimum, an evidentiary hearing to determine whether the
Government knowingly misrepresented facts to procure an order modifying the protective order.
The Court requires information from the Government for scheduling purposes.
The Government is ORDERED to inform the Court by letter docketed on ECF no later
than April 20, 2021, whether it intends to use any of the documents subject to the pending
motions to suppress in the trial of the non-perjury counts in this case.
EFTA00027089

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Case 1:20-cr-00330-AJN Document 216 Filed 04/19/21 Page 2 of 2
If the Government does not intend to use any of the documents subject to the pending
motions to suppress in the trial of the non-perjury counts, the Court will defer consideration of
those motions until it has scheduled the trial of the perjury counts.
SO ORDERED.
Dated: April 19, 2021
New York, New York
Alim D.Netto
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
From: "
(USANYS)"
To:
"
(USANYS)"
(USANYS)"
^
(USANYS)"
i
(USANYS)"
(USANYS)"
Subject: Fwd: ATTORNEY GENERAL WILLIAM P. BARR DELIVERS REMARKS AT THE GRAND
LODGE FRATERNAL ORDER OF POLICE'S 64TH NATIONAL BIENNIAL CONFERENCE
Date: Mon, 12 Aug 2019 16:06:22 +0000
See remarks at beginning re Epstein.
Begin forwarded message:
From:
"
"
Date: August 12, 2019 at 11:53:16 AM EDT
To:
Subject: ATTORNEY GENERAL WILLIAM P. BARR DELIVERS REMARKS AT THE GRAND
LODGE FRATERNAL ORDER OF POLICE'S 64TH NATIONAL BIENNIAL CONFERENCE
Reply-To:
EFTA00023984

=== Page 2 ===
seal - centered header for gov delivery
The United States Department of Justice
FOR IMMEDIATE RELEASE
AUGUST 12, 2019
ATTORNEY GENERAL WILLIAM P. BARR DELIVERS
REMARKS AT THE GRAND LODGE FRATERNAL ORDER OF
POLICE'S 64TH NATIONAL BIENNIAL CONFERENCE
New Orleans, LA
Remarks as prepared for delivery
Good morning! Thank you, Chuck [Canterbury], for your kind introduction. Jim
[Pasco], it's great to see you and thanks for all that you have done for the FOP
over the years.
EFTA00023985

=== Page 3 ===
Congressman Scalise, it is good to see you this morning. Thank you for your
support for law enforcement. We will never forget the heroism of the Capitol
Police Officers that day and how their swift action prevented a mass tragedy.
Before I begin, I would like to briefly address the news from the Manhattan
Correctional Center over the weekend regarding Jeffrey Epstein. This case was
very important to the Department. It was important to the dedicated prosecutors
and agents who investigated the case and were preparing it for trial. Most
importantly, this case was important to the victims who had the courage to come
forward and deserved the opportunity to confront the accused in court.
I was appalled - indeed, the entire Department was - and frankly angry, to learn
of the MCC's failure to adequately secure this prisoner. We are now learning of
serious irregularities at this facility that are deeply concerning and that demand a
thorough investigation. The FBI and the Office of Inspector General are already
doing just that. We will get to the bottom of what happened at the MCC and we
will hold people accountable for this failure.
Let me assure you that this case will continue on against anyone who was
complicit with Epstein. Any co-conspirators should not rest easy. The victims
deserve justice, and we will ensure they get it.
And now, let me turn to the reason I am here, to renew a relationship with old
friends.
It is a real privilege for me to join the Fraternal Order of Police this morning. I
enjoyed a close relationship with the FOP my first time around in this job, and I
am looking forward to an even closer one this time.
Let me say I am proud to serve in an Administration and under President Trump
who so strongly support law enforcement.
To my mind, there is no more noble profession than serving as a police officer.
You put your own life and well-being on the line to protect your communities.
Your families spend anxious nights, so we can sleep in peace. You never know
what your day may bring - what uncertainty, danger, or threat you might face.
But you still get up, put on your uniform and badge, kiss your loved ones, and
head out to face whatever risks might come your way.
This calls for a special kind of bravery. I remember that when our troops went off
to war in the First Gulf War, they were cheered along the highways as they went.
And when they returned in victory, they were cheered and given ticker tape
parades - and rightly so.
But when police officers leave their precincts every morning, there are no crowds
on the highway cheering you. And when you come home at the end of the day
after a job well done, there are no ticker tape parades.
EFTA00023986

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One reason for this is that law enforcement is fighting a different type of war. We
are fighting an unrelenting, never-ending fight against criminal predators in our
society. While there are battles won and lost each day, there is never a final
resolution - a final victory is never in sight.
It takes a very special kind of courage to wage this kind of fight - a special kind of
commitment; a special kind of self-sacrifice.
So it is an honor for me to have been invited here, to be among you, and to have
the opportunity, as Attorney General, to support you and salute you.
The horrors of El Paso and Dayton last week still weigh heavily on all of us. We
still mourn the victims of these evil acts. We are also proud of the police who
responded to the scenes and prevented further bloodshed.
It is particularly stirring to watch the footage from Dayton. As the shooting
started and civilians fled, you can see the police charging headlong towards the
shooter, whom they quickly and skillfully neutralized. Every American should
thank God that we still have men and women like them - like you - who stand
ready to run toward the mortal danger.
Let me assure you that the President will not let acts of mass shootings and
domestic terrorism go unanswered. He has been consulting widely and has
directed me and Director Wray to work with our state and local partners, as well
as the private sector, to develop strategies and measures to address these threats,
including developing tools that can assist us in detecting potential mass shooters
before they strike. I anticipate that we will be sharing range of proposals -
legislative as well as operational - in the near future. I can assure you that our
proposals will involve collaboration, with you - our colleagues at the state and
local levels.
The recent atrocities also remind us of a basic truth. Human beings are capable of
great good, but also of the basest evil. Even in a healthy society, violence,
lawlessness, and predation lie just below the surface. In the final analysis, what
stands between chaos and carnage on the one hand, and the civilized and tranquil
society we all yearn for, is the thin blue line of law enforcement. You are the ones
manning the ramparts - day in, and day out.
Even in the best of times, there is no tougher calling than serving as a police
officer. Today, it is much tougher than it has ever been.
The Framers believed that a free society can only exist if the people have the
personal virtue and self-restraint to control their own worst passions and
appetites.
If people lose the values and moral discipline to control themselves, then
government would increasingly have to use external force to keep order, and the
community would gradually lose its freedom. This is what James Madison was
EFTA00023987

=== Page 5 ===
talking about when he said, "We have staked our future on the ability of each of us
to govern ourselves."
We live in an age now when the institutions we have relied on to inculcate values
and self-restraint have been under constant assault for over 50 years. As a result,
we see about us increased social pathology: boys growing up without fathers;
alienated and angry young men; gangs engaged in the most brutal violence; mass
shootings; increasing mental illness and suicide among young people; a drug
epidemic inflicting casualties beyond what we would sustain in a major war;
growing domestic violence; an increase in sexual assaults and child exploitation.
You name it. And who is expected to deal with this? As other institutions fail and
abdicate, who is expected to stand their ground? Who is expected to pick up the
pieces? You are. The police. The thin blue line.
That is why I say that the job you are asked to do has never been more
challenging. The risks you are called on to take have never been greater.
Despite the fact that the majority of the American people do support the police,
unfortunately, over the past few years, there has been an increasingly vocal
minority that regularly attacks the police and advances a narrative that it is the
police that are the bad guys rather than the criminals. Whenever there is a
confrontation involving the use of force by police, they automatically start
screaming for the officers' scalps, regardless of the facts.
I am not suggesting there are never abuses. As with all human institutions there
are sometimes bad apples; and we will deal with that. But these are very much the
exceptions, not the rule. If anything, I continue to be amazed at the
professionalism of our police officers in the most extreme circumstances.
The anti-police narrative is fanning disrespect for the law. In recent years, we
have witnessed increasing toleration of the notion that it is somehow okay to
resist the police.
Previously, it was well understood that, regardless of the circumstances, physical
resistance is unacceptable because it necessarily leads to a spiral of escalating
violence that endangers the safety of the officer, the suspect, and all in the
vicinity. For that reason, virtually all jurisdictions have made resistance a serious
crime.
Not too long ago influential public voices - whether in the media or among
community and civic leaders - stressed the need to comply with police
commands, even if one thinks they are unjust. "Comply first" and, if you think
you have been wronged, "complain later."
But we don't hear this much anymore. Instead, when an incident escalates due to
a suspect's violent resistance to police, that fact is usually ignored by the
EFTA00023988

=== Page 6 ===
commentary. The officer's every action is dissected, but the suspect's resistance,
and the danger it posed, frequently goes without mention.
We need to get back to basics. We need public voices, in the media and elsewhere,
to underscore the need to "Comply first, and, if warranted, complain later." This
will make everyone safe - the police, suspects, and the community at large. And
those who resist must be prosecuted for that crime. We must have zero tolerance
for resisting police. This will save lives.
We are seeing disrespect for law enforcement in other ways. We were all
nauseated by the spectacle of prancing punks pelting New York police officers
with water and plastic buckets. Unfortunately, these were not isolated events.
From 2014 through 2017, there has been a 20 percent increase in assaults against
police, up to about 60,000 per year.
This Administration will not tolerate violence against police, and we will do all we
can to protect the safety of law enforcement officers. I will share with you one
proposal that we will be advancing after Labor Day. We will be proposing
legislation providing that in cases of mass murder, or in cases of murder of a law
enforcement officer, there will be a timetable for judicial proceedings that will
allow imposition of any death sentence without undue delay. Punishment must
be swift and certain.
There is another development that is demoralizing to law enforcement and
dangerous to public safety. That is the emergence in some of our large cities of
District Attorneys that style themselves as "social justice" reformers, who spend
their time undercutting the police, letting criminals off the hook, and refusing to
enforce the law.
These anti-law enforcement DAs have tended to emerge in jurisdictions where the
election is largely determined by the primary. Frequently, these candidates
ambush an incumbent DA in the primary with misleading campaigns and large
infusions of money from outside groups.
Once in office, they have been announcing their refusal to enforce broad swathes
of the criminal law. Most disturbing is that some are refusing to prosecute cases
of resisting police. Some are refusing to prosecute various theft cases or drug
cases, even where the suspect is involved in distribution. And when they do deign
to charge a criminal suspect, they are frequently seeking sentences that are
pathetically lenient. So these cities are headed back to the days of revolving door
justice. The results will be predictable. More crime; more victims.
One of my messages today is that the American people need to pay close attention
to issues of public safety in their communities. As a society we should not take
our police officers for granted.
I would like to see the American people gain a renewed appreciation of the noble
work done by our police officers in protecting our communities. I would like to
EFTA00023989

=== Page 7 ===
see increased recognition that being a police officer is the toughest job in the
country, and it is getting tougher. I would like to see a greater commitment to
supporting the police.
The "thin blue line" is getting thinner. The number of sworn officers per capita
has been dropping. We are now in a full employment economy. With lucrative
and safer jobs now available in other sectors, police departments must compete
hard to attract the best candidates.
Many cities are already unable to fill their ranks, and vacancy rates are mounting.
The harder we make the police officer's job - the less they are supported - the
harder it will be to attract qualified candidates. And I think we can anticipate that
those who come forward to serve will be increasingly attracted to jurisdictions
where the community supports the police.
It is imperative that state and local jurisdictions not scrimp on investing in law
enforcement. At time when governments are trying to be all things to all people, it
is important not to forget the basics. The very reason we have government is to
protect the public safety. The very first duty of government is to provide the
police. If we are to maintain the professional police forces we currently have, we
must ensure ample budgets to fund good compensation, full force levels, sufficient
equipment and adequate training.
I would like to turn for a moment to my priorities and the importance of our
partnership.
Two of my highest priorities are continuing the fight against violent crime and
combating the opioid epidemic and the scourge of other dangerous drugs, like
resurging methamphetimine.
When I last served as Attorney General in the early 90's, violent crime was at all-
time high levels in the country. Starting in the 1960's, we had gone through three
decades of "reform" that turned our criminal justice system into a laughable
revolving door. Incarceration rates dropped precipitously; and crime rates
tripled, reaching a high in 1991-92.
Starting with the Reagan Administration, and running though the Bush, Clinton,
and Bush years, we strengthened our criminal justice systems at both the Federal
and state level. We focused on getting chronic violent offenders off the streets and
into prisons to serve meaningful sentences that protected the community. We
worked closely with our State and local partners on programs like Weed & Seed
and Triggerlock.
The result? A steady and sharp drop in violent crime starting in 1992. Today,
violent crime has been cut in half.
Unfortunately, in the last few years of the Obama Administration, the violent
crime rate started rising again. Days after his inauguration, President Trump
EFTA00023990

=== Page 8 ===
issued an Executive Order with two clear directives. First, he declared that this
Administration would reduce crime in America. Second, he directed the
Department of Justice to take the lead on Federal actions to support law
enforcement efforts nationwide and to collaborate with State, tribal, and local
jurisdictions to restore public safety to all of our communities.
We take this responsibility seriously and, working closely with our State and local
partners, we have succeeded once again in driving crime rates back down. I am
proud of our work together on Project Safe Neighborhood, and a variety of joint
anti-gang and anti-gun crime efforts.
We have made a difference, but we cannot rest on our laurels. Crime levels are
still too high and we must keep up a full court press. In the weeks ahead, we will
be doubling down on our attack on violent crime. We will be expanding our
efforts against gun violence and violent gangs. Once again, we plan on doing this
shoulder-to-shoulder with our State and local partners.
On the drug front, we are facing a monumental challenge. To be frank, the
Obama Administration showed little interest in prosecuting the fight against
dangerous drugs. A tsunami built up and has been crashing over the country,
bringing death and destruction.
The death toll from opioids alone is higher than we would sustain in a major war.
Indeed, in a single year, we lose more people to opioids than we lost during the
entire Vietnam War.
Fortunately, this Administration has thrown down the gauntlet. It declared a
national emergency, marshalled the Nation's resources, and is fighting back.
We have a robust program to attack the problem of over-prescription and
diversion of legal opioids, and we are definitely having an impact. Prescription
rates are markedly down. I am confident these successes will accelerate.
I think our attack on illicit opioids is building momentum. It is going to be a long
difficult road, but we are gaining real traction.
As you know, this Administration has sharply increased drug trafficking
prosecutions, especially as to opioids. In 2018 we prosecuted 36 percent more
opioid-related offenses than we did in the previous year. Fentanyl prosecutions
were up 200 percent.
Fentanyl and other synthetics are especially deadly. Unless we make progress on
fentanyl, the gains we are making elsewhere can be overwhelmed. A year ago, the
Department launched Operation SOS, targeting synthetics in 10 high-impact
districts. The first year's results are promising, and I plan to ratchet up this
initiative.
Obviously, the head of the snake is outside the United States. Most of the illegal
drugs coming into the country - opioids, cocaine, and meth - are trafficked from
EFTA00023991

=== Page 9 ===
Mexico by transnational organized crime, particularly the Mexican cartels.
We must destroy these cartels. This is a uniquely Federal responsibility. We have
destroyed cartels in the past, but we let up so that other groups were able to take
their place. We cannot do that again. I don't underestimate how hard this work
is, and how long it will take.
The successful prosecution of El Chapo was a big step forward. We have to
capitalize on that. I have asked our agencies to use every tool at our Nation's
disposal to step up the attack on the cartels. I am hoping that President Trump's
breakthrough agreement with Mexico on cooperating on the immigration crisis
will give us an opportunity to work more closely in attacking the cartels.
In closing, I want to thank you again for all that you do. Thank you for keeping us
safe where we live and work. Ever since the settlers in Boston established the
night watch in 1635, America has had a proud tradition of professionals who
stand guard against those who would do us harm. You are the latest in that noble
line.
Please continue to do what you do. This Administration has your back. May God
bless you and keep you safe. And may God bless the United States of America.
###
AG
19-856
Do not reply to this message. If you have questions, please use the contacts in the
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EFTA00023992


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=== Page 1 ===
Subject: RE: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
Date: Wed, 20 Nov 2019 19:27:14 +0000
Good afternoon all,
Alex, an Accounting Department representative just contacted me regarding the transient occupancy tax you were
charged for your stay at Doubletree by Hilton Santa Monica, but unfortunately since you used your personal card to pay
for the hotel, they are not authorized to remove the taxes from your bill. Sorry for the inconvenience. Let me know if you
have further questions regarding your travel voucher for this trip.
Subject: RE: Final Voucher 10810414(1) prepared by a travel arranger IS pending your review
Alex, regarding the Transient Occupancy Tax, LA County is tax exempt. I've contacted Doubletree by Hilton Santa Monica
for a refund for those charges. Thanks for your patience in this matter.
Subject: RE: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
Unfortunately this is still incorrect. First, it has the nightly lodging costs listed as $248 when in fact it was $247 - see the
invoice, which is attached again. (Or please let me know if I'm supposed to be reimbursed for the maximum daily
allowance rather than the actual cost.) Also it still does not include the tax.
Please let me know when it is corrected and I will review it again.
From: etravelservices@cwtsatotravel.com
Sent: Wednesday, November 20, 2019 10:06
Subject: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
EFTA00025248

=== Page 2 ===
Dear
Final voucher 10810414(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10810414
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
Current status: Pending Voucher Approval
Voucher total expenses: 1517.64
Estimated trip cost: 1583.95
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
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Please note: Replies to this mailbox are not monitored.
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Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00025249


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=== Page 1 ===
From:
To: "Martin G. Weinberg"
, 'Michael Miller'
Cc:
Subject: RE: US V Epstein
Date: Sat, 17 Aug 2019 18:19:24 +0000
Marty,
Based on quick research, I don't immediately see where that would be publicly filed; are you able to send us a copy of the
Petition? Or if you're not able to, to point us in the direction of someone who would be?
thank you,
From: Martin G. Weinberg
>
Sent: Friday, August 16, 2019 08:30
To:
is
>;
>; 'Martin G. Weinberg'
>; 'Michael Miller'
Subject: US V Epstein
during our telephone conversation yesterday you asked for information regarding the status of the estate.
Yesterday in the Virgin Islands there was a fiing of a Petition to Probate the Epstein Estate and Will.
Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
EFTA00024408


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=== Page 1 ===
From
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:28:23 +0000
Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf, Ghislaine_Maxwell_Indictment_PR.pdf
Inline-Images: image001.png
Congrats! I was in NH visiting my parents yesterday. If I had only known, I would have offered to handle the presentment!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO UNITED VILLING
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,
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.
EFTA00024550

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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.
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
EFTA00024551

=== Page 3 ===
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.
EFTA00024552


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=== Page 1 ===
From:
To: "ROBERT C. JOSEFSBERG"
Cc:
Subject: RE: Epstein victims
Date: Thu, 22 Aug 2019 18:13:16 +0000
Bob,
As an update, Judge Berman has scheduled a conference regarding the dismissal of the indictment in light of Epstein's
death for Tuesday, August 27th at 10:30am in Courtroom 17B of the 500 Pearl Street courthouse. The order scheduling
the conference indicated that Judge Berman will allow victims to be heard-either directly or through their counsel-
during the proceeding. If any of your clients would like to attend the conference but cannot afford the travel costs, our
office's victim witness coordinator
)
can provide assistance in arranging travel. They are
certainly not required to attend, but we wanted to let you know that the option is available.
Feel free to give me a call if you have any questions or would like to discuss.
Thanks,
From: ROBERT C. JOSEFSBERG
Sent: Monday, August 19, 2019 7:02 PM
To:
Cc:
Subject: Re: Epstein victims
- Thank you for your informative email/invitation. We will attempt to contact each of our clients re your offer. Thank
you for this offer of counseling, and for your dedication to the entire bizarre situation. Bob
Robert C. Josefsberg, Esq.
Sent from my iPhone
On Aug 19, 2019, at 1:18 PM,
wrote:
Bob,
We've discussed victim resources before, but I wanted to follow up as a reminder to say that if any of your clients would
like counseling or other victim services, please let them know that they are encouraged to contact the case agent on this
case, who can put them in touch with victim services at FBI. The agent is Special Agent
and her phone
number is
We recognize that this is a complicated and stressful time for victims, so we wanted to remind
you that resources are available.
Our team is always available if issues come up, so please feel free to give us a call.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00023929


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=== Page 1 ===
From:
To:
Subject: Fwd: Epstein Travel
Date: Thu, 27 Jun 2019 18:16:19 +0000
Attachments: Travel_searches_6.1.19_to_6.27.19.pdf; ATT00001.htm
Begin forwarded message:
From:
Date: June 27, 2019 at 13:52:15 EDT
To:
Subject: Epstein Travel
Hey!
I searched Epstein's travel records from 6/1/2019 to 6/27/2019 at noon and attached the record. His last record
shows an OUTBOUND flight on 6/14/2019 to Paris.
Search capabilities only show international travel and are limited if he travels to the islands because it is US
Territory. It is unclear why some OUTBOUND/INFBOUND records show Epstein going to/from the islands
and others don't but it is likely up to how CBP inputs their information.
Hope this helps!
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=== Page 1 ===
From:
(NY) (FBI)"
To:
(NYPD)"
)"
Cc:
"
)"
(USANYS)"
Bcc:
=
Subject: [EXTERNAL EMAIL] - FW: Follow up
Date: Sun, 04 Oct 2020 01:23:16 +0000
Embedded: [EXTERNAL_EMAIL]_-_FW:_Follow_up.msg
Sender:
Subject: [EXTERNAL EMAIL] - FW: Follow up
Message-Id: <88789ce3-b399-4186-b521-13d95ec0e6fe@fbi.gov>
Recipient:
EFTA00026573


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=== Page 1 ===
From:
To:
Cc:
Subject: FW:
Interview
Date: Wed, 27 Oct 2021 01:40:52 +0000
Attachments:
Please add to TW 3500 for
(start a new production folder) and
witness folder. Thanks!
From:
Sent: Tuesday, October 26, 2021 2:31 PM
To:
Cc:
Subject: [EXTERNAL] Re:
Interview
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
Sent: Saturday, October 23, 2021 2:42 PM
To:
Cc:
Subject:
Interview
CAUTION! EXTERNAL SENDER
STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide user
ID or password. Suspicious? Please report to this email address:
Hi
Can you please send us the notes for the
email (and the 302 as soon as it is ready)?
Thanks,
Assistant United States Attorney
EFTA00024226

=== Page 2 ===
United States Attorney's Office
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=== Page 1 ===
From:
To:
Cc:
Subject: July 14th hearing
Date: Wed, 08 Jul 2020 19:06:21 +0000
Attachments: 20cr330_Order_7.7.20.pdf
Hi
Attached is a copy of the Court's scheduling order, in case this is helpful.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00024787


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=== Page 1 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page1 of 10
19-1018-cr
United States v. Boustani
In the
United States Court of Appeals
for the Second Circuit
AUGUST TERM 2018
No. 19-1018-cr
UNITED STATES OF AMERICA,
Appellee,
V.
JEAN BOUSTANI, AKA JEAN BOUSTANY,
Defendant-Appellant."
On Appeal from the United States District Court
for the Eastern District of New York
ARGUED: MAY 14, 2019
DECIDED: AUGUST 1, 2019
The Clerk of Court is directed to amend the caption as set forth above.
EFTA00024833

=== Page 2 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page2 of 10
Before: CABRANES, HALL, Circuit Judges, and STANCEU, Judge.*
Defendant-Appellant Jean Boustani ("Boustani") appeals from
a March 28, 2019 order of the District Court for the Eastern District of
New York (William F. Kuntz, II, Judge) denying Boustani's bail
application and directing that he be detained pending trial. We
affirmed the District Court's order by order on May 16, 2019. We write
to explain that decision and to clarify the circumstances under which
the Bail Reform Act permits a District Court to release a defendant
pending trial pursuant to a condition that the defendant pays for
private armed security guards.
MARK E. BINI (David C. James and Hiral D.
Mehta, on the brief), Assistant United States
Attorney, for Richard P. Donoghue, United
States Attorney for the Eastern District of
New York, Brooklyn, NY, for Appellee.
RANDALL JACKSON (Michael S. Schachter
and Casey E. Donnelly, on the brief), Willkie
* Chief Judge Timothy C. Stanceu, of the United States Court of International
Trade, sitting by designation.
2
EFTA00024834

=== Page 3 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page3 of 10
Farr & Gallagher LLP, New York, NY, for
Defendant-Appellant.
JOSÉ A. CABRANES, Circuit Judge:
Defendant-Appellant Jean Boustani ("Boustani") appeals from
a March 28, 2019 order of the District Court for the Eastern District of
New York (William F. Kuntz, II, Judge) denying Boustani's bail
application and directing that he be detained pending trial. We
affirmed the District Court's order by order on May 16, 2019. We write
to explain that decision and to clarify the circumstances under which
the Bail Reform Act permits a District Court to release a defendant
pending trial pursuant to a condition under which the defendant
would pay for private armed security guards.
I.
BACKGROUND
Boustani is charged with conspiracy to commit wire fraud, in
violation of 18 U.S.C. $$ 1343 and 1349; conspiracy to commit
securities fraud, in violation of 15 U.S.C. §§ 78j(b) and 78ff and 18
U.S.C. §§ 371; and conspiracy to commit money laundering, in
violation of 18 U.S.C. $ 1956(a) and (h).
Boustani filed an application for bail pending trial, proposing a
set of conditions that included home confinement under the
supervision of private armed security guards, to be paid for by
Boustani. The Government opposed Boustani's request and argued
that he should be detained pending trial because he was a flight risk.
3
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=== Page 4 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page4 of 10
The District Court denied Boustani's bail application, and Boustani
appealed. We affirmed the District Court's order without prejudice to
further bail applications before the District Court.¹ Boustani then filed
another bail application, which the District Court again denied on
March 28, 2019. Boustani now appeals from the District Court's order
denying his second bail application. After oral argument on May 14,
2019, we affirmed the District Court order by order on May 16, 2019.
II. DISCUSSION
We review a district court's order of detention for clear error
and will reverse only where "on the entire evidence we are left with
the definite and firm conviction that a mistake has been committed."2
Under the Bail Reform Act, a court is required to order the
pretrial release of a defendant on personal recognizance or after
execution of an appearance bond "unless the judicial officer
determines that such release will not reasonably assure the
appearance of the person as required or will endanger the safety of
any other person or the community."3 If the court finds that a
defendant poses a risk of flight, it must release him "subject to the
least restrictive further condition, or combination of conditions,
1 See United States v. Boustani, No. 19-344, 2019 WL 2070656, at *1 (2d Cir.
Mar. 7, 2019).
2 United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007) (internal quotation
marks omitted).
3 18 U.S.C. $ 3142(b).
4
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=== Page 5 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page5 of 10
that
will reasonably assure the appearance of the person."⁴ The
court must order detention, however, if it "finds that no condition or
combination of conditions will reasonably assure the appearance of
the person as required and the safety of any other person and the
community."5 In determining whether any condition or combination
of conditions is sufficient, a court should consider several factors,
including: (1) the nature and circumstances of the charged offense;
(2) the weight of the evidence; (3) the history and characteristics of
the defendant; and (4) the nature and seriousness of the danger
posed by the defendant's release.6
The Government bears the burden of proving by a
preponderance of the evidence both that the defendant "presents an
actual risk of flight" and that "no condition or combination of
conditions could be imposed on the defendant that would reasonably
assure his presence in court."7
We have previously recognized that, in limited circumstances,
a court may release a defendant subject to conditions of home
confinement in which, among other things, the defendant pays for
private armed security guards.⁸ In United States v. Sabhnani, we first
4 18 U.S.C. $ 3142(c)(1)(B).
5 18 U.S.C. $ 3142(e).
6 18 U.S.C. $ 3142(g); Sabhnani, 493 F.3d at 76 & n.16.
7 Sabhnani, 493 F.3d at 75.
8 Id. at 77-78.
5
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=== Page 6 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page6 of 10
acknowledged that such home confinement, combined with other
restrictive conditions, may suffice to reasonably assure the
defendant's appearance in court. We noted in that case, however,
that we had "no occasion to consider whether it would be contrary to
principles of detention and release on bail to allow wealthy
defendants to buy their way out by constructing a private jail."9 We
observed that the defendants in that case were likely denied bail
because of their wealth and that defendants of "lesser means
might have been granted bail in the first place."¹⁰
Since Sabhnani, however, we have highlighted our concerns
regarding granting bail to defendants because of their wealth. In non-
precedential summary orders, we have observed that pretrial release
pursuant to, inter alia, conditions such as supervision by privately
hired security guards may not be appropriate for wealthy defendants
when similarly situated defendants of lesser means would be
detained. 11 And we have noted that district courts need not routinely
consider "the retention of self-paid private security guards," which
9 Id. at 78 n.18 (internal quotation marks omitted).
10 Id.
11 See, e.g., United States v. Esposito, 749 F. App'x 20, 24 (2d Cir. 2018) (non-
precedential summary order).
6
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=== Page 7 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page7 of 10
may be best understood as "a less onerous form of detention
available only to the wealthy."12
We now expressly hold that the Bail Reform Act does not
permit a two-tiered bail system in which defendants of lesser means
are detained pending trial while wealthy defendants are released to
self-funded private jails. It is a fundamental principle of fairness that
the law protects "the interests of rich and poor criminals in equal
scale, and its hand extends as far to each."13 To interpret the Bail
Reform Act as requiring district courts to permit wealthy defendants
to employ privately funded armed guards where an otherwise
similarly situated defendant without means would be detained
would violate this core principle. Such a two-tiered system would
"foster inequity and unequal treatment in favor of a very small
cohort of criminal defendants who are extremely wealthy."14
That said, the private-security condition we described in
Sabhnani may be appropriate where the defendant is deemed to be a
flight risk primarily because of his wealth. In other words, a defendant
may be released on such a condition only where, but for his wealth,
he would not have been detained. By contrast, if a similarly situated
defendant of lesser means would be detained, a wealthy defendant
12 United States v. Banki, 369 F. App'x 152, 154 (2d Cir. 2010) (non-
precedential summary order).
13 Smith v. Bennett, 365 U.S. 708, 714 (1961).
14 United States v. Zarrab, No. 15 CR 867, 2016 WL 3681423, at *13 (S.D.N.Y.
June 16, 2016) (Richard M. Berman, J.).
7
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=== Page 8 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page8 of 10
cannot avoid detention by relying on his personal funds to pay for
private detention. Such a limitation on private-security conditions
ensures that the standards of the Bail Reform Act are applied
equitably to all defendants.
In the instant appeal, Boustani does not challenge the District
Court's finding that he poses a risk of flight. Instead, he argues that
the District Court erred in finding that no conditions or combination
of conditions would reasonably assure his appearance in court.
In ruling on Boustani's initial bail application, the District
Court found that he poses a risk of flight based on several factors.¹⁵
First, the District Court noted the seriousness of the charged offenses
and the lengthy possible sentence Boustani would face if convicted. 16
Second, without drawing any conclusions about the merits of the
case, the District Court found that the evidence against Boustani
"appears strong." Third, the Court considered Boustani's personal
characteristics, including his "alleged deceptive actions, access to
substantial financial resources, frequent international travel,
complete lack of ties to the United States, and extensive ties to foreign
countries without extradition." Having evaluated "the totality of
15 United States v. Boustani, 356 F. Supp. 3d 246, 252-55 (E.D.N.Y.), aff d, No.
19-344, 2019 WL 2070656 (2d Cir. Mar. 7, 2019).
16 Id. at 252.
17 Id. at 253.
18 Id. at 255.
8
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=== Page 9 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page9 of 10
the circumstances," the District Court found that "the Government
has shown by a preponderance of the evidence" that Boustani poses
"a serious risk of flight."19
The District Court further found that the Government had
satisfied its burden of showing that no conditions or combination of
conditions could reasonably assure Boustani's appearance in court.
The District Court noted, among other considerations, that releasing
Boustani to a privately funded jail would lead to disparate treatment
between him and his co-defendants, who might pose flight risks for
similar reasons but lack the financial resources available to
Boustani.²⁰
Boustani's amended bail application did not alter the District
Court's conclusions that Boustani poses a flight risk and that no
conditions or combination of conditions would reasonably assure his
appearance in court.
The District Court's findings are not clearly erroneous. It is
clear that the District Court did not rely primarily on Boustani's
personal wealth in finding that he posed a flight risk. Rather, his
wealth was one of many factors the Court considered. A similarly
situated defendant of lesser means surely would be detained pending
trial, and Boustani is not permitted to avoid such a result by relying
on his own financial resources to pay for a private jail.
19 Id.
20 Id. at 258.
9
EFTA00024841

=== Page 10 ===
Case 19-1018, Document 61, 08/01/2019, 2621854, Page10 of 10
III. CONCLUSION
For the foregoing reasons, the District Court's order of March
28, 2019, was affirmed by order on May 16, 2019.
10
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From:
To:
Subject: Child Exploitation & Porn Update Report III
Date: Thu, 21 Mar 2019 21:05:38 +0000
Attachments: Child_Exploitation_&_Porn_Update_Report_II.pdf
Attached is the Child Exploitation & Porn Update Report III for Project Safe Childhood.
Chiefs and Project Safe Childhood Coordinator, please remind the assigned AUSA to make updates in their
cases. Thanks!
EFTA00026810


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From:
To:
Cc:
Bcc: "USAHUB-USAJournal111
Subject: Re:
Date: Thu, 19 Nov 2020 17:22:23 +0000
Embedded: Re:
Sender:
Subject: Re:
Message-Id:
To:
Cc:
Cc:
Cc:
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=== Page 1 ===
From:
To:
Cc:
Subject: FW: SDNY Investigation
Date: Tue, 07 Jul 2020 21:24:42 +0000
Attachments: WinZip_Extraction_Directions.pdf;disclaim.txt
Inline-Images: image001.png
Hi
In a moment, l'll forward you two emails with subpoena returns from UBS. Could you please unzip the files (password
below), save them in the Epstein shared, update the subpoena tracker, and reach out to
to provide him with a
copy?
Thanks!
From:
Sent: Tuesday, July 7, 2020 5:22 PM
To:
Cc:
Subject: RE: SDNY Investigation
You're welcome. The password for all is Max_0707. Winzip directions are attached and 7-zip.org is also useful for opening
files.
From:
)
Sent: Tuesday, July 7, 2020 4:17 PM
To: Canter, Nicole <nicole.canter@ubs.com>
Cc:
is
>; Wills, Theodore <theodore.wills@ubs.com>
Subject: [External] RE: SDNY Investigation
Received, and thanks very much.
Best,
From: nicole.canter@ubs.com <nicole.canter@ubs.com>
Sent: Tuesday, July 7, 2020 5:13 PM
EFTA00024490

=== Page 2 ===
To:
Cc:
Subject: SDNY Investigation
Counsel,
I am sending, in multiple emails, account statements for 2020. Once I receive confirmation of receipt, I will send the
password.
I have also requested a CD containing account statements for 2018 and 2019; I anticipate overnighting it tomorrow for
delivery on Thursday.
UBS
Paralegal - Authorized Officer
UBS Group AG
Legal - SLG
Nashville, TN 37238
www.ubs.com
EFTA00024491


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=== Page 1 ===
From:
To:
Subject: RE: Expert Testimony
Date: Mon, 02 Nov 2020 18:04:07 +0000
Good for me, thanks
From
Sent: Monday, November 02, 2020 12:09 PM
To:
Subject: Fwd: Expert Testimony
2 work for you on Wednesday?
Sent from my iPhone
Begin forwarded message:
From: Dawn Hughes
Date: November 2, 2020 at 10:53:58 AM EST
To:
Cc:
Subject: Re: Expert Testimony
Yes. I would be happy to speak with you all. I have some open time on Wednesday after 2:00. Let
me know what works for you.
Best,
Dr. Hughes
DAWN M HUGHES, PHD ABPP
CLINICAL AND FORENSIC PSYCHOLOGIST
On Thu, Oct 29, 2020 at 3:48 PM
wrote:
Dr. Hughes,
Together with colleagues
I'm one of the federal prosecutors handling
the case of United States V. Ghislaine Maxwell, which is scheduled to go to trial on July 12, 2021 in the
Southern District of New York. We would be interested in speaking with you about your availability to
testify as an expert witness at trial. Are you available for a call tomorrow or next week to discuss?
EFTA00024756

=== Page 2 ===
Thanks very much
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From:
To:
Cc:
Subject: RE: SHU Photos/Number of Steps
Date: Wed, 18 Sep 2019 14:28:53 +0000
l'll have an answer for you today
From:
Sent: Wednesday, September 18, 2019 10:15 AM
To:
Subject: SHU Photos/Number of Steps
Hey
I know FBI was taking photos of the SHU generally and measuring the number of steps from Epstein's cell to the guard
desk. Do you have those photos and can you provide them to us? Thank you.
Also, let us know if you need a hard drive from us for Thomas' phone.
Thanks.
Assistant United States Attorney
Southern District of Ne
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From:
To:
Subject:
Date: Tue, 07 Jul 2020 16:51:02 +0000
Hi everyone. One of our shared challenges in this time is nurturing the sense of community that's so important to what
we do-that spirit of shared purpose which brings us together in good times and bad to celebrate, laugh, and reflect.
Last week brought some very public milestones: a civil settlement that held Novartis accountable for years of illicit
kickbacks and the arrest of Ghislaine Maxwell.
But so much your important work is happening outside the spotlight, and I wanted to take a moment to celebrate that as
well. So thank you to everyone who has taken on new gun cases to help combat the recent rise in violence; thank you to
everyone handling the civil and criminal litigation around incarceration in the Covid era with thoughtfulness and
care; [civil example]; thank you to all of our unsung AUSAs, paralegals, and staff. We miss seeing you every day, but we
celebrate your efforts today and always. This District is lucky to have you.
Until next time, stay safe and keep up the great work.
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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 17:33:37 +0000
Inline-Images: image001.png
Now with
From:
Sent: Thursday, July 2, 2020 1:28 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats! I was in NH visiting my parents yesterday. If I had only known, I would have offered to handle the presentment!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO TOTAL UNITED VILLING
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
OF
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
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purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
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
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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.
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
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unless and until proven guilty.
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Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 1 of 14
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 8/13/21
United States of America,
-v-
20-cr-330 (AJN)
Ghislaine Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On April 16, 2021, the Court issued an Opinion & Order granting in part and denying in
part Ghislaine Maxwell's various pretrial motions seeking to dismiss portions of the
Government's (S1) superseding indictment and compel discovery. Prior to the issuance of that
Opinion & Order but after the motions were fully briefed, a grand jury returned a second (S2)
superseding indictment adding a sex trafficking count and sex trafficking conspiracy count. The
Court did not address the new charges in the April 16, 2021 Opinion & Order. On May 25,
2021, Maxwell filed another round of pretrial motions seeking to dismiss the S2 indictment in
whole or in part and to compel discovery. Dkt. No. 292, 293. For appeal preservation purposes
or otherwise, the arguments largely, though not entirely, rehash the positions rejected by the
Court in its April 16, 2021 Opinion & Order. To the extent new arguments are made, they are
addressed below. All pending motions are DENIED. The Court provides a brief summary of its
conclusions here and its reasoning on the pages that follow:
Maxwell moves to dismiss counts one, three, five, and six as barred by Jeffrey
Epstein's non-prosecution agreement. The Court again concludes, as it did in its April
16, 2021 Opinion & Order, that the agreement does not bind the United States Attorney
for the Southern District of New York.
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Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 2 of 14
Maxwell moves to dismiss counts five and six on the grounds that prosecuting her on
those counts would violate her rights under the Double Jeopardy Clause. The Court
concludes that Maxwell has not previously been put in jeopardy for these offenses and
therefore her prosecution on these counts does not violate the Double Jeopardy Clause.
Maxwell moves to dismiss counts five and six as untimely. The Court again concludes,
as it did in its April 16, 2021 Opinion & Order, that the Government brought the
charges within the applicable statute of limitations.
Maxwell moves to dismiss count five and either count one or count three as
multiplicitous. The Court again determines, as it did in its April 16, 2021 Opinion &
Order, that this motion is premature and denies it without prejudice for renewal at trial.
Maxwell moves to dismiss the S2 indictment for pre-indictment delay. The Court again
concludes, as it did in its April 16, 2021 Opinion & Order, that Maxwell has not
established that she suffered prejudice and therefore any delay has not violated her
rights to due process.
Maxwell moves for a bill of particulars related to counts five and six because they are
too vague, and in particular do not provide specific dates. The Court again concludes,
as it did in its April 16, 2021 Opinion & Order, that the charges are sufficiently
specific.
Maxwell moves to compel the Government to produce the statements of "Minor-Victim
4" in the S2 indictment as Brady material. The Court concludes that the current
disclosure schedule gives Maxwell sufficient time to make effective use of any such
statements and therefore immediate disclosure is not warranted.
I.
Jeffrey Epstein's non-prosecution agreement does not bar the charges in the S2
indictment
In its April 16, 2021 Opinion & Order on Maxwell's first set of pretrial motions, the
Court held that the non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S.
Attorney's Office for the Southern District of Florida did not bar the charges against Maxwell in
the S1 superseding indictment. See United States V. Maxwell, No. 20-cr-330 (AJN), 2021 WL
1518675, at *2 (S.D.N.Y. Apr. 16, 2021). Maxwell now renews those arguments for the charges
in the S2 superseding indictment. The Court understands the primary purpose of Maxwell's
renewed motion to be to preserve these arguments for appellate review, and the Court denies the
2
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Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 3 of 14
renewed motion for substantially the same reasons set forth in its April 16 opinion. The Court
will proceed to briefly explain why neither the new charges in the S2 superseding indictment nor
the supplemental authority Maxwell cites change the Court's conclusion that the NPA does not
bar the charges against her.
As the Court explained in its April 16, 2021 Opinion & Order, the Second Circuit held in
United States V. Annabi that "[a] plea agreement binds only the office of the United States
Attorney for the district in which the plea is entered unless it affirmatively appears that the
agreement contemplates a broader restriction." 771 F.2d 670, 672 (2d Cir. 1985) (per curiam).
The Second Circuit's opinion in Annabi is clear, and that court has followed it steadfastly since.
See, e.g., United States V. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004); United States V.
Brown, No. 99-1230(L), 2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002); United States V.
Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States V. Rivera, 844 F.2d 916,
923 (2d Cir. 1988). The Second Circuit has held that language nearly identical to that in
Epstein's NPA is not enough to overcome the presumption in favor of single-district plea
agreements. See Salameh, 152 F.3d at 120. Adhering to this binding authority, this Court thus
concluded (and continues to conclude) that the NPA does not bind the U.S. Attorney's Office for
the Southern District of New York. It thus provides Maxwell no defense in this case even if it
would otherwise cover the conduct charged in the new counts in the S2 superseding indictment.
Maxwell advances two new arguments for why the Court should depart from this
reasoning-the first in her renewed motion and the second in a letter of supplemental authority.
See Dkt. Nos. 293, 310. In her renewed motion, she contends that Annabi contains an exception
for out-of-district prosecutions for charges that are "identical to the dismissed charges." And in
the letter of supplemental authority, she contends that the opinion of the Pennsylvania Supreme
3
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Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 4 of 14
Court in Commonwealth V. Cosby, No. 39 MAP 2020, 2021 WL 2674380 (Pa. June 30, 2021),
requires dismissal. Neither argument is persuasive.
Annabi contains no exception for out-of-district prosecutions for charges that are
"identical to the dismissed charges." In the language Maxwell cites from Annabi, the Second
Circuit discussed (and rejected) a claim based on the Double Jeopardy Clause, not a claim based
on the plea agreement in that case. See Annabi, 771 F.2d at 672. In that section of the opinion,
the Second Circuit held that even if the charges had been identical to the dismissed charges, the
defendants' double jeopardy claims would fail because they were never in jeopardy on the
charges that were dismissed under the plea agreement. Nothing in Annabi suggests that the
presumption in favor of single-district plea agreements does not apply if later charges in another
district are sufficiently "identical" to the dismissed ones, and no subsequent Second Circuit case
applying Annabi has so held. Annabi applies squarely to the facts of this case and binds this
Court.
The Court also disagrees that Cosby mandates a different result. To begin with, this
Court must follow the precedential opinions of the Second Circuit on questions of federal law,
not those of a state court. Thus, nothing in Cosby could change this Court's view that Second
Circuit precedent in Annabi forecloses Maxwell's arguments related to the NPA. In any event,
the state court in Cosby did not purport to decide the same federal question at issue here. In
Cosby, the court held that it was unfair for a district attorney to proceed with charges against Bill
Cosby after the district attorney's office had, in that court's view of the facts, unequivocally
promised that it would not charge him. Cosby, 2021 WL 2674380, at *34. That case did not
involve a question of whether one office's promise bound another, much less whether a plea
agreement in one federal district should be construed to apply in another district. Instead, the
4
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Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 5 of 14
case focused on whether prosecutors were required to honor a promise that the court found to be
clear in the absence of a formal plea agreement. Even if this Court agreed with the analysis in
Cosby, that opinion sheds no light on the proper interpretation of the NPA in this case.
After considering the arguments in Maxwell's renewed motion and letter of supplemental
authority, the Court's view remains unchanged from its April 16, 2021 Opinion & Order. Under
Second Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of
New York. It thus does not bar the charges in the S2 superseding indictment.
II.
This prosecution does not violate the prohibition against double jeopardy
The Double Jeopardy Clause provides that "[n]o person shall be
subject for the same
offence to be twice put in jeopardy of life or limb." U.S. Const. amend. V. "This protection
applies both to successive punishments and to successive prosecutions for the same criminal
offense." United States V. Dixon, 509 U.S. 688, 696 (1993). "A defendant may only raise a
Double Jeopardy claim if he has been put in jeopardy (i.e. jeopardy has "attached") sometime
before the alleged 'second' prosecution." United States V. Podde, 105 F.3d 813, 816 (2d Cir.
1997). A defendant is put in jeopardy when the jury in their case is empaneled or upon the
defendant's entry of a guilty plea. Crist V. Bretz, 437 U.S. 28, 35 (1978); Morris V. Reynolds,
264 F.3d 38, 49 (2d Cir. 2001). Until then, a defendant has not been put in jeopardy and the
Government is free to commence a prosecution.
Maxwell has not previously been put in jeopardy for the offenses charged in this case.
She concededly has not been punished or prosecuted for any prior offense. She was never
charged in the Southern District of Florida in connection with the Epstein investigation. She
agreed to nothing in Epstein's NPA, because she was not a party to it. She suffered no criminal
consequences as a result of Epstein's guilty plea in Florida state court. To the contrary, there is
5
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=== Page 6 ===
Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 6 of 14
no indication that Maxwell was even a subject of the Florida investigation. The Double Jeopardy
Clause bars only successive prosecution or punishment for the same offense, and Maxwell has
endured neither. Thus, the Double Jeopardy Clause does not bar the charges against her.
Despite facing no prior prosecution or punishment herself, Maxwell contends that she is
immune from prosecution because Epstein was already punished for the same conspiracy. The
cases she cites, however, deal with successive prosecutions of a particular defendant for the same
conspiracy, not separate prosecutions of individual co-conspirators. See, e.g., United States V.
Lopez, 356 F.3d 463, 469 (2d Cir. 2004). The Double Jeopardy Clause does not require all co-
conspirators be tried together for related offenses. See Zafiro V. United States, 506 U.S. 534, 539
(1993); United States V. Hinton, 543 F.2d 1002, 1014 (2d Cir. 1976). Whether the Government
could have charged Epstein again in this case has nothing to do with Maxwell's rights under the
Double Jeopardy Clause.
Maxwell finally points to one case in which the Second Circuit held that a subsequent
prosecution might not be permissible against a defendant whose charges were dismissed after her
husband pleaded guilty. Dkt. No. 293 at 19 (citing United States V. Cambindo Valencia, 609
F.2d 603 (2d Cir. 1979)). However, the Court agrees with the Government that the result in
Cambindo Valencia rested on the terms of the husband's plea agreement, not the Double
Jeopardy Clause. See Cambindo Valencia, 609 F.2d at 638. No precedent stands for the
proposition that an uncharged co-conspirator is put in jeopardy when another co-conspirator
accepts a non-prosecution agreement. This is the first case in which Maxwell will be put in
jeopardy for these offenses, and so this prosecution does not put her in jeopardy a second time.
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Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 7 of 14
III.
Counts five and six are not time-barred
For most non-capital offenses, the statute of limitations under federal law is five years.
18 U.S.C. $ 3282(a). Congress has enacted longer limitations periods for certain crimes, in
particular for "offense[s] involving the sexual or physical abuse, or kidnapping" of a minor in 18
U.S.C. $ 3283. Prior to 2003, the limitations period in $ 3283 lasted until the victim reached the
age of 25, and then Congress extended the limitations period to the life of the victim with the
PROTECT Act of 2003, Pub. L. No. 108-21, 117 Stat 60. In 2006, Congress enacted 18 U.S.C.
§ 3299, which eliminated the statute of limitations for the sex trafficking of minors in violation
of 18 U.S.C. $ 1591 and for some other sex crimes. See 18 U.S.C. $ 3299 ("Notwithstanding
any other law, an indictment may be found or an information instituted at any time without
limitation for any offense under section 1591.").
In her previous motion, Maxwell argued that the Mann Act charges against her in the
indictment were time-barred on the grounds that the extended limitations period $ 3283 was not
applicable. The Court denied that motion in its April 16, 2021 Opinion & Order. Maxwell, 2021
WL 1518675, at *5. Maxwell now argues that the new charges the Government has brought
against her in the S2 indictment, Sex Trafficking Conspiracy (18 U.S.C. $ 371) and Sex
Trafficking (18 U.S.C. $ 1591), are time-barred as well because $ 3283 does not apply to those
offenses either. She renews her contention from her previous motion that the limitations period
in $ 3283 only applies to offenses which "necessarily entail" the sexual abuse of a minor and
argues that a violation of 18 U.S.C. $ 1591 does not. Thus, according to Maxwell's reasoning,
the general five-year statute of limitations period in 18 U.S.C. $ 3282(a) applies to the sex
trafficking counts and, because the alleged conduct occurred from 2001 to 2004, the Government
is now time-barred for prosecuting her for these offenses.
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Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 8 of 14
The Court denies this motion for substantially similar reasons as those discussed in its
April 16, 2021 Opinion & Order. As an initial matter, the Court reiterates that Maxwell's
analysis of $ 3283 is incorrect. As the Court explained, $ 3283 does not call for a
"categorical approach" nor an "essential ingredient" test, but instead requires that the defendant's
conduct in that particular case involved the sexual abuse of a minor. Maxwell, 2021 WL
1518675 at *5-7. Here, there is no question that Maxwell is alleged to have engaged in activity
that constitutes the sexual abuse of a minor with respect to the sex trafficking counts.
But in any event, as the Government pointed out in its brief - and as Maxwell did not
contest in her reply - $ 3283 is not the only statute of limitations that applies to the sex
trafficking counts. As discussed above, in 2006, Congress enacted $ 3299 to eliminate altogether
the limitations period for the offense of sex trafficking children in violation of $ 1591. See 18
U.S.C. $ 3299.
Moreover, while the alleged sex trafficking in the S2 indictment is alleged to have
occurred prior to the enactment of § 3299 in 2006, the Court holds that the provision nonetheless
applies retroactively to cover that conduct. In its April 16, 2021 Opinion & Order, the Court
analyzed $ 3283 under the Landgraf v. USA Film Products, 511 U.S. 244, 280 (1994) framework
and concluded that the limitations period applied retroactively so long as the previous limitations
period had not yet expired. Maxwell, 2021 WL 1518675, at *7-8. Similar to $ 3283, which
states that "[n]o statute of limitations that would otherwise preclude prosecution" shall apply, the
language of $ 3299 provides that an indictment may be instituted at any time for certain offenses
"[n]otwithstanding any other law." As discussed in the Court's previous opinion with respect
to $ 3283, this kind of language unambiguously requires that the limitations period apply
retroactively to prosecutions for offenses committed before the date of enactment so long as the
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=== Page 9 ===
Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 9 of 14
applicable limitations period has not yet run - offenses that by definition are those for which
"other law[s]" of limitation would otherwise bar prosecution. See 18 U.S.C. § 3299. Moreover,
as the Court also explained, not only does this kind of language unambiguously require
retroactivity, it also does not result in any impermissible retroactive effects so long as it does not
revive time-barred claims. Maxwell, 2021 WL 1518675, at *7-8. The Court therefore joins
multiple other district courts in concluding that, like $ 3283, $ 3299 applies retroactively to
offenses for which the previous limitations period has not yet run. See United States V. Nader,
425 F. Supp. 3d 619, 629 (E.D. Va. 2019); United States V. Pierre-Louis, No. 16 CR 541 (CM),
2018 WL 4043140, at *6 (S.D.N.Y. Aug. 9, 2018); United States V. Vickers, No. 13-CR-128-A,
2014 WL 1838255, at *8 (W.D.N.Y. May 8, 2014); United States V. Sensi, No. 3:08-CR-253
(WWE), 2010 WL 2351484, at *3 (D. Conn. June 7, 2010).
The sex trafficking charges are therefore not time-barred. Regardless of whether it was
the general five-year limitations period in § 3282(a) or the extended limitations period for sexual
abuse of minors in $ 3283 that was applicable to Maxwell's alleged conduct prior to the
enactment of § 3299 in 2006, neither had expired by that date. Thus, as Maxwell does not
contest, $ 3299 applies retroactively to the sex trafficking offenses in the indictment and the
Government is permitted to bring those charges without time limitation.
IV.
Maxwell's motion to dismiss count five and either count one or count three as
multiplicitous is premature
In her previous motions, Maxwell argued that either count one or count three of the S1
indictment, the Mann Act conspiracy charges, must be dismissed because the counts are
multiplicitous. In the Court's April 16, 2021 Opinion & Order, the Court joined many other
courts in this Circuit holding that pretrial motions of this sort are premature in light of United
States V. Josephberg, 459 F.3d 350, 355 (2d Cir. 2006), and the Court dismissed without
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Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 10 of 14
prejudice. Maxwell, 2021 WL 1518675, at *14. In the instant motion, Maxwell similarly argues
that count five of the S2 indictment, the sex trafficking conspiracy charge, is duplicative of either
counts one or three. Maxwell's motion is denied without prejudice for the reasons stated in the
Court's April 16, 2021 Opinion & Order.
V.
The Government's delay in bringing the charges did not violate due process
Maxwell also renews her motion to dismiss the S2 indictment based on alleged improper
pretrial delay. In its April 16, 2021 Opinion & Order, the Court denied Maxwell's motion,
concluding that her efforts to show actual and substantial prejudice fell far short of the "stringent
standard" necessary to prevail on such a claim. Maxwell, 2021 WL 1518675, at *9. Maxwell's
motion to dismiss the S2 on these grounds fails for the same reasons. As before, nothing in the
record indicates that the Government's delay in bringing these charges was designed to thwart
Maxwell's ability to prepare a defense. However, it is sufficient to conclude that Maxwell does
not make the strong showing of prejudice required to support this sort of claim. Maxwell
contends that the Government's delay in bringing charges has prejudiced her interests because
potential witnesses have died, others have forgotten, and records have been lost or destroyed. It
is highly speculative that any of these factors would make a substantial difference in her case.
The Court thus again concludes for the reasons stated in the April 16, 2021 Opinion &
Order, that Maxwell has failed to establish actual prejudice from the Government's delay in
bringing charges. She may renew her motion if the factual record at trial shows otherwise. On
the present record, neither the applicable statute of limitations nor due process bars the charges
here.
10
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=== Page 11 ===
Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 11 of 14
VI.
No bill of particulars is warranted
Maxwell moves for a bill of particulars as to counts five and six. Federal Rule of
Criminal Procedure 7 requires that an indictment contain "a plain, concise, and definite written
statement of the essential facts constituting the offense charged[.]" The indictment must be
specific enough to inform the defendant of the charges and allow the defendant to plead double
jeopardy in a later prosecution based on the same events. See United States V. Stavroulakis, 952
F.2d 686, 693 (2d Cir. 1992). "Under this test, an indictment need do little more than to track the
language of the statute charged and state the time and place (in approximate terms) of the alleged
crime." United States. V. Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975).
"Rule 7(f) of the Federal Rules of Criminal Procedure permits a defendant to seek a bill
of particulars in order to identify with sufficient particularity the nature of the charge pending
against him, thereby enabling defendant to prepare for trial, to prevent surprise, and to interpose
a plea of double jeopardy should he be prosecuted a second time for the same offense." United
States V. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). "The purpose of a bill of particulars is to
supplement the allegations in the indictment when necessary to (1) enable the defendant to
prepare his defense, (2) avoid unfair surprise to the defendant at trial, and (3) preclude a second
prosecution of the same offense." United States V. Mandell, 710 F. Supp. 2d 368, 384 (S.D.N.Y.
2010)). On the other hand, the Court must balance these interests against the harm to the
Government from restricting its proof at trial. See United States V. Rajaratnam, No. 09-cr-1184
(RJH), 2010 WL 2788168, at *1 (S.D.N.Y. Jul. 13, 2010).
In her previous motions, Maxwell argued that the Mann Act counts in the indictment
should be dismissed for lack of specificity or that, in the alternative, the Court should compel the
Government to submit a bill of particulars providing greater detail of the charges. Maxwell
11
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=== Page 12 ===
Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 12 of 14
contended specifically that the indictment is too vague because it refers to open-ended time
periods for the Mann Act counts. The Court disagreed in light of Circuit precedent requiring
only that an indictment describe the time and place of the charged conduct in "approximate
terms" and permitting the use of "on or about" language to describe the window of when a
violation occurred. Maxwell, 2021 WL 1518675, at *10 (citing Tramunti, 513 F.2d at 1113;
United States V. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)). The Court explained that
approximate time periods are particularly appropriate if the allegations involved ongoing conduct
and especially if the indictment alleges sexual abuse against minor victims. Id. (citing United
States V. Young, No. 08-cr-285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008)).
Maxwell now again moves for a bill of particulars. Maxwell primarily argues that the S2
indictment does not provide specific dates for the conduct alleged with respect to the sex
trafficking counts. Instead, the S2 indictment provides a four-year time period from 2001 to
2004 in which the alleged sex trafficking and sex trafficking conspiracy occurred. Maxwell's
motion in this respect is denied for the same reasons stated in the Court's April 16, 2021 Opinion
& Order. The indictment alleges ongoing conduct that involve the sexual abuse of minors with
respect to counts five and six and therefore the approximate time period provided is sufficient.
Accordingly, the motion for a bill of particulars is denied.
VII. The current disclosure schedule for impeachment material is adequate
Finally, Maxwell moves to compel the immediate disclosure of any of Minor Victim's
prior statements in which she did not mention Maxwell, including prior statements made to the
1 Additionally, Maxwell includes in her motion for a bill of particulars a request to require the
government to identify the unnamed co-conspirators who allegedly participated in the conspiracies
charged in the S2 indictment. Maxwell also made this request in the parties' joint May 21, 2021 letter to
the Court regarding the disclosure schedule. Dkt. No. 291. In both her motion and the May 21, 2021
letter, Maxwell requests that this information be disclosed to the defense at the same time that the
Government discloses Jencks Act material. The Government has not opposed this request. In the absence
12
EFTA00023906

=== Page 13 ===
Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 13 of 14
FBI. The Court has ordered the Government to disclose all Jencks Act and Giglio material by
October 11, 2021. Dkt. No. 297 at 1. That date is seven weeks in advance of trial. The Court
sees no reason to depart from the rule in this district that impeachment material of anticipated
witnesses does not warrant an order compelling immediate disclosure. See United States V.
Campo Flores, No. 15 Cr. 765 (PAC), 2016 WL 5946472, at *11 (S.D.N.Y. Oct. 12, 2016).
Seven weeks in advance of trial is far more time than is standard in this district and no showing
has been made that it will be insufficient for Maxwell to make effective use of the information in
preparation of her defense.
To the extent Maxwell argues that the Government is in possession of prior statements
that are exculpatory under Brady (for example, if a witness denied Maxwell's involvement),
rather than useful only for standard impeachment purposes, it is of course the Government's
obligation to "disclose such information to the defense promptly after its existence becomes
known to the Government so that the defense may make effective use of the information in the
preparation of its case." Dkt. 68 at 1. The context of questions and answers surely matters as to
whether a statement (or omission) is exculpatory, impeaching, or neither. It is for the
Government to make these assessments ex ante and fully meet its disclosure obligations so that
the defense may make effective use of any such information in preparation for trial. See United
States V. Coppa, 267 F.3d 132, 144-46 (2d Cir. 2001). The Government has repeatedly
confirmed that it understands those obligations, and that it has met them and will continue to
meet them. Accordingly, the motion to compel the immediate disclosure of any of Minor
Victim-4's prior statements in which she did not mention Maxwell is denied.
of objection, the Court presumes the Government intends to disclose this information to Maxwell at the
same time that as it discloses Jencks Act material.
13
EFTA00023907

=== Page 14 ===
Case 1:20-cr-00330-AJN Document 317 Filed 08/13/21 Page 14 of 14
Conclusion
For the reasons above and in this Court's April 16, 2021 Opinion & Order, the Court
DENIES Maxwell's motion to obtain relief specified in her supplemental pre-trial motions
relating to the S2 indictment. This resolves Dkt. No. 292.
so ORDERED.
Dated: August 13, 2021
New York, New York
Alim D.Netto
ALISON J. NATHAN
United States District Judge
14
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=== Page 1 ===
From:
To:
Subject: Hotline results
Date: Thu, 11 Jul 2019 01:17:26 +0000
Attachments: HOTLINE_TRACKER_9PM_7.10.2019.xlsx
FBI New York
EFTA00026680


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=== Page 1 ===
From:
To:
Subject: Last MILs
Date: Mon, 25 Oct 2021 04:13:48 +0000
Attachments: Suppress_ID_v3.docx;Suppress_ID_v3.pdf_Exhibits_v4pdf Forbidden_Words_v2.docx;
Forbidden_Words_v2.pdf; Irrelevant_mots_v2.docx;Irrelevant_mots_v2.pdf;
Exhibits_v4.docx
Hi
Attached are the last set of MILs for your review. There are four documents (in word and PDF).
We also expect to hear from the expert tomorrow by noon, after which we should have a clean and full document to
share, if you want to give it one last read.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00025032


c1: EFTA00024672
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=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Wed, 12 May 2021 22:44:43 +0000
Hi
It's going in the mail tomorrow and I'll email it to you as well.
Get Outlook for iOS
From:
Sent: Wednesday, May 12, 2021 6:20:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
I'm working on it and hope to have it complete and ready in the next couple of days.
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.
EFTA00024672

=== Page 2 ===
From:
)"
Date: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, l'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
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, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
EFTA00024673

=== Page 3 ===
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
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, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>, "
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00024674

=== Page 4 ===
Hi
-
I'm available between 9am and 10am, and then again after 11am.
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, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
Alison
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
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
EFTA00024675

=== Page 5 ===
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:
)"
>,
(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
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(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
EFTA00024676

=== Page 6 ===
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:
)"
>,
(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
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.
EFTA00024677

=== Page 7 ===
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,
Alison
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,
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
EFTA00024678

=== Page 8 ===
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 Maurene -
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.
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)"
EFTA00024679

=== Page 9 ===
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.
Hope you are also staying safe and healthy.
Thanks,
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
EFTA00024680

=== Page 10 ===
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:
)"
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,
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
EFTA00024681

=== Page 11 ===
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:
)"
>,
)"
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
EFTA00024682


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: Accepted: Epstein defense bail submission due
Date: Wed, 10 Jul 2019 05:50:04 +0000
Importance: Normal
Attachments: unnamed
EFTA00026651


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=== Page 1 ===
From:
)"
To:
Subject: Fwd: Epstein search warrant documents
Date: Tue, 12 May 2020 17:13:56 +0000
Could you please give me a call when you have a moment? Not an emergency but when you have a chance. I'm
at
Thanks.
Sent from my iPhone
Begin forwarded message:
From:
Date: May 12, 2020 at 13:02:53 EDT
To:
Cc:
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.
EFTA00025482

=== Page 2 ===
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
in
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:
Sent: Tuesday, May 12, 2020 11:30
To:
is
Cc:
is
)
Subject: RE: Epstein search warrant documents
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.
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:
Sent: Tuesday, May 12, 2020 11:11
To:
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.
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
EFTA00025483

=== Page 3 ===
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:
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
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.
Please let us know if there are any questions.
Thank you.
From:
)
Sent: Friday, May 8, 2020 2:15 PM
To:
is
(USANYS)
is
>;
(USANYS)
Cc:
>;
>;
is
is
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:
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
i
)
>;
>;
(USANYS)
Cc:
is
>;
is
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.
EFTA00025484

=== Page 4 ===
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:
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
V.
-
V.
>;
(USANYS)
Cc:
>;
>;
is
is
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.
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:
Sent: Tuesday, April 07, 2020 15:27
EFTA00025485

=== Page 5 ===
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
>;
is
)
is
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:
is
(USANYS)
is
is
(USANYS)
Cc:
is
i
is
is
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.
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:
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
is
)
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
On Apr 7, 2020 1:55 PM,
)"
wrote:
EFTA00025486

=== Page 6 ===
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:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
is
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
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,
EFTA00025487

=== Page 7 ===
From:
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
i
(USANYS)
Cc:
is
is
is
is
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.
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
in
(USANYS)
is
is
(USANYS)
Cc:
is
is
>;
is
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:
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
>;
i
(USANYS)
Cc:
is
is
is
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.
EFTA00025488

=== Page 8 ===
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:
is
(USANYS)
>;
>;
(USANYS)
Cc:
>;
>;
>;
is
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:
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
)
>;
>;
(USANYS)
Cc:
is
>;
is
is
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.
EFTA00025489

=== Page 9 ===
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.
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:
is
Cc:
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.
EFTA00025490

=== Page 10 ===
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
EFTA00025491


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c6: pdf
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c0:
=== Page 1 ===
From:
"
To:
Cc:
Bcc: "USAHUB-USAJourmal111"
Subject: RE: Maxwell Follow Up
Date: Mon, 22 Feb 2021 22:36:21 +0000
Embedded: RE:_Maxwell_Follow_Up.msg
Sender:
Subject: RE: Maxwell Follow Up
Message-Id:
<BN3P110MB0500D7B8675C0ABCDF8CA4B490819@BN3P110MB0500.NAMP110.PROD.OUTLOOK.CO
M>
Recipient:
EFTA00026597


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
)"
Subject:
3500
Date: Fri, 19 Nov 2021 14:55:16 +0000
Embedded: Re:_[EXTERNAL]_Re:_travel.msg; Re:_[EXTERNALJ_Re:_travel(1).msg
Hey
Would you mind adding these emails to
3500 and witness folder when you get a chance?
Also, one of the emails has some attachments that we should produce in Rule 16 if we haven't already. Would you mind
de-duping or having someone de-dupe them? We're not sure if we already received these from Interlochen.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00024899


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c0:
=== Page 1 ===
From:
To:
Subject: RE: Draft RTC
Date: Tue, 17 Aug 2021 14:45:06 +0000
Attachments: Maxwell_RTC_v7.moe.LP_(MC).docx
Thanks
My comments/edits attached.
From:
Sent: Friday, August 13, 2021 11:00 AM
To:
Subject: RE: Draft RTC
Thanks so much,
Some small suggestions on top of
comments.
From:
Sent: Wednesday, August 11, 2021 8:01 PM
To:
Subject: RE: Draft RTC
Thanks,
and
just a nudge to look at this when you have a chance? I'd like to get this up to
sometime
soon.
From:
Sent: Monday, August 9, 2021 4:14 PM
To:
Subject: RE: Draft RTC
Thanks very much. Attached are some comments. Once the team has had a chance to review, we can discuss whether we
might want to do a "cleanup" superseder to fix any statutory language in the indictment, or whether any issues are either
harmless or can be resolved by not giving the indictment to the jury (or amending/redacting the version that goes back to
cure any issues).
Thanks!
From:
Sent: Friday, August 6, 2021 7:28 PM
To:
Subject: Draft RTC
Hi all,
EFTA00023892

=== Page 2 ===
Attached is a draft RTC for your review. I've left in some comment bubbles to flag some of the judgment calls, and I'm
going to clean up the cites/do a citecheck.
Looking forward to your comments.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00023893


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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
Event: Proffer:
Start Date: 2019-07-12 16:00:00 +0000
End Date: 2019-07-12 19:30:00 +0000
Organizer
Class: X-PERSONAL
Date Created: 2019-07-10 18:57:36 +0000
Date Modified: 2019-07-10 18:57:36 +0000
Priority: 5
DTSTAMP: 2019-07-10 18:42:05 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00026687


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=== Page 1 ===
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 25, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today the Government is producing additional materials, including Jencks Act and
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today's production.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. Please note that the records stamped 3501.507 through 3501.516 were previously
produced to you on October 11, 2021 with a different stamp (3501.450 through 3501.459), which
was inadvertently used for two sets of witnesses. The Government is reproducing the materials to
avoid any confusion. This production should not be taken to indicate that the Government believes
it has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
EFTA00025035

=== Page 2 ===
Page 2
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
Please note that this letter, the enclosed indices, and the enclosed materials are
governed by the July 31, 2020 Protective Order in this case. In particular, the entire production
is designated as "confidential" under the Protective Order. The index is itself designated as
"confidential," because it includes information regarding records designated as
"confidential" under the Protective Order. The Department of Justice directed this office to
cease the dissemination of materials marked with the word "confidential" in order to avoid
potential confusion with markings reserved for classified documents. Accordingly, in order to
note the appropriate designation of this production under the operative Protective Order in this
case, the materials being produced today are marked with the following label: "SUBJECT TO
PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to
the specific paragraphs of the Protective Order that govern today's production.
Additionally, please note that many of the individuals referenced in this production are
represented by counsel, as detailed in the enclosed indices. The Government reserves its right to
amend and supplement these disclosures.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
Assistant United States Attorneys
EFTA00025036


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c0:
=== Page 1 ===
From: "
To:
Cc: II
Subject: RE: USAO SDNY Prisoner for Court Production Request
Date: Tue, 09 Jul 2019 21:59:59 +0000
Importance: Normal
Correction below-this will be at 10 a.m. Thanks.
From:
Sent: Tuesday, July 9, 2019 2:14 PM
To:
Cc:
Subject: USAO SDNY Prisoner for Court Production Request
PRISONER PRODUCTION FOR COURT REQUEST
Use this e-mail only to order defendants for Court.
DATE
7/15/19
TIME
10 am
JUDGE
Berman
COURT
17B
ROOM
PRODUCTION TYPE (enter X in box to the right of
CASE#
19 Cr. 490 (RMB)
description)
Arraignment
Bond hearing
Bond signing
Change of plea
Detention hearing
X
Fatico hearing
Motion hearing
Other, describe below
Preliminary
Revocation hearing
Revocation &
Sentencing
hearing
sentencing
Status hearing
Suppression
Trial
Material witness
hearing
Defendant
USMS #
On writ status
USMS use only/report result to
(indicate Y only)
CrimSec
Sentence
Time served
Detainer
1
Jeffrey Epstein
76318-
054
2
3
4
5
6
7
8
9
EFTA00026656

=== Page 2 ===
10
REMARKS (security precautions, separations, violent crime charge, not standard release issues):
AUSA NAME
AUSA
PHONE
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00026657


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=== Page 1 ===
From:
To:
)"
Cc:
Christian Everdell
,
"Mark S. Cohen"
)"
Subject: RE: Pretrial Interview - Ghislaine Maxwell
Date: Mon, 06 Jul 2020 19:04:02 +0000
ok
From:
Sent: Monday, July 6, 2020 1:35 PM
To
Cc:
Christian
Everdell
; Mark S. Cohen
Subject: Re: Pretrial Interview - Ghislaine Maxwell
I will handle this matter.
Thanks
U.S. Pretrial Services
On Jul 6, 2020, at 1:33 PM,
wrote:
Good afternoon,
Copied on this email are Chris Everdell and Mark Cohen, two attorneys representing defendant Ghislaine Maxwell in
case number 20 Cr. 330 (AJN). Please let them know how they can arrange for a pretrial interview with their client in
advance of her bail hearing this week.
If you need any additional information, please do not hesitate to contact me.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00024562

=== Page 2 ===
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c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: FW: GM Suppression Replies
Date: Wed, 17 Mar 2021 15:32:26 +0000
Attachments: !Reply_Memo_of_Law_ISO_Motion_to_Suppress_Evidence_Obtained_from_BSF_Subpoe
na (Unredacted).pdf;
!Reply_Memo_of_Law_ISO_Motion_to_Suppress_BSF_Subpoena_Under_4A,_5A,_Martin
dell.pdf
From:
(USANYS)
Sent: Tuesday, March 16, 2021 7:40 PM
To:
Subject: GM Suppression Replies
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00024027


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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 1 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 1 of 9
USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT
ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK
DOC #:
-
X
:
DATE FILED: July 25,3019
UNITED STATES OF AMERICA
:
:
PROTECTIVE ORDER
- V. -
:
:
19 Cr. 490 (RMB)
JEFFREY EPSTEIN,
:
:
Defendant.
:
:
X
RICHARD M. BERMAN, United States District Judge:
WHEREAS the Government intends to produce to JEFFREY
EPSTEIN, the defendant, certain documents and materials that
(1) affect the privacy and confidentiality of individuals,
(ii) would impede, if prematurely disclosed, the Government's
ongoing investigation of uncharged individuals; (iii) would risk
prejudicial pretrial publicity if publicly disseminated, and
(iv) is not authorized to be disclosed to the public or
disclosed beyond that which is necessary for the defense of this
action, and other materials pursuant to Federal Rule of Criminal
Procedure 16 ("Rule 16") and pursuant to any other disclosure
obligations (collectively, the "Discovery"), which contain
sensitive, confidential, or personal identifying information;
WHEREAS, the Government seeks to protect sensitive,
confidential, or personal identifying information contained in
the materials it produces consistent with Rule 16 or other
disclosure obligations;
1
EFTA00026772

=== Page 2 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 2 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 2 of 9
WHEREAS the defendant, through his counsel, consents
to the entry of this Order;
IT HEREBY IS ORDERED:
1. The Discovery disclosed to the defendant
("Defendant") and/or to the defendant's attorneys ("Defense
Counsel") during the course of proceedings in this action:
a) Shall be used by the defendant or his
counsel solely for purposes of the defense of this action;
b) Shall not be copied or otherwise recorded or
transmitted by the defendant;
c) Shall not be disclosed or distributed in any
form by the defendant or his counsel except as set forth in
paragraph 2 (d) below;
d) May be disclosed only by Defense Counsel and
only to the following persons ("Designated Persons"):
i. investigative, secretarial, clerical,
or paralegal personnel employed full-time or part-time by the
defendant's counsel ("Defense Staff");
ii. any expert, advisor, or any other
individual retained or employed by the Defendant and Defense
Counsel for the purpose of assisting in the defense of this case
("Defense Experts/Advisors");
iii. such other persons as hereafter may be
authorized by Order of the Court ("Other Authorized Persons");
2
EFTA00026773

=== Page 3 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 3 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 3 of 9
e) May be shown to, but not disseminated to or
provided copies of to, prospective witnesses and their counsel
(collectively, "Potential Witnesses"), to the extent deemed
necessary by defense counsel, for trial preparation.
2. To the extent the Discovery is disclosed to
Defense Staff, Defense Experts/Advisors, Other Authorized
Persons, or Potential Witnesses, Defense Counsel shall instruct
such individual (s) of the terms of this Order and that such
individual (s) are bound by this Order. To the extent that
Discovery is disseminated to Defense Staff, Defense
Experts/Advisors, or Other Authorized Persons, Defense Counsel
shall encrypt and/or password protect the Discovery. The
provisions of this paragraph do not apply to communications
exclusively between and among Defense Counsel.
3. The Government, the Defendant, Defense Counsel,
Defense Staff, Defense Experts/Advisors, Potential Witnesses,
and Other Authorized Persons are prohibited from posting or
causing to be posted any of the Discovery or information
contained in the Discovery on the Internet, including any social
media website.
4. The Government (other than in the discharge of
their professional obligations in this matter), Defense Counsel,
Defense Staff, Defense Experts/Advisors, Potential Witnesses,
and Other Authorized Persons are precluded from publicly
3
EFTA00026774

=== Page 4 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 4 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 4 of 9
disclosing or disseminating the identity of any victims or
witnesses referenced in the Discovery. This Order does not
prohibit Defense Counsel from publicly referencing individuals
who have spoken on the public record in litigation - criminal or
otherwise -- relating to Jeffrey Epstein.
5. The Defendant, Defense Counsel, Defense Staff,
Defense Experts/Advisors, Potential Witnesses, and Other
Authorized Persons are prohibited from filing publicly as an
attachment to a filing or excerpted within a filing any of the
Discovery or information contained in the Discovery, unless
authorized by the Government in writing or by Order of the
Court. Any filings that incorporate the Discovery by
attachment, contain any excerpts of Discovery, or incorporate
Discovery by reference must be filed under seal. Nothing in
this Order precludes Defense Counsel from using the Discovery in
judicial proceedings in this case.
6. Copies of Discovery or other materials produced
by the Government in this action bearing "confidential" stamps
or otherwise designated as "confidential" and/or electronic
Discovery materials designated as "confidential" by the
Government, including such materials marked as "confidential"
either on the documents or materials themselves, or designated
as "confidential" in a cover letter, index, folder title, or
4
EFTA00026775

=== Page 5 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 5 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 5 of 9
other identifying designation, are deemed "Confidential
Information."
7.
Confidential Information may contain personal
identification information of specific individuals who are not
parties to this action, and other confidential information; as
well as information that identifies, or could lead to the
identification of, witnesses in this matter. The Government's
designation of material as Confidential Information will be
controlling absent contrary order of the Court.
8. Confidential Information disclosed to the
defendant, or Defense Counsel, respectively, during the course
of proceedings in this action:
a) Shall be used by the defendant or his
counsel only for purposes of the defense of this action;
b) Shall be maintained in a safe and secure
manner solely by Defense Counsel;
c) Shall be reviewed by the Defendant solely in
the presence of Defense Counsel;
d) Shall not be possessed outside the presence
of Defense Counsel, or maintained, by the Defendant;
e) May be disclosed only by Defense Counsel and
only to Designated Persons;
f) May be shown to, but not disseminated to or
provided copies of to, Potential Witnesses, to the extent deemed
5
EFTA00026776

=== Page 6 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 6 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 6 of 9
necessary by defense counsel, for trial preparation, and after
defense counsel and/or Defense Staff instructs such
individual (s) of the terms of this Order and that such
individual (s) are bound by this Order.
9.
Copies of Discovery or other materials produced
by the Government in this action bearing "highly confidential"
stamps or otherwise designated as "highly confidential" and/or
electronic Discovery materials designated as "highly
confidential" by the Government, including such materials marked
as "highly confidential" either on the documents or materials
themselves, or designated as "highly confidential" in a cover
letter, index, folder title, or other identifying designation,
are deemed "Highly Confidential Information."
10. Highly Confidential Information contains images
of nude or partially-nude individuals. The Government's
designation of material as Highly Confidential Information will
be controlling absent contrary order of the Court. Highly
Confidential Information disclosed to Defense Counsel during the
course of proceedings in this action:
a) Shall not be disseminated, transmitted, or
otherwise copied and provided to Defense Counsel or the
Defendant;
b)
Shall be reviewed by the Defendant solely in
the presence of Defense Counsel;
6
EFTA00026777

=== Page 7 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 7 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 7 of 9
c) Shall not be possessed outside the presence
of Defense Counsel, or maintained, by the Defendant;
d) Shall be made available for inspection by
Defense Counsel and the Defendant, under the protection of law
enforcement officers or employees; and
e) Shall not be copied or otherwise duplicated
by Defense Counsel or the Defendant during such inspections.
11. The Defendant and Defense Counsel shall provide a
copy of this Order to Designated Persons to whom they disclose
Confidential Information or Highly Confidential Information.
Prior to disclosure of such information to Designated Persons,
any such Designated Person shall agree to be subject to the
terms of this Order by signing a copy hereof and stating that
they "Agree to be bound by the terms herein," and providing such
copy to the defendant's counsel. However, the defendant and his
or her respective counsel need not obtain signatures from any
member of the defense team (i.e., attorneys, experts,
consultants, paralegals, investigators, support personnel, and
secretarial staff involved in the representation of the
defendants in this case), all of whom are nonetheless bound by
this Protective Order.
12. Except for Discovery that has been made part of
the record of this case, Defense Counsel shall return to the
Government or securely destroy or delete all Discovery,
7
EFTA00026778

=== Page 8 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 8 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 8 of 9
including but not limited to Confidential Information, within 30
days of the expiration of the period for direct appeal from any
verdict in the above-captioned case; the period of direct appeal
from any order dismissing any of the charges in the above-
captioned case; the expiration of the period for a petition
pursuant to 28 U.S.C. $ 2255; or the granting of any motion made
on behalf of the Government dismissing any charges in the above-
captioned case, whichever date is later.
8
EFTA00026779

=== Page 9 ===
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 9 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 9 of 9
13. The foregoing provisions shall remain in effect
unless and until either (a) the Government and Defense Counsel
mutually agree otherwise, or (b) this Order is modified by
further order of the Court.
so ORDERED:
Dated:
New York, New York
July 25. 2019
Richard M. BERMAN /AR
HONORABLE RICHARD M. BERMAN
United States District Judge
AGREED AND CONSENTED TO:
Dated: July 24, 2019
New York, New York
GEOFFREY S. BERMAN
United States Attorney
Southern District of New York
By:
/s/
Alison Moe / Alex Rossmiller / Maurene Comey
Assistant United States Attorneys
Dated: July 25, 2019
New York, New York
JEFFREY EPSTEIN
By: Mariel Martin Weinberg, Esq.
Reid Weingarten, Esq.
Counsel for Jeffrey Epstein
9
EFTA00026780


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=== Page 1 ===
From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Tue, 09 Mar 2021 20:38:29 +0000
Attachments: SDNY_GM_00173008_[CONFIDENTIAL].xlsx
Inline-Images: image001.jpg
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
EFTA00025206

=== Page 2 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
EFTA00025207

=== Page 3 ===
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00025208


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=== Page 1 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
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.
EFTA00026465


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: for the AUSA handling the new investigation
Date: Sat, 10 Aug 2019 21:33:51 +0000
We just got word from C-19 that Epstein made a phone call last night to Kristina Schuliak (ph), who is his current / latest
girlfriend, around 7:00 p.m. The agents contacted her, she said she wanted a lawyer, and the agents have now heard from
her lawyer who says she'll tell them about the content of the phone call but she wants some kind of protections. It sounds
like the girlfriend is willing to talk sooner rather than later, so whenever someone is assigned to the new investigation, we
can put him or her in touch with that agent for whatever follow-up is appropriate.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00024497


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: 302s (1 of 3)
Date: Thu, 23 Apr 2020 17:29:17 +0000
Attachments: 050D-NY-3027571_0000349.pdf; 050D-NY-3027571_0000350.pdf; 050D-NY-
3027571_0000340.pdf; 050D-NY-3027571_0000344.pdf; 050D-NY-3027571_0000345.pdf;
050D-NY-3027571_0000346.pdf; 050D-NY-3027571_0000347.pdf; 050D-NY-
3027571_0000348.pdf
I think this is helpful timing, since you have our naming and tracking systems up and running - we just got three emails
with a bunch of new 302s for the Epstein case. I believe they should all be interview 302s, but let us know if there are
other random reports as well. We got three emails with 302s attached, this is the first and l'll also send the other two -
could you please save each of the files into the correct witness folder, keeping the same naming convention, and update
the Interview Tracker spreadsheet as you go?
And then let us know when that's complete, and I'll look through and we can figure out what remains outstanding. Please
let us know if any questions at all, either up front or as you go through, and thanks as always.
From:
Sent: Wednesday, April 22, 2020 21:28
To:
is
Cc:
Subject: 302s (1 of 3)
Hey all,
Attached are the 302s that have been serialized since the last batch. It's too large to come in one email, so I'm
sending in 3 for a total of 24 302s right now.
EFTA00025098


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=== Page 1 ===
From:
To:
Subject: Former Teen Model Describes Jeffrey Epstein's Sex Abuse | TODAY - YouTube
Date: Wed, 13 Oct 2021 01:05:10 +0000
https://m.youtube.com/watch?v-
EFTA00026700


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
)"
Subject: RE:
question
Date: Sun, 10 Oct 2021 00:35:58 +0000
Embedded: Epstein_status.msg
was the attached in the
materials we got from
? Thanks!
From:
(USANYS) [Contractor]
Sent: Saturday, October 9, 2021 8:26 PM
To:
(USANYS)
is
(USANYS) [Contractor]
^
Cc:
Subject: RE:
question
This was also in the UNET duplicates folder. Looks like the image didn't load when it was converted. I can PDF this too and
include the image. Will send shortly.
From:
(USANYS)
Sent: Saturday, October 9, 2021 8:23 PM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
Subject: RE:
question
Can you find the email with the image you sent
in this chain? The image isn't embedded here. Thanks!
From:
(USANYS)
Sent: Saturday, October 9, 2021 8:00 PM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
Subject:
question
Can you please find the email
sent to
on July 14 at 16:09 pm? It is referenced in the attached but we
don't see it in the de-duped folders.
email should have a spreadsheet attached to it. You can email it to us here.
Thanks!
Lara
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00025274

=== Page 2 ===
EFTA00025275


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: Re:
Date: Fri, 30 Aug 2019 11:57:07 +0000
Thanks for putting us in touch!
Sent from my iPhone
> On Aug 30, 2019, at 7:44 AM,
(USANYS)
wrote:
>
>
Thanks!
>
On Aug 30, 2019, at 7:35 AM,
)
wrote:
H
Thanks, we'd be happy to speak with her. Please feel free to give her our contact info.
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 6:16 AM,
(USANYS)
wrote:
Hey guys,
I got the below text from
an AUSA in Boston, about a potential Epstein victim. Can I put her in
touch with you? Thanks!
I have a non-drug related question for you. Can you tell me who in your office is/was handling the Epstein
case? Long story short, a friend of a family friend was a model in NYC 20 years ago and was taken to Epstein's
townhouse one night. Not sure what happened be I haven't spoken to her yet, but I understand something
happened. She has talked to David Boise, and his firm is now all over her with calls and she doesn't know what
to do. I said i would talk to you but don't know if your office is still involved in the case at all or is in touch with
victims. If so, I can steer her in the right direction. I know it's an odd text, so thanks for any connection you can
make for me. Thanks and look forward to seeing you in DC.
EFTA00024434


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Sun, 23 Feb 2020 02:11:57 +0000
Understood, thanks.
From:
Sent: Saturday, February 22, 2020 20:38
To:
Cc:
is
;
Subject: Re: Epstein search materials for upload and privilege review
Totally understand, just wanted to alert you to the technical issues that may slow things down. In the interim, I've created
a Saved Search with all the Search Warrant Returns and the 1.23.20 Load. It's called "SW Returns Plus 1.23.20 Load" so
you can run your searches in that. Let me know if you want me add any more fields or modify it.
On Feb 22, 2020, at 7:22 PM,
)
wrote:
Totally understand it's voluminous, but we do to need to move it because otherwise our searching process will be all
messed up - we won't be able to run terms through all search warrant returns (instead, we'd have to duplicate literally
every search across two different huge folders). And it doesn't work to just search all materials in the entire file because
the FBI case file is also huge.
If going forward there is any question at all on where things should go in the folder structure, we're more than happy to
provide guidance on that.
From:
Sent: Friday, February 21, 2020 17:04
To:
Cc:
is
>;
Subject: Re: Epstein search materials for upload and privilege review
Moving may be an issue, PAE had trouble releasing the data because they were so voluminous.
EFTA00026865

=== Page 2 ===
On Feb 21, 2020, at 4:55 PM,
wrote:
Ah, possibly it's the "2020-01-23" folder under Subpoena Returns? If so,
can we please (1) move that to under
the Search Warrant Returns folder, and (2) if at all possible, combine the 37 different subfolders into one? There
doesn't appear to be any distinction between all of those folders so I don't think there's any utility in having so many
subgroups. But let us know if (2) is a problem and happy to discuss.
From:
Sent: Friday, February 21, 2020 16:53
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
I think they are in the Subpoena Returns folder, which I thought was strange. I'm heading to
now but will log
in after that to find them.
From:
Sent: Friday, February 21, 2020 4:32 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
just tried calling but didn't catch you - I don't see where these are located in Relativity? I think they should be
under "Search Warrant Returns" but I don't see them there (or anywhere else under the Epstein overall folder). Let
me know if I've just missed them, which is entirely possible, or if they're not accessible to us yet? Thank you!
From:
Sent: Thursday, February 20, 2020 21:12
To:
in
Cc:
is
Subject: Re: Epstein search materials for upload and privilege review
The NP folder has been released.
On Feb 20, 2020, at 2:28 PM,
wrote:
Here's the STR and the data should be released soon, it's just taking a while because the load is so large.
EFTA00026866

=== Page 3 ===
From:
Sent: Thursday, February 20, 2020 11:42 AM
To:
>;
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
New data is loaded and we've segregated the PP hits; you should have access to the new data today. Will keep you
posted.
Thanks,
From:
)
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
)
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be
grateful - and we'll plan to get it to
asap once we have access.
EFTA00026867

=== Page 4 ===
thanks,
From:
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection
with the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied
here)? I've left the hard drive with the materials on your chair. (And if we could please get that hard drive back once
the materials are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will
also be coming shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with
Epstein search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
<STR_Epstein_Privilege Terms_02.14.2020.pdf>
EFTA00026868


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c0:
=== Page 1 ===
From:
To:
Subject: Fwd: United States V. Ghislaine Maxwell --
Date: Sun, 28 Nov 2021 15:30:03 +0000
Get it, team! And yay for
Begin forwarded message:
From
Date: November 28, 2021 at 9:59:11 AM EST
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>, USANYS-CRIMINAL
PARALEGALS <USANYS-CRIMINALPARALEGALS@usa.doj.gov>, USANYS-INVESTIGATORS
<USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00024897


c1: EFTA00023728
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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein search warrant documents
Date: Tue, 07 Jul 2020 19:51:35 +0000
If it's huge, he said he should look at it first, to make sure it's in a format that they can deal with, and if it's small it can go
directly to PAE (since even if it's screwed up, they won't take much time on it).
But also, it likely won't be clear what we're getting from the hard drive itself, so given that we're receiving a subset of the
devices, we just want to know which ones are on the drive.
All that said, if he doesn't respond, we'll just take the drive and send it to
From:
(USANYS)
Sent: Tuesday, July 07, 2020 15:49
To:
Cc:
is
Subject: RE: Epstein search warrant documents
I wouldn't count on a response from
- he won't response quickly, and we'll end up annoyed. Just out of curiosity,
what is the significance of knowing what is on the drive before sending to PAE? Is there any particular work
is doing
in his initial review that we need done?
From:
Sent: Tuesday, July 7, 2020 3:43 PM
To:
(USANYS)
Cc:
is
Subject: FW: Epstein search warrant documents
We didn't get any devices yesterday, but
said that
is picking up the hard drive from
today. I spoke
with
who normally takes an initial look at this stuff (but is working remotely). Depending on the volume, the
devices will either go to him or directly to PAE. Just need to know from
what we're actually getting.
From:
Sent: Tuesday, July 07, 2020 15:42
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
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:
EFTA00023728

=== Page 2 ===
How many total devices are coming to us in this initial production?
What are those devices - i.e., type of device and which ones, from the spreadsheets you've sent?
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)'
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
is
)
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
Senior Forensic Examiner
cell
desk
EFTA00023729

=== Page 3 ===
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)
i
(NY) (FBI)
i
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)
V.
(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,
EFTA00023730

=== Page 4 ===
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(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)
i
)
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
Senior Forensic Examiner
EFTA00023731

=== Page 5 ===
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)
>;
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
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
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
is
EFTA00023732

=== Page 6 ===
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
Senior Examiner
EFTA00023733

=== Page 7 ===
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
>;
(NY) (FBI)
in
(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
i
(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
EFTA00023734

=== Page 8 ===
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]
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
EFTA00023735

=== Page 9 ===
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
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
EFTA00023736

=== Page 10 ===
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.
Please let us know if there are any questions.
Thank you.
EFTA00023737

=== Page 11 ===
From:
)
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
i
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)
is
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
y.
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)
is
)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(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.
EFTA00023738

=== Page 12 ===
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:
)
>;
(USANYS)
is
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
V.
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.
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)
EFTA00023739

=== Page 13 ===
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
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
i
>;
(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)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
i
(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
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:
EFTA00023740

=== Page 14 ===
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)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
>;
)
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.
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)
is
EFTA00023741

=== Page 15 ===
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
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)
is
)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
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
i
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
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.
EFTA00023742

=== Page 16 ===
(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)
V.
(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., 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,
EFTA00023743

=== Page 17 ===
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
EFTA00023744


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Scanned black book & yellow pages of notes
Date: Fri, 29 Oct 2021 13:56:27 +0000
Attachments: 2021.10.29 MDC - Maxwell_PASSWORD.docx; 2021.10.29_MDC_-
Maxwell_MAIN.docx
Disc for Maxwell has been burned, and cover letters are attached. Let me know if you have any changes or if these are
good to go out, thanks!
From:
>
Sent: Thursday, October 28, 2021 8:23 PM
To:
is
Cc:
is
Subject: RE: Scanned black book & yellow pages of notes
Great. And to confirm, we can send out a CD with these materials to the MDC to the defendant tomorrow?
From:
>
Sent: Thursday, October 28, 2021 8:22 PM
To:
is
Cc:
is
Subject: RE: Scanned black book & yellow pages of notes
Great, I'm ready to share on USAfx when you do.
From:
>
Sent: Thursday, October 28, 2021 8:21 PM
To:
is
Cc:
is
Subject: RE: Scanned black book & yellow pages of notes
Thanks,
!
I am going to send out in a few.
From:
Sent: Thursday, October 28, 2021 7:46 PM
To:
is
Cc:
is
Subject: RE: Scanned black book & yellow pages of notes
These have been added to the production (here).
Updated cover letter is attached.
EFTA00025163

=== Page 2 ===
From:
Sent: Thursday, October 28, 2021 7:34 PM
To:
is
Cc:
is
Subject: FW: Scanned black book & yellow pages of notes
Can we please add these to the pending production to send out tonight? They should marked confidential. The black
book should be described in the index as "Scan of 1 bound black address book marked Government Exhibit 52, as referred
to in SDNY_GM_02753612"; "Scan of 2 stapled handwritten set of documents on yellow legal pad paper, as referred to in
SDNY_GM_02753612"
Can you resend me the updated cover letter once that is ready?
Thanks!
From:
Sent: Thursday, October 28, 2021 7:19 PM
To:
is
is
Subject: [EXTERNAL] Scanned black book & yellow pages of notes
See attached.
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
EFTA00025164


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
(USANYS)"
Subject: RE: Epstein
Date: Tue, 26 Feb 2019 17:29:00 +0000
Importance: Normal
Great
Original Message
From:
(USANYS) [Contractor]
Sent: Tuesday, February 26, 2019 11:17 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein
OK sounds good. Should we say 1:30?
Original Message
From:
(USANYS)
Sent: Tuesday, February 26, 2019 11:03 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
Subject: RE: Epstein
Why don't we start with
n that window if we can grab 10 minutes. We can follow up with whole group
tomorrow if necessary -- noon is middle of Cohen testimony.
Original Message
From:
(USANYS) [Contractor]
Sent: Tuesday, February 26, 2019 10:51 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein
Unfortunately because of interviews there aren't slots when full brass is available.
is around 1:30-3:30 if
you want to bring him up to speed. The full group could meet tomorrow at noon or 5:30pm.
Original Message
From:
(USANYS)
Sent: Tuesday, February 26, 2019 10:46 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
Subject: Epstein
asked that we set up a brass meet on Epstein - any time today? Should be 30 min.
Sent from my iPhone
EFTA00024723


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=== Page 1 ===
From:
"
)"
To:
)"
)"
=
Cc:
)"
Subject: FW: 19CR490
Date: Fri, 12 Jul 2019 00:04:54 +0000
Importance: Normal
Attachments: 19CR490_7.11.19_7.43pm.pdf
From:
On Behalf Of
BermanNYSDChambers@nysd.uscourts.gov
Sent: Thursday, July 11, 2019 19:45
To:
Subject: 19CR490
EFTA00026689


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: US V Jeffery Epstein
Date: Tue, 09 Jul 2019 19:21:35 +0000
Importance: Normal
Thank you for passing this along.
Assistant United States Attorney
Southern District of New York
From:
Sent: Tuesday, July 9, 2019 3:16 PM
To:
Cc:
Subject: US V Jeffery Epstein
Counsel:
As Duty Assistant yesterday, the EDNY received this phone call from a potential witness in the Epstein case. Though
referred to the FBI, he indicated he only wished to speak to someone from the USAO. Having failed to get someone at the
SDNY he called here. An investigator from our office witnessed the call and his Memorandum of the call is attached. We
indicated that we would refer the matter to you and that an investigator from the SDNY might be in contact with him.
Assistant U.S. Attorney
Senior Investigative Counsel
Eastern District of New York
office
cell
EFTA00026658


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=== Page 1 ===
From: "Moyne, Parvin"
To:
Cc: Andrew Stemmer
"Moyer, Thomas"
>, "DiPiero, Joseph"
Subject: Exhibit - Timeline of Payments to Potential Co-Conspirators (002).pdf
Date: Fri, 06 Sep 2019 16:46:33 +0000
Attachments: Exhibit_-_Timeline_of_Payments_to_Potential_Co-Conspirators_(002).pdf
-
As requested, please find attached the payment information we identified for the names/entities you requested, as well
as other potentially-related or similar transactions. This includes any payments we have identified for the different
variations on
As always, we are happy to answer any questions.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
I
Direct
I
Internal:
Fax:
I
akingump.com
Bio
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00027018


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=== Page 1 ===
From:
To:
Subject: RE: BOP Devices
Date: Thu, 05 Mar 2020 13:20:41 +0000
- rather than forwarding this to you again, can you find the initial email from
and save the materials on the
shared?
Thanks!
From:
Sent: Wednesday, March 04, 2020 9:32 AM
To:
is
is
is
Subject: BOP Devices
The DOJ OIG Cyber team completed the analysis of the BOP devise. Attached is the report, they found one discussion of
Epstein in a text exchange.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
)
EFTA00023915


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Sat, 10 Aug 2019 21:14:54 +0000
,
It was nice speaking with all of you and I appreciate the offer of assistance on this.
,
Please see the AUSA team copied here and reach out to them for any assistance you may need from SDNY.
Thanks,
Supervisory Special Agent
FBI/NYPD
Violent Crimes Task Force
On Aug 10, 2019 4:50 PM,
)" wrote:
-
I am cc'ing our team for you to connect them with the relevant agents on your side.
Thanks very much,
EFTA00024499


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=== Page 1 ===
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 8, 2020
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
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
EFTA00026819

=== 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.
EFTA00026820

=== 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
EFTA00026821

=== 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.¹ 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.
EFTA00026822

=== 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.
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.
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 Bureau of Prisons ("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.
...
EFTA00026823

=== 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
EFTA00026824


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=== Page 1 ===
From:
To:
Subject: Epstein Indictment
Date: Fri, 12 Jun 2020 00:37:01 +0000
Attachments: 2019-07-01,_JE,_first_indictment,_final.docx
Here's the word version.
EFTA00023754


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=== Page 1 ===
From:
To:
Subject: Fwd:
Date: Tue, 15 Oct 2019 15:48:28 +0000
Attachments: Palm_Beach_Police_Reports.pdf; ATT00001.htm
Sent from my iPhone
Begin forwarded message:
From:
To:
Cc:
Subject:
In case you meet with her, here are the police reports about her calls with
and
The first page
addresses the threat, and later pages address the call records around that time.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York NY 10007
EFTA00025381


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein -- Release of USMS information
Date: Fri, 13 Sep 2019 18:43:00 +0000
These are some examples of the information that was released.
https://www.miamiherald.com/news/state/florida/article235039542.html
https://www.cnn.com/2019/09/11/us/jeffrey-epstein-investigation-us-marshals-documents/index.html
From:
(USANYS)
Sent: Friday, September 13, 2019 2:22 PM
To:
(USANYS)
Subject: Re: Epstein -- Release of USMS information
Can you forward to me the more problematic articles.
On Sep 13, 2019, at 2:01 PM,
(USANYS)
wrote:
As you are undoubtedly aware, there has been some press coverage since yesterday about the release pursuant to FOIA
of some USMS records. I just spoke with the Associate General Counsel at the USMS, who wanted to provide us with
the actual source materials (USM 11s (equivalent of 302s)) that were inadvertently released, because they were not in
all circumstances accurately reported, and he wanted to make sure that if we are concerned about any harm to our
investigation from the release, that we have the original materials. He also offered to serve as a POC if we have any
questions.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00024171


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE
)
- Epstein
Date: Sun, 07 Jul 2019 20:04:30 +0000
Importance: Normal
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules may be
somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for before you
meet with Ms.
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check in
tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being in
touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Saturday, July 06, 2019 22:55
To:
)
Subject:
)
- Epstein
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
)
- Epstein
Mr.
My former partner,
, represented
(now known as
), prior to his passing in 2018.
Agent
served Ms.
with a grand jury subpoena earlier today, and as
former partner and
FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet with her until
Tuesday, but I would appreciate a few minutes of your time at your convenience as I am getting up to speed.
Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
EFTA00026624

=== Page 2 ===
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00026625


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=== Page 1 ===
From:
To:
Subject: Re: AUSA
ECC package
Date: Sun, 18 Oct 2020 21:50:26 +0000
I sent
an email from
and he said thanks so we are ok.
Sent from my iPad
On Oct 18, 2020, at 5:22 PM,
)
wrote:
Hi
Thanks so much - and sorry for the slow reply. From the email chain I've attached, it sounds like it's possible
has
already sent you an email approving. But if not, I'm attaching our travel memo-- perhaps we can just use the text from
the memo if that's easier than endorsing the document.
Thanks for all of your help coordinating this trip, our whole team really appreciates it.
Best,
From:
Sent: Friday, October 16, 2020 9:42 AM
To:
Cc:
Subject: Re: AUSA
ECC package
I think we, or me, missed this
I will have
sen me an email saying Something like this. Edit it for me.
The SDNY requests approval for travel by AUSA
to the U.K. from October XX to October Yu, 2020. This travel
is required at this time as Ms.
will be conducting an interview of victim/witness in the case against Glaine Maxwell.
The victim was a victim of Jeffrey Epstein. She will only talk to us person and it is necessary for us to get her statement
on the record to preserve the government's right to use her at trial.
Please approve her travel to the U.K.
Acting United States Attorney.
Sent from my iPad
On Oct 16, 2020, at 9:05 AM,
wrote:
Hi
Do you happen to have the signed memo from
?1 think that's what the email below is asking me for, but not
exactly sure. Thanks! Hope you're doing well.
Sent from my iPhone
Begin forwarded message:
From: USAEO-Foreign Travel
Date: October 16, 2020 at 1:52:34 PM GMT+1
EFTA00027064

=== Page 2 ===
To:
Cc: USAEO-Foreign Travel
Subject: RE: AUSA
ECC package
AUSA
Please forward your USA approval for tip ID 11312503, so I can approve your travel authorization?
v/r
Executive Office for U.S Attorneys
Foreign Travel
From:
Sent: Monday, October 5, 2020 5:17 PM
To:
>; USAEO-Foreign Travel
Cc:
Subject: RE: AUSA
ECC package
Thank you. A visa is not required for this trip.
Much appreciated-
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, October 5, 2020 4:58 PM
To: USAEO-Foreign Travel
>;
Cc:
Subject: AUSA
ECC package
Importance: High
Hi RMP, Please see the attached ECC request package for AUSA
If required, please inform the traveler how to determine who the POC is for this trip.
Please advise the traveler of any additional steps they may need take.
Hi
,
Please let EOUSA know if you have checked to see if a visa is required for your destination.
View the state dept. link for the country you are traveling to visa link for the country you are traveling to.
Visa policies may be found on the Department of State's website or on the website hosted by each country's embassy.
https://travel.state.gov/content/passports/en/country.html
Traveler, Consult EOUSA usaeo.foreign.travel@usdoj.gov mailbox to obtain a visa for you.
To provide sufficient time for the State Dept. to issue the authorization letter and for the foreign government to process the
visa request, it is recommended that visa request package be submitted to EOUSA's RMP Travel.
Staff 15 business days prior to the proposed date of departure.
Thank you
<2020.10.2 Travel Memo London.docx>
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=== Page 1 ===
From:
To:
Subject: Re: JE estate meeting
Date: Sat, 21 Dec 2019 00:42:50 +0000
The protective order required defense counsel to destroy all materials we produced to them at the end of the case,
and Epstein's lawyers told us they did so at the nolle conference.
On Dec 20, 2019, at 5:17 PM,
wrote:
We're not yet exactly sure what our ability is to provide to the Trustees what is effectively discovery in a now-defunct
criminal case against Epstein himself; that said, I can convey that we did produce to defense counsel detailed search
warrant returns in connection with the New York property. Perhaps you would be able to obtain those from Epstein's
criminal defense counsel? In particular I believe what you're looking for would be especially at USAO_4381-4445, but
potentially also USAO_2662-4380 (though I note that a handful of those pages were marked as Confidential under a
protective order, as set forth in the discovery letter sent to counsel on July 31, 2019). We will also review the status of
the search warrant return with respect to the island property (and we have not searched the New Mexico property), and
I hope this is useful in the interim.
Separately, I've conveyed your request for a meeting to discuss the possibility of resolving the Government's potential
forfeiture claims, and I haven't yet gotten a response to relay but will let you know as soon as I do (and will also provide
these dates in connection with your request).
thanks,
From:
Sent: Thursday, December 19, 2019 19:09
To:
Cc:
Subject: JE estate meeting
To follow up on our call, can you please send us the search warrant returns/inventories and, if possible, any additional
detail regarding the items that were seized in the two searches of the New York property and the search of the New
Mexico property.
With respect to a next meeting with you and the Chief of the Criminal Division and, of course, any other colleagues you
wish to attend, the following dates in early January would be good for us:
January 3, 6 (before 2:00), 7, 8 (1:00 or later), 9 (after 11:00), or 10
Happy and Healthy New Year from Andy and me.
EFTA00024510

=== Page 2 ===
Partner
Co-Chair, White Collar Defense
Hughes Hubbard & Reed LLP
New York, NY 10004-1482
Office
Cell
Fax
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.
EFTA00024511


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=== Page 1 ===
From:
To: "Berman, Geoffrey (USANYS)"
,
Bec:
Subject: Epstein
meeting
Date: Fri, 10 Jan 2020 01:04:39 +0000
FYI, our sense that it was a good meeting was universally shared. Both
said the team was very
pleased with the thoughtful reception, and
reiterated that to me tonight. Well handled on your part.
Sent from my iPhone
EFTA00023969


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=== Page 1 ===
From:
)"
To: Gary Bloxsome
Cc: Daniel Cundy
Jennifer Richardson
)"
)"
Subject: RE: Sensitive Correspondence
Date: Tue, 28 Jul 2020 22:29:15 +0000
Attachments: Standard_Proffer_Agreement_(blank).pdf
Gary,
We write to follow up on our conversation yesterday, to confirm certain aspects of our discussion and to provide certain
information you requested. First, thank you for conveying your questions, and I hope our initial responses were of some
use. To provide additional information that may be helpful, attached please find a blank proffer agreement, which is our
standard form agreement for proffer interviews, as you requested. Please note that in addition to the provisions I briefly
described on our call, there are also provisions that may not be relevant to your client. We nevertheless send the
complete agreement for your review.
Additionally, and also as requested, certain information relating to Title 18, United States Code, Section 1001, is provided
below.
In relevant part, that statute states the following: "Except as otherwise provided in this section, whoever, in any matter
within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States, knowingly
and willfully-(1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact; (2) makes any materially
false, fictitious, or fraudulent statement or representation; or (3) makes or uses any false writing or document knowing
the same to contain any materially false, fictitious, or fraudulent statement or entry [is guilty of an offense]. The full
language of the statute is also available here.
Regarding the elements required to prove such an offense, pursuant to Sand, Modern Federal Jury Instructions, Instruction
36-3 (Elements of the Offense), a conviction for this offense require that the following elements each must be proven
beyond a reasonable doubt:
First, that on or about the date specified in the indictment, the defendant falsified (or concealed or covered up) a
material fact;
Second, that the fact falsified (or concealed or covered up) was material;
Third, that defendant did so by trick, scheme or device;
Fourth, that defendant acted knowingly and willfully; and
Fifth, that the falsification, concealment or coverup was with respect to a matter within the jurisdiction of the
government of the United States (if applicable: or that federal funds were involved).
You may note in particular the inclusion of the "knowingly and willfully" requirement, as we discussed.
We also understand that you will send us, to the extent you believe it is relevant or helpful for our consideration, any
particular provisions or protections contemplated under the MLAT process, and which of those, if any, you believe are
relevant, or should be applicable, to a voluntary interview.
We look forward to speaking with you again this coming Monday, August 3, at 4:00 p.m. (LDN time), and we further
confirm, as discussed, that our Office is prepared to extend the Negotiation Period, referenced in our email of July 14,
2020, for two weeks from our call yesterday, to August 10, 2020, under the terms previously mutually agreed upon.
Regards,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From: Dawn Hughes
To:
Cc:
Subject: Re: Expert Testimony
Date: Mon, 02 Nov 2020 18:42:50 +0000
Attachments: Curriculum Vitae - Dr._Dawn_Hughes - 2020.pdf;
Dr_Hughes_Engagement_Agreement__2020.pdf
Great. We will speak then. I have attached my CV and standard engagement agreement for your
review.
On Mon, Nov 2, 2020 at 1:37 PM
wrote:
Dr. Hughes,
Thanks very much. We are free at 2 p.m. on Wednesday, and if that works for you we can use this conference
line
Thanks,
Sent from my iPhone
On Nov 2, 2020, at 10:54 AM, Dawn Hughes
wrote:
Yes. I would be happy to speak with you all. I have some open time on Wednesday after 2:00. Let
me know what works for you.
Best,
Dr. Hughes
DAWN M HUGHES, PHD ABPP
CLINICAL AND FORENSIC PSYCHOLOGIST
On Thu, Oct 29, 2020 at 3:48 PM
wrote:
EFTA00024758

=== Page 2 ===
Dr. Hughes,
Together with colleagues,
I'm one of the federal prosecutors
handling the case of United States V. Ghislaine Maxwell, which is scheduled to go to trial on July 12, 2021
in the Southern District of New York. We would be interested in speaking with you about your availability
to testify as an expert witness at trial. Are you available for a call tomorrow or next week to discuss?
Thanks very much,
EFTA00024759


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=== Page 1 ===
From:
To:
Subject:
Date: Thu, 11 Jun 2020 17:44:27 +0000
Hi
,
I'm an AUSA in EDNY and am working on an investigation into the death of an inmate at the Brooklyn MDC.
The OCME told me that it signed a confidentiality agreement in connection with the investigation into the
murder of Jeffrey Epstein. We were hoping to extend a similar agreement and I wanted to see if you could share
the agreement (or a boilerplate version of it).
I'm happy to speak over the phone if that's easier. My cell is
Thanks so much,
Sent from my iPhone
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=== Page 1 ===
From: "Tomback, Andrew"
To:
"Weinstein, Marc
A."
Cc:
>, "Tomback, Andrew"
Subject: RE: subpoena follow-up question
Date: Tue, 19 May 2020 12:27:44 +0000
Inline-Images: image001.png
Marc and/or I will respond to your email below soon- ideally later today.
Regarding my open issue, the Estate won't list any property before June 15.
Stay safe.
Andy
Andrew E. Tomback I Partner
T
E
White & Case LLP I 1221 Avenue of the Americas I New York, NY 10020-1095
WHITE&CASE
From:
Sent: Monday, May 18, 2020 4:17 PM
To: Tomback, Andrew
>; Weinstein, Marc A.
Cc:
Subject: RE:
follow-up question
Mark,
One question I had meant to ask in our call but forgot, on a separate subject - we had briefly discussed in late February
our request for photographs and videos in the possession of the estate, and my recollection is that with respect to videos,
the estate and trustees were not aware of being in possession of any historical surveillance-type videos (and in particular
that any such surveillance video is regularly over-written, and so would not currently exist for any time before, for
example, Epstein's suicide), and that separately the estate and trustees were not aware of being in possession of other
physical video recordings.
My recollection is that with respect to photographs, that there were some photographs in the properties that had not
been the subject of physical search warrants, i.e., the Florida and New Mexico residences. I think we had discussed that
the most efficient step, in the first instance, would be for us to receive digital photos of those physical photographs, to
whatever extent they exist, but that doing so was not immediately possible at the time of our conversation in late
February due to the estate's then-inability to retain or engage anyone to do that.
In the first instance, please let me know if I am getting any of that wrong, and second, understanding that the
circumstances of the pandemic may have affected this in the interim, we've been asked to again check with you about
whether there is anyone currently working at (or reasonably able to go to) those properties who could convey
photographs of any physical photos at those locations? If you could please let us know any sense of possibility / timing on
that last outstanding request.
thanks,
EFTA00026534

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
This email communication is confidential and is intended only for the individual(s) or entity named above and
others who have been specifically authorized to receive it. If you are not the intended recipient, please do not
read, copy, use or disclose the contents of this communication to others. Please notify the sender that you have
received this email in error by replying to the email or by telephoning
Please then delete the
email and any copies of it. Thank you.
Our external privacy policy is available on https://www.whitecase.com/privacy-policy.
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=== Page 1 ===
GG
800 Third Avenue
COHEN & GRESSER LLP
New York NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Christian R. Everdell
ceverdell@cohengresser.com
October 25, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
We respectfully submit this letter to request a one-week extension until November 3, 2021,
to file the joint proposed jury charge and verdict sheet, which are currently due on October 27,
2021. See 8/27/2021 Order (Dkt. 330). The government consents to this request.
On October 20, 2021, the government provided the defense with its proposed jury charge.
Because of the press of other deadlines in this case-including the motions in limine responses
and replies, and the Rule 412 briefing-the defense requests an additional week to provide its
counterproposals to the government and to submit the final proposed jury charge to the Court.
The government and the defense have met and conferred and agreed that the defense will
send the government a redlined version of the government's proposed jury charge containing the
defense's counterproposals by November 1, 2021. The parties will submit the final joint proposed
request to charge and verdict sheet, with the areas of continued disagreement shown in redline, on
November 3, 2021. We respectfully request that the Court approve this revised schedule.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
cc:
All Counsel of Record (By ECF)
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=== Page 1 ===
Response to Follow Up Questions from 2/13/20 Attorney Proffer
Dear Counsel:
Below please find our reply, in no particular order, to your follow-up questions
from the 2/13/20 attorney proffer. As we discussed, the same terms covering
the attorney proffer govern these communications as well.
Who told
to keep to herself, not ask questions and not to fraternize
with those she encountered through her work with JE?
When
was first hired, Ms. Maxwell told her not to fraternize with any of JE's
business associates, friends, etc. It was Epstein who reprimanded
for
breaking this rule when she appeared at the party, the details of which were
set forth on 2/13. So, it was both Maxwell and Epstein who directed
not to
fraternize and to stick to business
Qualifications for the job. Did she replace anyone? Who trained her?
Were massages already on the agenda when
took over?
Prior to working for JE,
had managed an office supply company for 9 years
and then worked in the men's department at Nordstrom's selling clothes. This
was a commission-based job and she did quite well.
placed her resume on
Monster.com looking for a job in event planning. The headhunter Epstein had
hired contacted
, not to work for Epstein, but for a job with the NY Knicks as
an event planner. Unfortunately, as a result of a large snowstorm LG could not
get into the City from NJ and missed the Knicks opportunity (the position had
been filled by the time she finally met with Russell, the headhunter.) Once
Russell interviewed
, he asked if she had time to go meet with someone who
she could "event plan" for.
interviewed with Maxwell and then with
Epstein and hired.
had not heard of JE prior to that time.
was trained
by JE's then assistant,
and others told
that massages were
a part of JE's agenda --just part of his normal day. Akin to someone going daily
to the gym.
remained in the company as a receptionist after
was hired
and later became Ms. Maxwell's assistant after
left.
was given no explicit instructions regarding massage appointments by
Massage appointments were to be handled like any other appointments.
does not recall anything specific being discussed about the women. Massage
appointments were a part of a normal day and were usually a daily occurrence.
Note: Correction to my proffer.
generally made 1-2 appointments for
massages a day. I misstated that JE had 4 or more daily.
does not know if
massages were being scheduled after hours after she left for home. Massages
EFTA00025091

=== Page 2 ===
were at times cancelled and rescheduled if JE got busy.
also
scheduled massages.
After JE pleaded guilty in FL, did
schedule massages?
was not asked to make massage appointments after his plea, and, to her
memory, the word 'massage' was not used again.
Does
remember the names of people who she scheduled massages
with? Is there a list of names? When JE called to schedule a massage, if
a person was a repeat masseuse, did JE just say call X? If the person was
not available, did
ask the person if she had the name of a third party
to do a massage? Who else made massage appointments?
Names of the masseuses were usually by first name. JE provided
a name
and a phone number. Once the name of any new contact was given,
was
directed to always add the name and phone number to her company directory
maintained on the computer. At times, masseuse(s) would have the same
name, so for example, JE referred to X as Little X or Big X.
does not recall
any names since there many names and the masseuses would come and go. If
a person particular person requested by JE was not available
would inform
JE. JE might ask
to call a different individual. At times, JE directed
to
ask X (if she was unavailable) if she had a friend who was available. When
was away from the job for vacation, pregnancy, maternity leave, etc.,
,
(before she left in
approximately 2002/3) made all appointments, business, and otherwise. After
the birth of
son in Dec. 2004, she was on maternity leave for 3 months.
Upon her return, she worked only 3 days a week for several years.
Did
ever work out of the mansion? Did
have a workspace or office
there? Does
know who worked out of the house?
worked out of the Villard House at the Helmsley exclusively from day one
until they moved the office to the 66th Street apartments around 2009.
worked out of the Palm Beach office twice in 2009 for approximately one day
each visit. The offices moved to 575 Lexington Ave around 2010.
worked
from the mansion from approximately 2012 (not sure) onward, but only when
Epstein was in NY. Her office was on the first floor at the very front of the
mansion. When Mr. Epstein was not in NY, she worked from home, which
occurred over 50% of the time.
Mr. Epstein had staff at the mansion. Maid, Houseman, Engineer, Chef, other
maids.
EFTA00025092

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During the time of JE's previous case, did anyone ask
to get rid of
anything or is she aware of any other type of obstruction (even if it was
not apparent at the time)?
was never asked to get rid of anything. They did upgrade the antiquated PC
computer system over to Mac around 2009 and converted from BlackBerry
phones to Apple iPhones.
Once they moved into the office at 575 Lexington Ave, at some point (she does
not recall exactly when) old storage boxes with folders arrived from storage and
were shredded by an "office helper"
,
who did odds and ends type of jobs
for Epstein. At one time she was cleaning the apartments and the offices
located at the apartment building at 301 East 66th.
does not know what
was in the folders and was told it was time to get rid of very old files not worth
paying to store.
What was
impression of
Maxwell? Did she discuss if
she had had a relationship with Mr. Epstein? Ever say she was abused?
Did she seem intimidated by him? Scared?
was hired as Epstein's traveling assistant sometime around 2002/3.
thought
was nice, responsible, organized and professional.
never
discussed having a relationship with Epstein or being abused by him.
sure
there were times
felt intimidated or scared if she made an error, but it
was not discussed. Mr. Epstein was very demanding and could be very intense
to everyone he worked with.
thought both
and Maxwell were professional and treated her with
respect. They both were busy people, and
recalls that Maxwell was building
her brownstone when
was first hired.
didn't interact with her very
much, and she believes that Maxwell was intimidated and scared of Epstein at
times.
had no social relationship with either of them.
Did
schedule massages for JE at locations other than NY?
Sometimes in FL.
Did
keep a directory/database of people I called for JE?
Yes. They had a directory but it was a directory of everyone JE knew.
did
not have a separate directory or database for just masseuses. As far as she
can recall, everyone in the office had access to the directory and could add to it
as well.
When JE told
to schedule a massage, what was the time frame for the
appointment? (i.e. that day? Next week?)
EFTA00025093

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Mostly that day. Sometimes the next day.
At any time during the FL investigation, did
receive a subpoena? Was
there any discussion with JE about it?
did receive a subpoena. She only knows it was handled and was not
involved with the FL case/investigation. JE had one conversation with
about the case as relayed in the proffer. JE asked her if she knew about the
case, and she replied she didn't need to know. JE said that someone was trying
to blackmail him and apologized for the disruption it was causing to the office.
JE also said that it was embarrassing.
Were there any discussions with JE about future payments to
(i.e. in
his will, if she left, retirement or otherwise)?
No.
Were there any conversations with JE or Maxwell re civil suits? Did they
ever ask
to be dishonest in replying? How was she advised by JE or
others? Aware of any obstructive conduct?
did not have any conversations with JE or Maxwell re civil suits. They
never asked her to be dishonest, and never advised by him or others about the
suit, and she is not aware of any obstructive conduct.
What were the logistics of international and other flight travel
arrangements? What travel agencies etc. were used?
Travel was booked through a travel agency and on-line bookings for both
international and domestic flights. (Shoppers Travel when she was first hired
then Amex Centurion. Other agencies may have been used also but she cannot
recall the names. Online services could be Orbitz, Travelocity, Google, etc.
Epstein wanted the best pricing but also wanted exact times for flights to
depart/land.)
Many times, people flew with Mr. Epstein on his private plane. Prior to JE's
plea, most travel was done by other administrator in the office or by
may have booked a trip from time to time but usually was too busy to do
so. After JE returned to the office around 2011,
still booked
travel. Once
was married and left, Epstein had
and
sometimes
booking travel. Approximately in 2016 (?) Epstein asked
to
take over travel because he felt
was incompetent when it came to
finding the best pricing for good flights. Epstein told
he wanted to hire a
new person to take over handling all the travel, but he never found anyone.
EFTA00025094

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When did
leave JE's employ?
resigned end of July 2019. She felt betrayed and disgusted once the
indictment came out.
Before the arrest, was she already planning to leave?
considered leaving after the arrest in 2010. She perused websites and
interviewed with a high-end staffing agency. After considering what was
available, she realized her job offered a lifestyle flexibility that she could not
replicate anywhere else. Epstein was still communicating with the same
businesspeople, scientists, politicians etc., and she simply gave him the benefit
of the doubt that he had done his time, etc. JE continued to claim it was all
blackmail. Working from home, being a good mother and wife were and are
the most important aspects in of her life. This job allowed her both a
challenging, interesting job and still be an attentive mom and wife.
What was
reaction to the charges?
As discussed in the proffer, she felt used, and realized that despite what JE
said to her about the previous case, she realized that the allegations were likely
real and she felt betrayed. She had mixed emotions given the time she spent
there.
felt that Epstein kept her in front of a curtain, a façade. She was a
real executive assistant with real executive functions, but he used her to
conceal his personal problems and predilections.
Was
ever the subject of JE's abuse in any way?
No.
Did
ever observe JE acting inappropriately with women? Employees
or others?
No.
Impression of JE's business? How did he make money?
Epstein was a money manager. He managed Les Wexner's money and possibly
other client's money.
thought he made money just on his own money by
interest and trading.
Was
represented in any way in the FL case where named in the non-
prosecution provision?
She met with Nate Dershowitz once, but does not recall any specific questions
from him. She did not know she was in the non-prosecution agreement.
EFTA00025095

=== Page 6 ===
How much time did
spend at the Palm Beach residence?
None.
Did LG ever visit other properties, New Mexico ranch, Little St. James
Island, Great St. James island or the Paris residence?
never went to the ranch in New Mexico. As stated in the proffer, in or about
2002, when
and her husband went to London for vacation, Epstein
suggested they go to Paris while abroad and stay in a guest room of his Paris
apartment around.
and her husband also visited Little St. James island
and had lunch there on a trip to Tortola for a wedding around 2002/3). Post
2014,
went to Little St. James island on two other occasions- to view
construction work. Epstein was hoping
could help by following up with
contractors and staff, organization and keeping things on schedule.
flew in,
spent a few hours with
, the island manager, then went back to St.
Thomas to a hotel to have dinner and slept there.
was up early the next
day to fly home.
( wanted to fly in/out same day but it is not possible with
any of the airlines flight schedules). On her second trip, she visited Great St.
James as well to view construction. She never went to the Palm Beach
residence - only to the Palm Beach office on two or so occasions to work - for
quick one-night trip.
Clearing up a few points:
2001-2009 (or 2008 when they), cash was always kept in the office in the
accounting department while they worked out of the Villard house. Money
would be messengered from the office in envelopes prior to Epstein's plea.
do not recall much, if any, messengering of money after he went to jail.
Parenthetically, Epstein liked to use messengers and Fed Ex for everything,
buying a book online, for example, he wanted to spend the money to expedite
the delivery. He didn't want to wait for anything and had the money to pay for
the fastest service available.) Money would be messengered per Epstein's
directive to do so.
relayed to the accounting department that 'Y' amount
should be messengered to X. Sometimes she would set up the messenger and
sometimes the receptionist would set up the messenger. Either an address
would be given to
by Epstein. Alternatively,
or the receptionist, would
need to call X and ask where to messenger the envelope.
does not recall
any masseuse or other persons ever coming to the office to pick up an envelope
of money. There was never any discussion of prostitution or anything sexual
that she heard. No one she saw appeared to be underage.
After 2011,
had an office at Mr. Epstein's mansion because he no longer
had a recognizable 'office address' to work from. The office at 575 Lexington
was like a We Work environment - lots of small businesses working out of small
EFTA00025096

=== Page 7 ===
offices. Epstein did not want to hold his meetings from the We Work
atmosphere and wanted all his appointments to come see him at his mansion.
office was located at the front of the mansion. Generally, when someone
entered the residence, he/she passed her office. When a visitor came to meet
with Epstein, he would either go straight back to see him from the front door to
the dining room where he held his meetings or he would wait in
office
until JE was ready/available to meet with them. Due to where
desk was
situated, if someone went straight back to the dining room,
would not see
them.
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From:
To:
Subject: RE: epstein
Date: Tue, 27 Aug 2019 22:31:55 +0000
Received, thank you.
From:
Sent: Tuesday, August 27, 2019 5:13 PM
To:
Subject: epstein
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=== Page 1 ===
10/9/21, 11:12 PM
SOFTWARE.dat.[AD].html
Registry SOFTWARE
Information
Install Date
11/7/2003 16:31:36 +0000
Product Name
Microsoft Windows XP
Registered Organization
Registered Owner
J Epstein
CSDVersion
Service Pack 2
Digital Product ID
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00 00 0B B0 01 7B
fie://usa.doj.gov/cloud/NYS/StAndrews/Shared/USvEpstein-2018R01618/Discovery/GM/29 Twentieh Production (2021-09-13)/SDNY_GM_02753699... 1/1
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=== Page 1 ===
From:
To:
Subject: Epstein update
Date: Sat, 10 Aug 2019 11:26:39 +0000
Can you please give me a call?
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=== Page 1 ===
Case 1:20-cv-00484-JGK-DCF Document 80 Filed 09/09/20 Page 1 of 4
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
The Clerk of Court is directed
to file this letter on the Docket
September 4, 2020
of Case No. 20cv00484.
BY EMAIL¹
Dated: 09/09/2020
The Honorable Debra Freeman
SO ORDERED
United States District Court
Southern District of New York
who mm
United States Courthouse
DEBRA FREEMAN
500 Pearl Street
United States Magistrate Judge
New York, New York 10007
Re:
Jane Doe V. Darren K. Indyke, et al., 20 Civ. 484 (DCF) (JGK)
Dear Judge Freeman:
The Government respectfully submits this letter to request that the Court: (1) permit the
Government to intervene in the above-referenced matter for the limited purpose of seeking a stay
of the action, and (2) stay this matter in its entirety pending the resolution of the criminal
prosecution against Ghislaine Maxwell in the matter of United States V. Ghislaine Maxwell, 20 Cr.
330 (AJN). As discussed below, the Government submits that a complete stay of this civil action
will serve the public interest of preserving the integrity of the criminal prosecution against
Maxwell and will conserve private, public, and judicial resources; and that those interests will
outweigh any delay or disruption caused to the resolution of this civil action.
On June 29, 2020, a federal grand jury in this District returned a sealed indictment (the
"Indictment") charging Ghislaine Maxwell with one count of conspiracy to entice minors to travel
to engage in illegal sex acts, in violation of 18 U.S.C. $ 371; one count of enticing a minor to travel
to engage in illegal sex acts, in violation of 18 U.S.C. $ 2422 and 2; one count of conspiracy to
transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371; one count of
transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. $ 2423 and 2; and
two counts of perjury, in violation of 18 U.S.C. $ 1623. The charges arise from a scheme to
sexually abuse underage girls at Jeffrey Epstein's properties in New York, Florida, and New
Mexico, between approximately 1994 and 1997. As the Indictment details, Maxwell played a key
role in Epstein's abuse of minors by helping Epstein to identify, groom, and ultimately abuse
underage girls.
I While the Government understands that letters from parties are required to be filed via ECF, the
Government is not a party in this matter, and the ECF system does not permit non-parties to file
letters.
EFTA00024724

=== Page 2 ===
Case 1:20-cv-00484-JGK-DCF Document 80 Filed 09/09/20 Page 2 of 4
Page 2
Over the past year, a number of plaintiffs have filed civil complaints in this District
asserting claims arising from Jeffrey Epstein's sexual abuse of minor girls. Of those lawsuits, the
above-captioned matter is the lone case in this District that has not yet been either resolved or
stayed at this point, as far as the Government is aware. In particular, this matter appears to be the
only remaining active civil case in this District in which claims against Ghislaine Maxwell have
been asserted.
This Court has the inherent power to stay civil cases in the interests of justice pending the
completion of criminal prosecution. See Landis V. North Am. Co., 299 U.S. 248, 255 (1936); Kashi
V. Gratsos, 790 F.2d 1050, 1057 (2d Cir. 1986). Courts routinely grant applications to stay civil
proceedings in order to protect a pending criminal case. See, e.g., Johnson V. New York City Police
Dep't, 01 Civ. 6570 (RCC) (JCF), 2003 WL 21664882, at *2 (S.D.N.Y. July 16, 2003); Okoli V.
Cty. of Nassau, 15 Civ. 0701 (JS) (SIL), 2015 WL 8207496, at *2-3 (E.D.N.Y. Dec. 7, 2015).
The complaint in this civil action alleges that Maxwell facilitated the sexual abuse of a
minor by Jeffrey Epstein in the 1990s. Those allegations will, by definition, touch on matters
relating to the pending Indictment. Indeed, based on a review of the civil complaint, the
Government understands that it is likely that should discovery in civil action go forward, multiple
witnesses or potential witnesses at the criminal trial would be subject to deposition. Accordingly,
there is a significant risk that proceeding with this civil matter would adversely affect the ongoing
criminal prosecution against Maxwell. Those concerns include, among others: (i) subjecting
potential trial witnesses in the criminal matter to depositions by civil litigants in advance of their
testimony on similar matters in the criminal trial; (ii) subjecting the defendant to a deposition on
matters for which she presently stands criminally charged in advance of her criminal trial; and (iii)
the potential waste of significant judicial, government, and defense resources that would result
from having both the civil and criminal proceeding move forward simultaneously given the
potential of the resolution of the criminal case to impact any resolution of the civil action.
Courts generally apply a five-factor test in determining whether to stay a civil action
pending the resolution of a related criminal matter, considering: (i) the private interests of the
plaintiffs in proceeding expeditiously with the civil litigation balanced against the prejudice to the
plaintiffs if delayed; (ii) the private interests of and burden on the defendants; (iii) the interests of
the courts; (iv) the interests of persons not parties to the civil litigation; and (v) the public interest.
SEC V. Beacon Hill Asset Mgmt. LLC, No. 02 Civ. 8855, 2003 WL 554618, at *1 (S.D.N.Y. Feb.
27, 2003); see also SEC V. Doody IV, 186 F. Supp. 2d 379, 381 (S.D.N.Y. 2002). Here, the factors
weigh in favor of granting a stay.
Here, while the Government appreciates the plaintiff's interest in resolving the civil suit,²
any potential prejudice to the plaintiff is outweighed by both the public interest in the enforcement
of criminal laws and the fact that resolution of the criminal process may result in a more efficient
resolution of the civil suit. See generally In re Ivan F. Boesky Sec. Litig., 128 F.R.D. 47, 49
(S.D.N.Y. 1989) ("the public interest in the criminal case is entitled to precedence over the civil
2 As Maxwell also seeks a stay of this matter, it does not appear that granting the stay would cause
any prejudice to Maxwell.
EFTA00024725

=== Page 3 ===
Case 1:20-cv-00484-JGK-DCF Document 80 Filed 09/09/20 Page 3 of 4
Page 3
litigant"); United States V. Hugo Key & Son, Inc., 672 F. Supp. 656, 685 (D.R.I. 1987) ("While a
civil litigant with a private dispute has an interest in the prompt disposition of his or her claims,
the public has a greater interest in the enforcement of the criminal law."). In particular, any
concern regarding the potential delay of this civil suit is outweighed by the concern that Maxwell
would seek to assert her Fifth Amendment rights rather than submit to a deposition in the civil
action, and that depositions of other witnesses could potentially interfere with the criminal
prosecution. See United States V. Saad, 229 F.R.D. 90, 91 (S.D.N.Y. 2005) (noting that
invocations of the Fifth Amendment privilege can disrupt the orderly conduct of a civil case).
Moreover, given the factual overlap between the civil and criminal cases, allowing the criminal
matter to be resolved in the first instance may result in a narrowing of the factual and legal issues
before this Court. See Volmar Dist., Inc. V. New York Post Co., 152 F.R.D. 36, 40 (S.D.N.Y.
1993). Accordingly, the interests of judicial economy are better served by the stay the Government
seeks.
Additionally, consideration of the interests of third parties, including the public, weighs in
favor of granting the stay. In particular, the Government is not aware of any third parties that
would be harmed by a stay, and, to the contrary, the public interest in the enforcement of the
criminal law will be served by a stay. Multiple third-party witnesses possess information that is
potentially relevant to both this lawsuit and the criminal prosecution.³ Premature disclosure of the
testimony of these witnesses could severely impair the criminal prosecution. First, such witnesses
may be forced to testify about any efforts to assist the criminal investigation and prosecution, and
may thereby expose facts about the investigation that would otherwise not be disclosed far in
advance of a criminal trial and could potentially expose witnesses and/or their families to
harassment. Moreover, permitting any discovery to proceed in this lawsuit would enable Maxwell
to seek a preview of trial testimony in the criminal case, and would afford her with a broader array
of discovery than she is entitled to in the criminal case. See Johnson, 2003 WL 21664882, at *2
("[T]he civil action, if not stayed, might undermine the criminal defendant's Fifth Amendment
privilege against self-incrimination, expand the rights of discovery beyond the limits of the state's
criminal procedure law, expose the basis of the defense to the prosecution, or otherwise prejudice
the criminal case."). Finally, the Government notes that Maxwell's access to information about
the criminal matter is under the jurisdiction of the Honorable Alison J. Nathan, who has entered a
protective order and has issued several rulings regarding the scope of discovery that Maxwell is
3 In an August 25, 2020 opinion, Judge Nathan held that Maxwell is not entitled to know who the
Government's trial witnesses are at this stage of the criminal case. United States V. Ghislaine
Maxwell, 20 Cr. 330 (AJN), Dkt. 49. Consistent with that ruling, the Government is not including
detailed information in this letter about who those trial witnesses might be and will not engage
with Maxwell's speculation as to who those witnesses may be. The Government respectfully
submits that the Court need not make any findings on that score to resolve this motion, as a
complaint concerning sexual abuse of minors by Epstein and Maxwell will inevitably implicate
documents, witnesses, and other evidence that overlaps with the criminal matter, whether or not
the plaintiff in this action-or the conduct she alleges-has any direct connection to the charges in
the Indictment. If it would be useful to the Court, however, the Government is prepared to provide
an ex parte submission under seal detailing the anticipated overlap of witnesses between the
criminal case and this case.
EFTA00024726

=== Page 4 ===
Case 1:20-cv-00484-JGK-DCF Document 80 Filed 09/09/20 Page 4 of 4
Page 4
entitled to and the manner in which she may or may not use that information. Given that Maxwell
is represented by the same counsel in both the criminal and civil matter, a stay is necessary to avoid
blurring the carefully drawn boundaries between the criminal case and pending civil litigation.
The Government recognizes that the plaintiff in this action has an interest in pursuing her
claim against Maxwell. To that end, the Government has considered whether a partial stay-or
some other remedy short of a complete stay of this action-would address the Government's
concerns. However, after carefully considering the issues in this case and the pending criminal
case, the Government respectfully submits that nothing short of a full stay of this matter would
address the Government's concerns and preserve the public's substantial interest in avoiding
interference with prosecution of the criminal case
Finally, the Government notes that any stay would be no longer than necessary to
accommodate the interests of the criminal process. At this time, the Government only seeks a stay
until the conclusion of the criminal trial, which is scheduled to begin on July 12, 2021.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By:
/s
Assistant United States Attorneys
Southern District of New York
Tel:
Cc:
All counsel of record (by email)
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=== Page 1 ===
From:
"
(USANYS)"
To: "Kramer, Amanda K"
Cc:
)"
Subject: RE: Call
Date: Tue, 23 Feb 2021 02:10:53 +0000
Hi Amanda,
Do you have a few minutes to chat tomorrow?
and I are free between I am and 4pm and after 5pm.
Thanks so much,
Original Message
From: Kramer, Amanda K
Sent: Tuesday, February 09, 2021 4:22 PM
To:
(USANYS)
Cc:
)
Subject: RE: Call
Hi
and
Apologies for the delay - I had full days set aside for witness interviews and was waiting for clarity from the client. It looks like I'm
available Thursday 2:30-5 and Friday 2-4. Please let me know if those times work for you.
Best,
Amanda
Original Message
From:
(USANYS)
Sent: Monday, February 8, 2021 7:08 PM
To: Kramer, Amanda K
Cc:
)
Subject: RE: Call
[EXTERNAL]
Hi Amanda,
So sorry to bother you, but we wanted to follow up on scheduling in light of our pre-trial motion opposition deadline. Can you please
let us know some times that work for you to speak?
Thanks so much,
Original Message
From:
(USANYS)
Sent: Saturday, February 06, 2021 1:08 PM
To: 'Kramer, Amanda K'
Cc:
)
Subject: RE: Call
Amanda,
I hope all is well. Sorry to bother you on the weekend, but we wanted to send along the emails as discussed and reach out regarding
scheduling. Can you please let us know some days and times that would be convenient for you to speak by phone early next week if
EFTA00026599

=== Page 2 ===
possible? We are happy to speak whenever best for you.
Thanks again,
Original Message
From: Kramer, Amanda K
Sent: Friday, January 29, 2021 9:19 PM
To:
(USANYS)
Cc:
)
)
Subject: Re: Call
Hi all,
I'm flexible on Tuesday before 2:00. Does that work?
Best,
Amanda
On Jan 29, 2021, at 9:04 PM,
(USANYS)
wrote:
[EXTERNAL]
Hi Amanda,
I hope all is well with you. We are hoping to find a time for an initial call with you early next week. In advance of speaking, we
wanted to send you your notes from a meeting in February 2016 and a link to the following article: http://www.nydailynews.com/new-
york/ny-jeffrey-epstein-maxwell-case-20201013-jmzhl7zdrzdgrbbs7yc6bfnszu-story.html.
Can you please let us know some times that work for you?
Thanks so much, and have a good weekend,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
<2016.2.29 Meeting Notes and Business Cards.pdf>
EFTA00026600


c1: EFTA00024919
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=== Page 1 ===
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
November 18, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are
stamped with control numbers SDNY_GM_02772262 through SDNY_GM_02774104.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. The Department of Justice directed this office to cease the dissemination of materials
marked with the word "confidential" in order to avoid potential confusion with markings reserved
for classified documents. Accordingly, in order to note the appropriate designation of this
production under the operative Protective Order in this case, the materials being produced today
are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,
8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective
Order that govern today's production.
An index of the materials contained in this production is below:
EFTA00024919

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02772262
SDNY GM 02774104
Records relating to
Confidential
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
s/
Assistant United States Attorneys
EFTA00024920


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Bec:
:
Subject: RE: Epstein FOIA Atty Visit Logs and Count Slips
Date: Sat, 09 Jan 2021 17:27:44 +0000
Embedded: RE:_Epstein_FOIA_Atty_Visit_Logs_and_Count_Slips.msg
Sender:
Subject: RE: Epstein FOIA Atty Visit Logs and Count Slips
Message-Id:
<BN3P110MB043420B0DCB0B3B0E106F90A9FAD0@BN3P110MB0434.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
Cc:
Cc:
EFTA00026963


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=== Page 1 ===
90A-NY-3151227 Serial 34
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027707
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027707: One (1) Western Digital
1TB hard drive, WD10EADS-00L5B1, S/N WCAU45803950, containing the Clone
Copy of 1B8 hard drive (Western Digital 500GB HDD, WD5000AVDS-63U7B1, S/N
WCAV9Z911026), collected via Tableau TD3-B, S/N 01D3407C-1222. Request ID
112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027707: One (1) Western Digital 1TB hard drive,
WD10EADS-00L5B1, S/N WCAU45803950, containing the Clone
Copy of 1B8 hard drive (Western Digital 500GB HDD,
WD5000AVDS-63U7B1, S/N WCAV9Z911026), collected via
Tableau TD3-B, S/N 01D3407C-1222. Request ID 112048.
Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Located By:
Device Type: Hard Drive
Designation: Derivative
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00025404

=== Page 2 ===
90A-NY-3151227 Serial 34
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027707
Re: 90A-NY-3151227, 08/16/2019
Number of Devices Collected: 1
UNCLASSIFIED
2
EFTA00025405


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=== Page 1 ===
Event: Accepted: Epstein estate counsel call
Start Date: 2019-10-30 18:30:00 +0000
End Date: 2019-10-30 19:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-10-23 19:50:43 +0000
Date Modified: 2019-10-23 19:50:43 +0000
Priority: 5
DTSTAMP: 2019-10-23 19:39:13 +0000
Attendee:
EFTA00024295


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Fri, 01 Mar 2019 16:25:29 +0000
Importance: Normal
Thanks,
1:30 should work for us. We can give you a call then.
From:
Sent: Friday, March 1, 2019 10:16 AM
To:
Cc:
Subject: RE: Epstein
Good morning!
Thank you for reaching out. I have some availability for a phone call today around 1:30/2 p.m. Please let
me know if that works for you. I look forward to connecting.
From:
Sent: Thursday, February 28, 2019 5:56 PM
To:
Cc:
Subject: Epstein
Hi
-
and I are the supervisors of the Public Corruption Unit in the Southern District of New York, and we
understand you reached out to one of the line AUSAs in our unit,
regarding our Epstein investigation. We
wanted to introduce ourselves and connect. Do you have time for a call tomorrow or Monday?
Thanks,
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00027046


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=== Page 1 ===
From:
Subject: RE: Epstein Call Tomorrow
Date: Thu, 21 May 2020 18:22:12 +0000
We can use my dial in:
From:
(USANYS)
Sent: Thursday, May 21, 2020 10:04 AM
To:
is
is
Cc:
(USANYS)
Subject: RE: Epstein Call Tomorrow
Thanks - let's say 230
From:
Sent: Thursday, May 21, 2020 9:59 AM
To:
Subject: RE: Epstein Call Tomorrow
Same, thanks
From:
Sent: Thursday, May 21, 2020 9:33 AM
To:
Cc:
Subject: Re: Epstein Call Tomorrow
Same, thanks.
Sent from my iPhone
On May 21, 2020, at 9:30 AM,
wrote:
I can do any time in that range.
On May 21, 2020, at 09:30,
wrote:
Do some or all of you have a few minutes to chat between 230 and 4 today in advance of this call tomorrow? Just
want to update you on what I expect.
EFTA00026606

=== Page 2 ===
From:
(USANYS)
Sent: Thursday, May 21, 2020 9:28 AM
To:
>;
(USANYS) [Contractor]
Cc:
(USANYS)
is
>;
Subject: RE: Epstein Call Tomorrow
Me too.
From:
Sent: Thursday, May 21, 2020 9:27 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
is
>;
(USANYS)
is
Subject: Re: Epstein Call Tomorrow
Either works for me, thanks.
On May 21, 2020, at 09:17,
(USANYS)
wrote:
1 would be better for me but I can make 11 work if it's better for others.
Sent from my iPhone
On May 21, 2020, at 9:11 AM,
wrote:
Both work for me, thanks.
From:
(USANYS) [Contractor]
Sent: Thursday, May 21, 2020 9:10 AM
To:
(USANYS)
is
(USANYS)
>;
>;
>;
Subject: Epstein Call Tomorrow
All,
I've been asked to set up a call with all of you and the brass for tomorrow. 11am or 1pm would work best for them.
Do either work for all of you?
Thanks,
EFTA00026607


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=== Page 1 ===
From: Jennifer Richardson
To:
)"
, Gary Bloxsome
Cc:
)"
)"
, Daniel Cundy
Subject: RE: U.S. Department of Justice investigation
Date: Fri, 10 Jan 2020 12:11:19 +0000
Inline-Images: image001.jpg; image002.jpg; image700723.jpg; image398875.jpg
Dear
Thank you for your email. We will call you on that number at 14:00 GMT.
Many thanks
Jen
Jennifer Richardson I Solicitor-Advocate
RANKED IN
Chambers
UK
500
2020
TOP TIER
Blackfords
Leading Firm
2020
LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
From:
Sent: 09 January 2020 21:53
To: Gary Bloxsome
Cc:
;
; Daniel Cundy ; Jennifer Richardson
Subject: RE: U.S. Department of Justice investigation
External email: is it safe to open attachments and links?
Gary,
You can reach us at my office line, at
or if you prefer we can give you a call at any number that would be
convenient, if you prefer to have a conference line. We look forward to speaking with you tomorrow.
thank you,
From: Gary Bloxsome
Sent: Wednesday, January 08, 2020 07:38
To:
Cc:
is
>; Daniel Cundy
>; ; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Friday 10th January at 1400(LDN) time is fine.
EFTA00023813

=== Page 2 ===
Please forward dial in details.
Kind regards
Gary
Gary Bloxsome I Partner
RANKED IN
Chambers
LEGAL
UK
500
MAGDON
2020
TOP TIER
Blackfords
Leading Firm
2020
LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
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 7 Jan 2020, at 18:56,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
We are available for a preliminary call this Friday, January 10. If it would be convenient for you, we are available at 9:00
local time for us (which I believe would be 14:00 your time). If that works, we can plan to call you at your office line
unless you'd prefer we use another number or a conference line.
thank you,
From: Gary Bloxsome
Sent: Tuesday, January 07, 2020 11:20
To:
Cc:
is
>; Daniel Cundy
>; ; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.
Kind regards.
Gary
Gary Bloxsome
Partner
Blackfords LLP
I
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this
address.
EFTA00023814

=== Page 3 ===
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 4 Jan 2020, at 01:38,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
Thank you for your response and for confirming your representation. To respond to your question generally, in
connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to
request a consensual, voluntary law enforcement interview with your client. Generally, we would expect to inquire
about his relationship and communications with Jeffrey Epstein and his associates, as well as certain allegations that
have arisen publicly and in our investigation to date.
Although we recognize we separately have the ability to convey such a request through diplomatic and law
enforcement channels, we understand we may also alternatively inquire directly with counsel, when an individual has
legal representation. Given your representation, we are inquiring directly with counsel in the first instance.
Certainly we can discuss our request in more detail, but we hope this will provide the information you were seeking as
a threshold matter, and we look forward to being in touch.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Friday, January 03, 2020 10:30
To:
Cc:
>; Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
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 I Partner
Blackfords LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
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
EFTA00023815

=== Page 4 ===
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,
Assistant U.S. Attorney
Southern District of New York
EFTA00023816


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: Fwd: Epstein Estate update
Date: Mon, 09 Nov 2020 14:55:23 +0000
Given that today is the deadline, I would be fine pushing this call to tomorrow to make more time today. Or if
you'd prefer I can just deal with this call alone this afternoon.
Sent from my iPhone
Begin forwarded message:
From: "Weinstein, Marc A."
Date: November 9, 2020 at 9:49:47 AM EST
To:
)"
)"
Cc: Andrew Tomback
Subject: Epstein Estate update
and
Would you have time for a call this afternoon to give you an update on a new development?
Thanks,
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.
EFTA00024818


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=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Fri, 08 Nov 2019 21:06:30 +0000
Yes, just wrapping something up - can I come by in about 5 minutes?
From:
Sent: Friday, November 8, 2019 4:04 PM
To:
Subject: Epstein
Do you have a few minutes to chat?
Deputy United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00026449


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Emailing: SNY.WP.07-08-20.Colloquy.Maxwellpdf
Date: Thu, 23 Jul 2020 14:42:28 +0000
Attachments: SNY.WP.07-08-20.Colloquy.Maxwell.pdf
Your message is ready to be sent with the following file or link attachments:
SNY.WP.07-08-20.Colloquy.Maxwellpdf
Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of
file attachments. Check your e-mail security settings to determine how attachments are handled.
EFTA00024659


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=== Page 1 ===
Event: Accepted: Epstein call
Start Date: 2020-04-29 18:00:00 +0000
End Date: 2020-04-29 18:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-04-29 16:18:44 +0000
Date Modified: 2020-04-29 16:18:44 +0000
Priority: 5
DTSTAMP: 2020-04-29 15:28:10 +0000
Attendee:
EFTA00025478


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=== Page 1 ===
United States v. Ghislaine Maxwell
20 Cr. 330 (AJN)
Government Exhibit Index
10/28/2021
0 Series
Message Pads
GX
Description
Bates Range/Identifier
Produced to Defense
GX-1
Physical Message Pad#
2021.10.11
GX-1-A
Message Pad Cover#
SDNY_GM_00165559
2021.10.11
GX-1-B
Message Pad Excerpt#
SDNY GM 00165560
2021.10.11
GX-1-C
Message Pad Excerpt#
SDNY GM 00165562
2021.10.11
GX-1-J
Message Pad Excerpt#
SDNY_GM_00165584
2021.10.11
GX-1-K
Message Pad Excerpt#
SDNY GM 00165587
2021.10.11
GX-1-M
Message Pad Excerpt#
SDNY_GM_00165610
2021.10.11
GX-1-0
Message Pad Excerpt#
SDNY_GM_00165622
2021.10.11
GX-1-P
Message Pad Excerpt#
SDNY GM 00165625
2021.10.11
GX-2
Physical Message Pad#
2021.10.11
GX-2-A
Message Pad Cover#
SDNY_GM_00165629
2021.10.11
GX-2-C
Message Pad Excerpt#
SDNY GM 00165643
2021.10.11
GX-2-D
Message Pad Excerpt#
SDNY GM 00165644
2021.10.11
GX-2-E
Message Pad Excerpt#
SDNY_GM_00165646
2021.10.11
GX-2-F
Message Pad Excerpt#
SDNY GM 00165647
2021.10.11
GX-2-G
Message Pad Excerpt#
SDNY GM 00165648
2021.10.11
GX-2-H
Message Pad Excerpt#
SDNY_GM_00165649
2021.10.11
GX-2-I
Message Pad Excerpt#
SDNY_GM 00165650
2021.10.11
GX-2-J
Message Pad Excerpt#
SDNY GM 00165651
2021.10.11
GX-2-K
Message Pad Excerpt#
SDNY_GM_00165652
2021.10.11
GX-2-L
Message Pad Excerpt#
SDNY GM 00165653
2021.10.11
GX-2-M
Message Pad Excerpt#
SDNY GM 00165654
2021.10.11
GX-2-N
Message Pad Excerpt#
SDNY_GM_00165655
2021.10.11
GX-2-0
Message Pad Excerpt#
SDNY_GM 00165658
2021.10.11
GX-2-P
Message Pad Excerpt#
SDNY GM 00165659
2021.10.11
GX-2-Q
Message Pad Excerpt#
SDNY GM 00165660
2021.10.11
GX-2-R
Message Pad Excerpt#
SDNY_GM_00165663
2021.10.11
GX-2-S
Message Pad Excerpt#
SDNY GM 00165669
2021.10.11
GX-2-T
Message Pad Excerpt#
SDNY_GM_00165670
2021.10.11
GX-2-U
Message Pad Excerpt#
SDNY GM 00165674
2021.10.11
GX-2-V
Message Pad Excerpt#
SDNY GM 00165677
2021.10.11
GX-2-W
Message Pad Excerpt#
SDNY_GM_00165682
2021.10.11
GX-3
Physical Message Pad#
2021.10.11
GX-3-A
Message Pad Cover#
SDNY GM 00165684
2021.10.11
GX-3-B
Message Pad Excerpt#
SDNY_GM_00165688
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
1
EFTA00024238

=== Page 2 ===
GX-3-C
Message Pad Excerpt#
SDNY GM 00165689
2021.10.11
GX-3-D
Message Pad Excerpt#
SDNY_GM_00165690
2021.10.11
GX-3-E
Message Pad Excerpt#
SDNY GM 00165692
2021.10.11
GX-3-F
Message Pad Excerpt#
SDNY GM 00165694
2021.10.11
GX-3-G
Message Pad Excerpt#
SDNY_GM_00165699
2021.10.11
GX-3-H
Message Pad Excerpt#
SDNY GM 00165700
2021.10.11
GX-3-1
Message Pad Excerpt#
SDNY GM 00165701
2021.10.11
GX-3-J
Message Pad Excerpt#
SDNY_GM 00165703
2021.10.11
GX-3-K
Message Pad Excerpt#
SDNY GM 00165704
2021.10.11
GX-3-L
Message Pad Excerpt#
SDNY GM 00165706
2021.10.11
GX-3-M
Message Pad Excerpt#
SDNY GM 00165709
2021.10.11
GX-3-N
Message Pad Excerpt#
SDNY_GM_00165710
2021.10.11
GX-3-O
Message Pad Excerpt#
SDNY GM 00165711
2021.10.11
GX-3-P
Message Pad Excerpt#
SDNY GM 00165714
2021.10.11
GX-3-Q
Message Pad Excerpt#
SDNY_GM_00165719
2021.10.11
GX-3-R
Message Pad Excerpt#
SDNY_GM 00165729
2021.10.11
GX-3-S
Message Pad Excerpt#
SDNY GM 00165742
2021.10.11
GX-3-T
Message Pad Excerpt#
SDNY_GM_00165743
2021.10.11
GX-3-U
Message Pad Excerpt#
SDNY GM 00165744
2021.10.11
GX-3-V
Message Pad Excerpt#
SDNY GM 00165745
2021.10.11
GX-3-W
Message Pad Excerpt#
SDNY_GM_00165747
2021.10.11
GX-3-X
Message Pad Excerpt#
SDNY GM 00165731
2021.10.11
GX-3-Y
Message Pad Excerpt#
SDNY GM 00165736
2021.10.11
GX-3-Z
Message Pad Excerpt#
SDNY_GM_00165737
2021.10.11
GX-3-AA
Message Pad Excerpt#
SDNY GM 00165738
2021.10.11
GX-3-BB
Message Pad Excerpt#
SDNY GM 00165739
2021.10.11
GX-3-CC
Message Pad Excerpt#
SDNY_GM_00165740
2021.10.11
GX-3-DD
Message Pad Excerpt#
SDNY_GM 00165741
2021.10.11
GX-3-EE
Message Pad Excerpt#
SDNY GM 00165742
2021.10.11
GX-3-FF
Message Pad Excerpt#
SDNY_GM_00165743
2021.10.11
GX-3-GG
Message Pad Excerpt#
SDNY GM 00165744
2021.10.11
GX-3-HH
Message Pad Excerpt#
SDNY GM 00165745
2021.10.11
GX-3-II
Message Pad Excerpt#
SDNY_GM_00165747
2021.10.11
GX-3-JJ
Message Pad Excerpt#
SDNY GM 00165749
2021.10.11
GX-3-KK
Message Pad Excerpt#
SDNY GM 00165750
2021.10.11
GX-4
Physical Message Pad#
2021.10.11
GX-4-A
Message Pad Cover#
SDNY_GM_00165751
2021.10.11
GX-4-B
Message Pad Excerpt#
SDNY GM 00165752
2021.10.11
GX-4-C
Message Pad Excerpt#
SDNY_GM_00165754
2021.10.11
GX-4-D
Message Pad Excerpt#
SDNY GM 00165759
2021.10.11
GX-4-E
Message Pad Excerpt#
SDNY GM 00165761
2021.10.11
GX-4-F
Message Pad Excerpt#
SDNY GM 00165776
2021.10.11
GX-4-G
Message Pad Excerpt#
SDNY_GM_00165790
2021.10.11
GX-4-H
Message Pad Excerpt#
SDNY GM 00165798
2021.10.11
GX-4-I
Message Pad Excerpt#
SDNY GM 00165811
2021.10.11
GX-4-J
Message Pad Excerpt#
SDNY GM 00165815
2021.10.11
GX-4-K
Message Pad Excerpt#
SDNY GM 00165817
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
2
EFTA00024239

=== Page 3 ===
10 Series
Birth Certificates
GX
Description
Bates Number/Identifier
Produced to Defense
GX-11
Certified Birth Certificate of Minor Victim-4#
SDNY GM 02765030
2021.10.11
GX-12
Certified Birth Certificate of Minor Victim-1#
SDNY_GM_02760681
2021.10.11
GX-13
Certified Birth Certificate of Minor Victim-2#
SDNY GM 02753693
2021.10.11
GX-14
Certified Birth Certificate of Minor Victim-5#
SDNY GM 02765767
2021.10.28
GX-15
Certified Birth Certificate of Minor Victim-6#
SDNY_GM_02760679-SDNY_GM_02760680
2021.10.11
GX-16
Certified Birth Certificate of Minor Victim-3#
SDNY GM 02766968
2021.10.28
50 Series
Other Physical Exhibits
GX
Description
Bates Number/Identifier
Produced to Defense
GX-51
Florida Massage Table
2021.10.11
GX-51-A
Photograph of Underside of Florida Massage Table
SDNY GM 02763005
2021.10.11
GX-51-B
Photograph of Sticker on Florida Massage Table
SDNY GM 02763006
2021.10.11
GX-51-C
Photograph of Sticker on Florida Massage Table
SDNY GM 02763007
2021.10.11
GX-52
Black Contact Book
2021.10.11
GX-52-A
Scanned Page from Black Contact Book#
SDNY_GM_02763008-SDNY_GM_02763008
2021.10.11
GX-52-B
Scanned Page from Black Contact Book
SDNY_GM_02763009-SDNY_GM_02763009
2021.10.11
GX-52-C
Scanned Page from Black Contact Book
SDNY GM 02763010-SDNY GM 02763010
2021.10.11
GX-52-D
Scanned Page from Black Contact Book
SDNY_GM_02763011-SDNY_GM_02763011
2021.10.11
GX-52-E
Scanned Page from Black Contact Book
SDNY GM 02763013-SDNY GM 02763014
2021.10.11
GX-52-F
Scanned Page from Black Contact Book#
SDNY GM 02763015-SDNY GM 02763015
2021.10.11
GX-52-G
Scanned Page from Black Contact Book#
SDNY_GM_02763016-SDNY_GM_02763016
2021.10.11
GX-52-H
Scanned Page from Black Contact Book
SDNY GM 02765768
2021.10.11
GX-53
Box of five costumes
2021.10.11
GX-54
Hard Drive NYC024350
2021.10.11
GX-55
Hard Drive NYC024349
2021.10.11
GX-56
Hard Drive NYC024383
2021.10.11
GX-57
New York Massage Table
2021.10.11
GX-57-A
Photograph of Underside of New York Massage Table
SDNY_GM_02763019-SDNY_GM_02763019
2021.10.11
GX-57-B
Photograph of Sticker on New York Massage Table
02763018-SDNY GM 02763018
2021.10.11
GX-58
Pair of Boots
2021.10.11
100 Series
Photographs of People
GX
Description
Bates Number/Identifier
Produced to Defense
GX-101
Photograph of Minor Victim-2#
SDNY GM 00166005
2021.10.11
GX-102
Photograph of Minor Victim-2#
SDNY GM 02750527
2021.10.11
GX-103
Photograph of Minor Victim-2#
SDNY GM 02760624
2021.10.11
GX-104
Photograph of Minor Victim-4#
SDNY GM 02753398
2021.10.11
GX-105
Photograph of Females, Including Minor Victim-4#
SDNY GM 02753398
2021.10.11
GX-106
Photograph of Minor Victim-1#
SDNY GM 00165992
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
3
EFTA00024240

=== Page 4 ===
GX-107
Photograph of Minor Victim-1#
SDNY GM 00165995
2021.10.11
GX-108
Photograph of Minor Victim-1#
SDNY GM 00165999
2021.10.11
GX-109
Photograph of Minor Victim-3#
SDNY GM 00166002
2021.10.11
GX-110
Photograph of
SDNY GM 02753621
2021.10.11
GX-111
Photograph of Ghislaine Maxwell
SDNY_GM_02753632
2021.10.11
GX-112
Photograph of Jeffery Epstein
SDNY GM 02753623
2021.10.11
GX-113
Photograph of Minor Victim-5#
Made Available for Review
2021.10.11
GX-114
Photograph of Minor Victim-5#
SDNY_GM_02753629
2021.10.11
200 Series
Photographs and Videos from PBPD Search
GX
Description
Bates Number/Identifier
Produced to Defense
GX-201
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174459
2021.10.11
GX-202
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174460
2021.10.11
GX-203
Photograph of Exterior at 358 El Brillo Way
SDNY_GM_00174461
2021.10.11
GX-204
Photograph of Exterior at 358 El Brillo Way
SDNY_GM_00174470
2021.10.11
GX-205
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174471
2021.10.11
GX-206
Photograph of Exterior at 358 El Brillo Way
SDNY_GM_00174472
2021.10.11
GX-207
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174473
2021.10.11
GX-208
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174381
2021.10.11
GX-209
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174474
2021.10.11
GX-210
Photograph of Exterior at 358 El Brillo Way
SDNY_GM_00174476
2021.10.11
GX-211
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174477
2021.10.11
GX-212
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174478
2021.10.11
GX-213
Photograph of Exterior at 358 El Brillo Way
SDNY_GM_00174479
2021.10.11
GX-214
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174480
2021.10.11
GX-215
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174481
2021.10.11
GX-216
Photograph of Exterior at 358 El Brillo Way
SDNY_GM_00174482
2021.10.11
GX-217
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174483
2021.10.11
GX-218
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174484
2021.10.11
GX-219
Photograph of Exterior at 358 El Brillo Way
SDNY_GM_00174490
2021.10.11
GX-220
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174491
2021.10.11
GX-221
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174492
2021.10.11
GX-222
Photograph of Exterior at 358 El Brillo Way
SDNY_GM_00174493
2021.10.11
GX-223
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY_GM_00174366
2021.10.11
GX-224
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174367
2021.10.11
GX-225
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY_GM_00174368
2021.10.11
GX-226
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174518
2021.10.11
GX-227
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174521
2021.10.11
GX-228
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174524
2021.10.11
GX-229
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174525
2021.10.11
GX-230
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174526
2021.10.11
GX-231
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174527
2021.10.11
GX-232
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174528
2021.10.11
GX-233
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174530
2021.10.11
GX-234
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174532
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
4
EFTA00024241

=== Page 5 ===
GX-235
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174533
2021.10.11
GX-236
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174535
2021.10.11
GX-237
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174536
2021.10.11
GX-238
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174545
2021.10.11
GX-239
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174687
2021.10.11
GX-240
Photograph of First Floor Office & Living Room at 358 El Brillo Way
GM 00174688
2021.10.11
GX-241
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174698
2021.10.11
GX-242
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY_GM_00174442
2021.10.11
GX-243
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174444
2021.10.11
GX-244
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174445
2021.10.11
GX-245
Photograph of First Floor Office & Living Room at 358 El Brillo Way#
SDNY_GM_00174699
2021.10.11
GX-246
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174446
2021.10.11
GX-247
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174447
2021.10.11
GX-248
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174700
2021.10.11
GX-249
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174704
2021.10.11
GX-250
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174448
2021.10.11
GX-251
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY_GM_00174449
2021.10.11
GX-252
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174450
2021.10.11
GX-253
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174451
2021.10.11
GX-254
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174452
2021.10.11
GX-255
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174707
2021.10.11
GX-256
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174726
2021.10.11
GX-257
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY_GM_00174727
2021.10.11
GX-258
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY_GM 00174369
2021.10.11
GX-260
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174425
2021.10.11
GX-261
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174426
2021.10.11
GX-262
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174427
2021.10.11
GX-263
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY 00174428
2021.10.11
GX-264
Photograph of Kitchen at 358 El Brillo Way
SDNY GM 00174504
2021.10.11
GX-265
Photograph of Kitchen at 358 El Brillo Way
SDNY_GM_00174505
2021.10.11
GX-266
Photograph of Kitchen at 358 El Brillo Way
SDNY GM 00174506
2021.10.11
GX-267
Photograph of Kitchen at 358 El Brillo Way
SDNY GM 00174685
2021.10.11
GX-268
Photograph of Kitchen at 358 El Brillo Way
SDNY_GM_00174686
2021.10.11
GX-269
Photograph of Master Bedroom at 358 El Brillo Way
GM 00174594
2021.10.11
GX-270
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174432
2021.10.11
GX-271
Photograph of Master Bedroom at 358 El Brillo Way
SDNY_GM_00174596
2021.10.11
GX-272
Photograph of Master Bedroom at 358 El Brillo Way
SDNY_GM_00174599
2021.10.11
GX-273
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174600
2021.10.11
GX-276
Photograph of Master Bedroom at 358 El Brillo Way*
SDNY_GM_00174601
2021.10.11
GX-277
Photograph of Master Bedroom at 358 El Brillo Way
SDNY_GM_00174602
2021.10.11
GX-278
Photograph of Master Bedroom at 358 El Brillo Way*
SDNY GM 00174603
2021.10.11
GX-279
Photograph of Master Bedroom at 358 El Brillo Way
SDNY_GM 00174604
2021.10.11
GX-280
Photograph of Master Bedroom at 358 El Brillo Way
SDNY_GM_00174605
2021.10.11
GX-281
Photograph of Master Bedroom at 358 El Brillo Way
SDNY_GM_00174433
2021.10.11
GX-282
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174434
2021.10.11
GX-283
Photograph of Master Bedroom at 358 El Brillo Way
SDNY_GM_00174435
2021.10.11
GX-284
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174436
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
5
EFTA00024242

=== Page 6 ===
GX-285
Photograph of Master Bedroom at 358 El Brillo Way*
SDNY GM 00174440
2021.10.11
GX-286
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174453
2021.10.11
GX-287
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174454
2021.10.11
GX-288
Photograph of Master Bedroom at 358 El Brillo Way*
SDNY GM 00174456
2021.10.11
GX-289
Photograph of Second Floor at 358 El Brillo Way
SDNY_GM_00174557
2021.10.11
GX-290
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174558
2021.10.11
GX-291
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174559
2021.10.11
GX-292
Photograph of Second Floor at 358 El Brillo Way
SDNY_GM_00174560
2021.10.11
GX-293
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174563
2021.10.11
GX-294
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174419
2021.10.11
GX-295
Property Receipts
SDNY GM 02753638-02753643
2021.10.11
GX-296
Video of Walkthrough at 358 El Brillo Way*
2021.10.11
300 Series
ESI Photographs
GX
Description
Bates Number/Identifier
Produced to Defense
GX-301
Photograph of Jet
SDNY GM 02753644-2753692
2021.10.11
GX-302
Photograph of Jet
SDNY GM 02753644-2753692
2021.10.11
GX-303
Photograph of Jet Interior
SDNY GM 02753644-2753692
2021.10.11
GX-304
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-305
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-306
Photograph of Ghislaine Maxwell
SDNY_GM_02753644-2753692
2021.10.11
GX-307
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-308
Photograph of Island
SDNY GM 02753644-2753692
2021.10.11
GX-309
Photograph of Minor Victim-3*#
Made Available for Review
2021.10.11
GX-310
Photograph of Jeffrey Epstein and
SDNY GM 02753644-2753692
2021.10.11
GX-311
Photograph of Plane (N404CE)
SDNY GM 02753644-2753692
2021.10.11
GX-312
Photograph of Plane (N908JE)
SDNY GM 02753644-2753692
2021.10.11
GX-313
Photograph of Ghislaine Maxwell and Jeffrey Epstein*
Made Available for Review
2021.10.11
GX-314
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-315
Photograph of Jeffrey Epstein and Plane
02753644-2753692
2021.10.11
GX-316
Photograph of Ghislaine Maxwell,
and
SDNY GM 02753644-2753692
2021.10.11
GX-317
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-318
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY_GM_02753644-2753692
2021.10.11
GX-319
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY_GM_02753644-2753692
2021.10.11
GX-320
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-321
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY_GM_02753644-2753692
2021.10.11
GX-322
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY_GM_02753644-2753692
2021.10.11
GX-323
Photograph of Ranch
SDNY GM 02753644-2753692
2021.10.11
GX-324
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-325
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-326
Photograph of Island
SDNY GM 02753644-2753692
2021.10.11
GX-327
Photograph of
SDNY GM 02753644-2753692
2021.10.11
GX-328
Photograph of Zorro Ranch Entryway
SDNY_GM_02753644-2753692
2021.10.11
GX-329
Photograph of Jeffrey Epstein and
SDNY GM 02753644-2753692
2021.10.11
GX-330
Photograph of
SDNY GM 02753644-2753692
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
6
EFTA00024243

=== Page 7 ===
GX-331
Photograph of Ghislaine Maxwell,
and
SDNY GM 02753644-2753692
2021.10.11
GX-332
Photograph of Minor Victim-5*#
Made Available for Review
2021.10.11
GX-333
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-334
Photograph of Ghislaine Maxwell and
SDNY GM 02753644-2753692
2021.10.11
GX-335
Photograph of Ghislaine Maxwell and
SDNY GM 02753644-2753692
2021.10.11
GX-336
Photograph of Planes
SDNY GM 02753644-2753692
2021.10.11
GX-337
Photograph of Ghislaine Maxwell on Plane
SDNY GM 02753644-2753692
2021.10.11
GX-338
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-339
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-340
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-341
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-342
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY_GM 02753644-2753692
2021.10.11
GX-343
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-344
Photograph of Helicopter
SDNY GM 02753644-2753692
2021.10.11
GX-345
Photograph of Helicopter
SDNY_GM_02753644-2753692
2021.10.11
GX-346
Photograph of Island
SDNY GM 02753644-2753692
2021.10.11
GX-347
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-348
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY_GM_02753644-2753692
2021.10.11
400 Series
ESI from Relativity
GX
Description
Bates Number/Identifier
Produced to Defense
GX-401
Email
SDNY GM 02736489-SDNY GM 02736489
2021.10.11
GX-402
Email Chain
SDNY_GM_02736488-SDNY_GM_02736488
2021.10.11
GX-403
Email Chain
SDNY GM GM 02736598
2021.10.11
GX-404
Email Chain
SDNY_GM_02736491-SDNY_GM_02736491
2021.10.11
GX-405
NYC024349 System Information
SDNY GM 02762473
2021.10.11
GX-406
Email Chain between Jeffrey Epstein and Minor Victim-3#
SDNY GM 00631742-SDNY GM 00631742
2021.10.11
GX-407
Email Chain between Jeffrey Epstein and Ghislaine Maxwell
SDNY_GM_00623470-SDNY_GM_00623470
2021.10.11
GX-408
Email from Ghislaine Maxwell to Jeffrey Epstein
SDNY_GM_00579091-SDNY_GM_00579091
2021.10.11
GX-409
Email
2021.10.11
GX-410
Email
SDNY_GM_02736735-SDNY_GM_02736735
2021.10.11
GX-412
Email Chain
SDNY_GM_02741883-SDNY_GM_02741884
2021.10.11
GX-413
Email
SDNY GM GM 02741405
2021.10.11
GX-415
Email Chain
SDNY GM 02741441-SDNY GM 02741442
2021.10.11
GX-416
List of Women
SDNY_GM_02736115-SDNY_GM_02736115
2021.10.11
GX-416-B
List of Women - Metadata
2021.10.28
GX-417
List and Contact Info of Masseuses#
SDNY GM 02735985-SDNY GM 02735991
2021.10.11
GX-417-B
List and Contact Info of Masseuses - Metadata
2021.10.11
GX-418
List and Contact Info of Palm Beach House Workers & Maintenance
SDNY_GM_02736160-SDNY_GM_02736166
2021.10.11
GX-418-B
List and Contact Info of Palm Beach House Workers & Maintenance - Metadata
2021.10.11
GX-419
NYC024350 System Information
SDNY GM 02762473
2021.10.11
GX-420
List of PB New Shampoo and Massage Products
SDNY_GM_02736212-SDNY_GM_02736212
2021.10.11
GX-420-B
List of PB New Shampoo and Massage Products - Metadata
2021.10.11
GX-421
Massage Therapist Help Wanted Ad
SDNY_GM_02736260-SDNY_GM_02736260
2021.10.11
GX-421-B
Massage Therapist Help Wanted Ad- Metadata
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
7
EFTA00024244

=== Page 8 ===
GX-422
Ghislaine Maxwell and Jeffrey Epstein Relationship Essay
SDNY 02736272-SDNY GM 02736272
2021.10.11
GX-422-B
Ghislaine Maxwell and Jeffrey Epstein Relationship Essay - Metadata
2021.10.11
GX-423
Jeffrey Epstein Amazon Order Confirmation
SDNY_GM_00567862
2021.10.11
500 Series
Financial Exhibits
GX
Description
Bates Number/Identifier
Produced to Defense
GX-501
June 2007 JPMC Statement for Air Ghislaine
SDNY GM 00277989
2021.10.11
GX-502
June 2007 JPMC Statement for Ghislaine Maxwell
SDNY_GM_00321356-SDNY_GM_00321363
2021.10.11
GX-503
J.P. Morgan Entity Account Application
SDNY_GM_00271135-SDNY_GM_00271137
2021.10.11
GX-504
September 2002 JPMC Account Activity
SDNY GM
2021.10.11
GX-505
JPMC October 1999 Asset Account Portfolio Records
SDNY_GM_00306061-SDNY_GM_00306067
2021.10.11
GX-506
Air Ghislaine Account Documents
SDNY_GM_00271605-SDNY_GM_00271610
2021.10.11
GX-507
Ghislaine Maxwell J.P. Morgan Account and Signature
SDNY GM 00068254
2021.10.11
SDNY_GM_00271037-SDNY_GM_00271041,
GX-508
SDNY_GM_00271546-SDNY_GM_00271550,
2021.10.11
J.P. Morgan Records
SDNY_GM_00271584-SDNY_GM_00271593
550 Series
Phone Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-551
May 2004 AT&T Wireless Monthly Statement for Jeffrey Epstein
SDNY_GM_00365036-SDNY_GM_00365049
2021.10.11
600 Series
Miscellaneous Documents
GX
Description
Bates Number/Identifier
Produced to Defense
GX-601
Journal Front Cover
SDNY GM 00165987
2021.10.11
GX-602
Journal Entry
SDNY GM 00165986
2021.10.11
GX-603
January 7, 1996 Journal Entry
SDNY_GM_00165984
2021.10.11
GX-604
January 25, 1996 Journal Entry
SDNY GM 00165982
2021.10.11
GX-605
Journal Back Cover
SDNY GM 00165988
2021.10.11
GX-606
Household Manual
SDNY_GM_00516864-SDNY_GM_00516922
2021.10.11
GX-607
Work Hours Document
SDNY_GM_00515785 SDNY_GM_00515787
2021.10.11
660 Series
Flight Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-661
Logbook from January 23, 2006 to September 19, 2013#
SDNY GM 00005676
2021.10.11
GX-662
Flight Logbook from April 25 1991 to January 19, 2006#
SDNY_GM_00005532-SDNY_GM_00005649
2021.10.11
700 Series
Photographs of Places
GX
Description
Bates Number/Identifier
Produced to Defense
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
8
EFTA00024245

=== Page 9 ===
GX-701
Ghislaine Maxwell New York Townhouse
SDNY GM 02760645
2021.10.11
GX-702
Ghislaine Maxwell London Townhouse
SDNY GM 02762477
2021.10.11
GX-703
Little Saint James
SDNY GM 02760646
2021.10.11
GX-704
Jeffrey Epstein New York Townhouse
SDNY GM 02760647
2021.10.11
GX-705
Paris Apartment Building
SDNY GM 02760648
2021.10.11
GX-706
New Mexico Ranch
SDNY GM 02760649
2021.10.11
720 Series
Maps
GX
Description
Bates Number/Identifier
Produced to Defense
GX-721
Map of Palm Beach
SDNY GM 02762484
2021.10.11
GX-722
Map of Palm Beach
SDNY_GM_02762485
2021.10.11
740 Series
Interlochen Records
GX
Description
Bates Number/Identifier
Produced to Defense
SDNY_GM_00005055, SDNY_GM_00004999-
GX-741
2021.10.11
Donor Records
SDNY GM 00005018
GX-742
Interlochen Application#
SDNY_GM_02753443-SDNY_GM_02753444
2021.10.11
SDNY_GM_02753433-SDNY_GM_02753435,
GX-743
SDNY_GM_02753523-SDNY_GM_02753524,
2021.10.11
Minor Victim-1 Application#
SDNY_GM_02753480-SDNY_GM_02753481
GX-744
Student Roster#
SDNY_GM_00005077-SDNY_GM_00005103
2021.10.11
760 Series
Professional Children's School Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-761
Records for Minor Victim-1#
SDNY_GM_00005511-SDNY_GM_00005514
2021.10.11
780 Series
Palm Beach County School District Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-781
Minor Victim-5 Enrollment Records for 1989-2002
SDNY GM 02753596
2021.10.11
GX-782
Minor Victim-5 Enrollment Records for 2001-2002
SDNY GM 02753597-SDNY GM 02753598
2021.10.11
GX-783
Minor Victim-5 Registration Records
SDNY_GM_02753608-SDNY_GM_02753610
2021.10.11
800 Series
FedEx Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-801
December 16, 2002 Invoice#
SDNY GM 00525676-SDNY GM 00525690
2021.10.11
GX-802
December 23, 2002 Invoice#
SDNY GM 00525700-SDNY GM 00525720
2021.10.11
GX-803
October 14, 2002 Invoice#
SDNY_GM_00431553-SDNY_GM_00431561
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
9
EFTA00024246

=== Page 10 ===
820 Series
Mar-A-Lago Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-821
Human Resources Correspondence Regarding Minor Victim-5's Records
SDNY GM 00120681
2021.10.11
GX-822
Mar-A-Lago Termination List
SDNY_00120686-SDNY_00120702
2021.10.11
900 Series
New York Search Photos
GX
Description
Bates Number/Identifier
Produced to Defense
GX-901
Photograph of Stairwell and Nude Portrait*
SDNY GM 00166249
2021.10.11
GX-902
Photograph of Hallway and Nude Portrait*
SDNY GM 00166251
2021.10.11
GX-903
Photograph of Massage Room*
SDNY GM 00166252
2021.10.11
GX-904
Photograph of Massage Room*
SDNY_GM_00166253
2021.10.11
GX-905
Photograph of Bathroom*
SDNY GM 00166258
2021.10.11
GX-906
Photograph of Massage Table*
SDNY GM 00166260
2021.10.11
GX-907
Photograph of Nude Portrait*
SDNY_GM_00166265
2021.10.11
GX-908
Photograph of Stairwell and Nude Portrait
SDNY GM 00166273
2021.10.11
GX-909
Photograph of Townhouse Exterior
SDNY_GM_00166275
2021.10.11
GX-910
Photograph of Interior and Stairwell
SDNY GM 00166327
2021.10.11
GX-911
Photograph of Interior
SDNY GM 00166328
2021.10.11
GX-912
Photograph of Interior
SDNY_GM_00166386
2021.10.11
GX-913
Photograph of Interior
SDNY GM 00166417
2021.10.11
GX-914
Photograph of Black Binders in Closet
SDNY GM 00166594
2021.10.11
GX-915
Photograph of Stairwell
SDNY GM 00166719
2021.10.11
GX-916
Photograph of Desk
SDNY_GM_00166731
2021.10.11
GX-917
Photograph of Massage Table
SDNY GM 00166746
2021.10.11
GX-918
Photograph of Vanity Drawers
SDNY GM 00166761
2021.10.11
GX-919
Photograph of Costumes
SDNY_GM 00166767
2021.10.11
GX-920
Photograph of Costumes
SDNY GM 00166768
2021.10.11
GX-921
Photograph of Desk
SDNY GM 00166771
2021.10.11
GX-922
Photograph of Interior
SDNY GM 00167663
2021.10.11
GX-923
Photograph of Female Portrait
SDNY GM 00166776
2021.10.11
GX-924
Photograph of Nude Sculpture
SDNY GM 00166778
2021.10.11
GX-925
Photograph of Black Binders in Closet
SDNY_GM_00166779
2021.10.11
GX-926
Photograph of Drawer Contents
SDNY GM 00166782
2021.10.11
GX-927
Photograph of Nude Sculpture
SDNY GM 00166784
2021.10.11
GX-928
Photograph of Interior
SDNY GM 00166907
2021.10.11
GX-929
Photograph of Interior
SDNY_GM_00167081
2021.10.11
GX-930
Photograph of Nude Portrait in Bathroom*
SDNY GM 00167094
2021.10.11
GX-931
Photograph of Nude Portrait in Bathroom*
SDNY GM 00167095
2021.10.11
GX-932
Photograph of Townhouse Exterior
SDNY_GM_00167102
2021.10.11
GX-933
Photograph of Interior
SDNY GM 00167111
2021.10.11
GX-934
Photograph of Interior
SDNY GM 00167211
2021.10.11
GX-935
Photograph of Bookshelves and Cabinet Contents
SDNY_GM_00167251
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
10
EFTA00024247


c1: EFTA00023545
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023545.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE:
Date: Fri, 18 Sep 2020 14:44:32 +0000
Thanks!
Original Message
From:
Sent: Friday, September 18, 2020 10:07 AM
To:
Subject: Re:
Ok. I'm going to reach out to federal defenders.
Sent from my iPhone
> On Sep 18, 2020, at 10:06 AM,
wrote:
>
>
Correct, around the 1999-2002 period, I think.
>
On Sep 18, 2020, at 9:59 AM,
wrote:
She is a former personal assistant to Epstein, correct? I just don't recall the conversation surrounding
subpoenaing her, so wanted to check. Thanks.
Sent from my iPhone
EFTA00023545


c1: EFTA00023937
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023937.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Priorities webpage -- drant
Date: Tue, 05 Nov 2019 21:37:29 +0000
Attachments: SDNY_PRIORITIES_DRAFT_Revised_11.5.19_nvb.docx
Attached for your review is a draft Priorities webpage. There are further edits to be made - some formatting (for
instance, putting dates in the right order or making sure that fonts and indentations are correct), some stylistic
(e.g., the Combatting Corruption entries each begin with language akin to a headline while the others do not),
and some more substantive (do we want to add or delete particular cases?). Also, the visuals that go with each
subpage have not been completed. In some instances, that's because Nick has not located visuals that he thinks
are usable or a good fit. In other places, he has identified visuals that he plans to add, but has yet to do so. That
said, many of the subpages do have visuals. In order to view the visuals for any subpage, you hit the "Ctrl" key
while clicking on the heading for the subpage - e.g., for Thwarting and Responding to Acts of Terror, you press
on the "Ctrl" key and click on the heading Thwarting and Responding to Acts of Terror. I've also attached a link
(below), which is easier to open for that subpage so that you can see how the subpages will look. Please let me
know if you have questions. Thanks.
Regards,
https://www.justice.gov/usao-sdny/thwarting-and-responding-acts-terror-and-enforcing-international-sanctions
EFTA00023937


c1: EFTA00023683
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023683.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS) [Contractor]"
)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
)"
Subject: RE: Epstein/Maxwell Upload
Date: Thu, 24 Sep 2020 15:45:40 +0000
Not a problem. I will let you know when everything has been copied to the below location.
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:42 AM
To:
(USANYS) [Contractor]
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
That's what I figured. Thanks! Now that they are all good to go would you please export both Deutsche Bank and
JPMorgan productions to the shared here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\Discovery\GM\04 Fourth Production\T BE PRODUCED
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:39 AM
To:
(USANYS) [Contractor]
>;
Cc:
(USANYS) [Contractor]
>;
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
No way to put a confidential stamp on a excel file. There should be an image placeholder that says document produced in
native format which has the confidential stamp.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:36 AM
To:
(USANYS) [Contractor]
>;
)
Cc:
(USANYS) [Contractor]
is
(USANYS)
>;
Subject: RE: Epstein/Maxwell Upload
Thanks
These look great. One quick question, on documents in native format (excel files) is there a confidential
stamp? I've checked and it seems the answer is no but I just want to be sure that I'm not missing anything.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:20 AM
EFTA00023683

=== Page 2 ===
To:
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
The documents should now be available for review. Please let me know if there are any questions.
Thank you.
From:
)
Sent: Thursday, September 24, 2020 9:11 AM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
These documents are not supposed to be privileged reviewed. The only documents that need to be privilege reviewed
are the electronic search warrant returns.
Thanks,
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 9:05 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
V.
(USANYS)
is
)
Subject: RE: Epstein/Maxwell Upload
The data is probably secured for privilege review. Please let me know if these documents are not supposed to be
privileged reviewed.
Thank you.
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 5:39 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
is
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
Hey
When I click on each of those links I'm brought to a Relativity page with no data. Am I doing something wrong?
Thanks,
EFTA00023684

=== Page 3 ===
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 11:32 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
>;
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
The production of the documents has been completed. The below are links to the production for you to review:
Deutsche Bank - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343058
JP Morgan - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343059
Please review the documents and let me know if anything needs to be adjusted with the production.
Thank you.
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:26 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
>;
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
1. Yes, we want to mark all of them confidential
2.
We are working on that.
3.
I suppose database load files? We want to retain the files as they are currently formatted as best we can.
4. That won't be an issue. I don't think we will be searching through them; the purpose is just to be able to stamp
them.
Thanks!
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:10 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
V.
(USANYS)
is
Subject: RE: Epstein/Maxwell Upload
I know you want to produce these documents can you please tell me the following:
1.
Will you placing a Confidential stamp on these documents?
2.
What bates number do you wish to use on the documents?
3.
How do you want to produce the documents (single page tiff images, database load files or PDF production).
4. Also please note that once the documents have been loaded to Relativity there is no way to run any searches for
these images since they are mostly images and video.
Please let me know if there are any questions.
Thank you.
EFTA00023685

=== Page 4 ===
From:
(USANYS) [Contractor]
Sent: Thursday, September 17, 2020 4:54 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
>;
(USANYS)
is
Subject: Epstein/Maxwell Upload
Hey
We have some materials that we need uploaded to Relativity to the Epstein database for the purpose of stamping them.
The files in question number about 40,000 and are about 300GB in size. They are currently copying onto a drive to be sent
to Relativity and should be ready by tomorrow. Do you want to see them first or can they go directly to PAE?
Folder/Subfolder in Relativity: US V. Epstein
FBI Case File
Images Seized During Search
Thanks,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00023686


c1: EFTA00024864
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024864.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B10
Evidence Item: 31E-MM-108062 -- 1B10
Evidence Type: General
Description:
(U//FOUO) One red rope: ONE (1) BOOK-MASSAGE FOR DUMMIES
Location:
E03707388 - ECR8
E616844 - ECR8, VS33
E5448596 - ECR8, VS33 A
Barcode:
E6516712
Details
Collected On: 08/07/2007 8:00 AM
Receipt Item #: None
CATS ID #:
None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery
Location
Holding Office: NY - NEW YORK
Finalized By:
Area:
Unavailable in data migrated from
Last Inventory: 07/20/2021 12:00 AM
ACS
Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Retention
Retention: Missing
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2007-08-07
Collected From: (U//FOUO)
2210 48TH TERRACE NORTH
WEST PALM BEACH, FL,
Receipt Given:
No
Holding Office:
MM MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/1
EFTA00024864

=== Page 2 ===
FD-1004
FEDERAL BUREAU OF INVESTIGATION
Revised
9-25-2006
EVIDENCE CHAIN-OF-CUSTODY
Evidence Type:
General
Drug
Valuable
Firearms
CART
Special Handling Instructions
Initial Receipt
Date and
Time
Batteries
Biohazard
FGJ
Signature:
HAZMAT
Latents
Refrigerate
60/4/8
Req. Charging
None
Printed Name
Other
Reason: Collected
11:WA
Relinquished Custody
Date and
Accepted Custody
Date and
Time
a
Time
Printed Signature: Name: Jhohand
02/08/2008
Signature:
02/08/2008
10:00am
Printed Name:
Reason:
TRANSPORT
Reason: Transport
10:00m
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
02/08/2008
Signature:
2-08-08
Printed Name:
Printed Name:
Reason: Relinguished custody
3:30pm 3:30 pm
330PM
Reason: STORAGE
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Printed Signature: Name: gill
Signature
4-10-08
04/10/2008
Printed Name:
Reason: RELEASED TO SA.
1100AM.
Reason: Review
11:01am
Relinquished Custody
Date and
Accepted Custody
Date and
M
Time
01-13-09
Signature: IRR
Time
Signature:
1-13-09
Printed Name:
Printed Name:
Reason: Returns 1B
314PM
3/4PM
Reason:
STORAGE
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
RF
Signature:
Printed Name:
6/14/19
Printed Name:
Reason:
Reason:
Firearms Certification:
Printed Name:
Signature:
Date:
Case ID: 31E-MM-148062 1B:
10
Barcode: 54229237
E6516722
EFTA00024865

=== Page 3 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody 4783446 6382
Date and
Accepted Custody
Signature
Signature: UN
Date and
Time
Time
6/17/19
Printed Name/Agency:
FBI
9/20/19
9:35AM
Printed Name/Agency:
Reason: Transferred to NY
Reason:
3:00am
Signature: Relinguished Custody an
Date and
Accepted Custody
Date and
Time
d24/9
Time
Signature:
Printed Name/Agency:
6/24/19
Reason:
40
2:10Pm
Printed Name/Agency:
Reason: Eviden Review
dai:e
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Signature:
9/26/19
Signature: O
Time
Printed Name/Agenc
FBI
9/26/19
Reason: storage
2:20p
Date and
Reason: Accepted Printed Chipsis Name/Age Custody
22op
Relinquished Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
IB: 10
Barcode: P4829837 E651 6712
This form is incomplete without reference to the FD-1087.
EFTA00024866

=== Page 4 ===
FD-597 (Rev 8-11-94)
Page
1
of
/
UNITED STATES DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File #
31E-mm-108062-1810
On (date)
08/07/2007
item(s) listed below were:
Received From
Returned To
Released To
Seized
(Name)
(Street Address)
2210 48 TERRACE NORTH
(City)
WEST PALM BEACH, FL
Description of Item(s): 1) Book - MASSAGE FOR DUMMIES
Received By: A your n (Signature) suchard
Received From:
EFTA00024867


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=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: Travel for Epstein victim for hearing
Date: Fri, 23 Aug 2019 00:51:36 +0000
FYI
-
Forwarded message
From:
Date: Aug 22, 2019 8:31 PM
Subject: Travel for Epstein victim for hearing
To:
Cc:
Hi
I just had another victim reach out to request help with travel for Tuesday. Her name is
represents her. She is currently in LA. We would also like to make arrangements to meet with and interview her
while she is here. I gave her your number and she will reach out to in the AM. Her number is
Thanks,
FBI New York
VCAC/HT
C:
EFTA00024416


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=== Page 1 ===
Event: Accepted: Epstein estate counsel call
Start Date: 2019-10-30 18:30:00 +0000
End Date: 2019-10-30 19:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-10-23 19:49:51 +0000
Date Modified: 2019-10-23 19:49:51 +0000
Priority: 5
DTSTAMP: 2019-10-23 19:38:58 +0000
Attendee:
EFTA00025256


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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
(USANYS)"
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Tue, 26 Oct 2021 23:49:21 +0000
Hi
Defense counsel has requested that we schedule an evidence inspection this week with the defendant present. We'd very
much appreciate it if the marshals could produce the defendant to a proffer room this week at
Our
understanding from
,
copied here, is that the marshals have been producing defendants for meetings of this
type. A CSO and a case agent will be present for the meeting.
Could you please let us know what dates this week would work for the meeting? We are scheduling this with defense
attorneys who are flying in from out of state, so would appreciate if you could let us know what dates work this week.
Thanks very much,
Assistant United States Attorney
Southern District of New York
EFTA00025141


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=== Page 1 ===
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 11, 2021
BY ELECTRONIC MAIL
Esq.
Esq.
New York, NY 10022
Esq.
Esa
Denver, CO 80203
Esq.
Law Offices of
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today the Government is producing materials, including Jencks Act and Giglio
material, regarding the witnesses who may be called to testify at trial in the above-referenced case.
Enclosed please find an index detailing the materials included in today's production.
The Government notes that the records stamped 3522-004 reflect that
testified in the grand jury in connection with the investigation conducted by the Palm Beach State's
Attorney's Office, but the clerk of court has confirmed to the Government that the audio files are
unplayable and, therefore, there is no record of
grand jury testimony.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
EFTA00025287

=== Page 2 ===
Page 2
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
The Government wishes to highlight for you a particular portion of statements made
by non-testifying witness
about Minor Victim-4. In particular
has previously
stated to law enforcement, in sum and substance, that Minor Victim-4 introduced
o Jeffrey
Epstein and instructed
to tell Epstein that
was 18 years old. These statements by
are contained in the Government's non-testifying witness productions, including in the first
such production dated April 12, 2021 (see, e.g., 3501.149-023 at 1; 3501.149-026 at 9; and
3501.149-024 between approximately timestamp 04:20 and timestamp 07:30).
Please note that this letter, the enclosed indices, and the enclosed materials are
governed by the July 31, 2020 Protective Order in this case. In particular, the entire production
is designated as "confidential" under the Protective Order. The index is itself designated as
"confidential," because it includes information regarding records designated as
"confidential" under the Protective Order. The Department of Justice directed this office to
cease the dissemination of materials marked with the word "confidential" in order to avoid
potential confusion with markings reserved for classified documents. Accordingly, in order to
note the appropriate designation of this production under the operative Protective Order in this
case, the materials being produced today are marked with the following label: "SUBJECT TO
PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to
the specific paragraphs of the Protective Order that govern today's production.
Additionally, please note that many of the individuals referenced in this production are
represented by counsel, as detailed in the enclosed indices. The Government reserves its right to
amend and supplement these disclosures.
The Government also writes to notify you of the following matters regarding certain
witnesses that the Government may call to testify at trial in the above-referenced case:
The FBI provided transportation to and from the airport for trial preparation
sessions. The FBI will similarly provide transportation for
when she
travels to New York for trial testimony.
The U.S. Attorney's Office for the Southern District of New York (the "USAO
SDNY") paid for travel to and from a trial preparation session, including hotel
expenses. The USAO SDNY will similarly pay travel and hotel expenses when
travels to New York to testify at trial.
The USAO SDNY paid for
to
accompany
for trial preparation sessions in New
York. The USAO SDNY will similarly pay for
to accompany
to New York in connection with
trial.
EFTA00025288

=== Page 3 ===
Page 3
The USAO SDNY paid for a car to take
The FBI provided meals and snacks to
during trial preparation
sessions.
The USAO SDNY will pay travel and hotel expenses when
travels to
New York to testify at trial.
The USAO SDNY paid for
to travel to and from a witness interview
with the Government in New York, including hotel expenses. The USAO
SDNY will similarly pay travel and hotel expenses when
travels to New
York to testify at trial.
The USAO SDNY paid for travel to and from an August 2019 court hearing
before Judge Berman, including hotel expenses.
The FBI paid for therapy sessions fo
The USAO SDNY will pay travel and hotel expenses when
travels
to New York to testify at trial.
The USAO SDNY paid for
to travel to and from a trial preparation
session in New York.
The USAO SDNY will pay travel and hotel expenses when
ravels to
New York to testify at trial.
The FBI provided transportation to and from the airport for trial preparation
sessions. The FBI will similarly provide transportation for
for trial
testimony.
The USAO SDNY paid for travel to and from a trial preparation session in New
York, including hotel expenses. The USAO SDNY will similarly pay travel
and hotel expenses when
travels to New York to testify at trial
The USAO SDNY paid for lunch for
during trial preparation sessions that took place at mealtimes.
The FBI has paid for transportation for
by car to and from trial
preparation sessions.
EFTA00025289

=== Page 4 ===
Page 4
The USAO SDNY will pay travel and hotel expenses when
travels to
New York to testify at trial.
The USAO SDNY provided a letter to
employer confirming dates of
trial preparation sessions and has agreed to similarly provide a letter to his
employer regarding dates of future trial preparation sessions and trial testimony.
The USAO SDNY paid for
to travel to and from a trial preparation
session in New York, including hotel expenses. The USAO SDNY will
similarly pay travel and hotel expenses when
travels to New York to
testify at trial.
The USAO SDNY paid for
to travel to and from two trial preparation
sessions in New York, including hotel expenses
The USAO SDNY will
similarly pay travel and hotel expenses when
travels to New York to
testify at trial.
The USAO SDNY paid for
to travel to and from a trial preparation
session in New York, including hotel expenses. The USAO SDNY will
similarly pay travel and hotel expenses when
travels to New York to
testify at trial.
The FBI offered the services of FBI victim specialists to all victims, including
The victim services offered included
counseling, assistance with finding appropriate therapy, and assistance with
determining available public benefits and other resources available to crime victims.
The USAO SDNY has offered-or will offer-to provide transportation to and/or from
and hotel accommodations in New York City in connection with the trial testimony of
the witnesses the Government anticipates testifying at the trial. Such arrangements
have not yet been finalized. The USAO SDNY anticipates that it will pay travel and
hotel expenses for trial testimony for at least the following individuals:
EFTA00025290

=== Page 5 ===
Page 5
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
I
EFTA00025291


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Acknowledgment and Notice of Appearance FILED"
Date: Tue, 13 Apr 2021 17:31:59 +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 04/13/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
ACKNOWLEDGMENT AND NOTICE OF APPEARANCE, on behalf of Appellant Ghislaine Maxwell,
FILED. Service date 04/13/2021 by CM/ECF.[3076442] [21-58]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Acknowledgment and Notice of Appearance FILED
Original Filename: Acknowledgment and Notice of Appearance Form 4.5.21-2.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/13/2021] [FileNumber=3076442-0]
[c5024ab6d0b85e0627dbf584811322ded4f4beb7d33cedb1eeb585f9c0d33cc6d8e66f4f9ba254ec0cb70336e4b21
EFTA00026918

=== Page 2 ===
e7b39f9afeaec099c0e8e66e6f9488f4e54]
EFTA00026919


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=== Page 1 ===
From:
(USANYS)"
To:
(ODAG)"
Cc:
(ODAG)"
Subject: RE: Epstein Victim Impact Statements
Date: Thu, 31 Oct 2019 18:27:45 +0000
Hi
The FBI is aware of 1 or 2 victims who indicated they could not come on short notice, but does not recall which victims
they were. There were other victims who decided not to come but cited other reasons, such as scheduling issues or
aversion to press exposure. USAO is not aware of victims who raised scheduling issues. Of course, that doesn't mean
they didn't have them, just that no one recalls anyone affirmatively raising them beyond the 1 or 2.
I also now know that, including victims whose known counsel we contacted as opposed to directly, the number who were
told about the hearing is at least 50, as opposed to 39. I am still working on whether this number of 50 includes all of the
identified Florida victims.
17 is the total number of victims who either spoke or provided written submissions.
From:
(ODAG)
Sent: Wednesday, October 30, 2019 11:33 PM
To:
(USANYS)
Cc:
(ODAG)
Subject: RE: Epstein Victim Impact Statements
,
Thank you for this information. It is very helpful but we need a little more clarity. Can you confirm with
the VW coordinators (USAO and FBI), prosecutors, and agents whether any victims complained about not
being able to participate in the SDNY hearing? Can you also confirm whether the 39 contacted victims
include all of the identified Florida victims? In addition to the 17 victims that spoke directly or through
counsel, did any victims submit letters to the court in their absence?
Petitioner's counsel has alleged that DOJ, specifically SDNY, possesses information that some of the
Epstein victims were unable to attend the SDNY hearing because they did not have sufficient notice to
travel to NY. They believe this information is material to the subjects currently being litigated in the 11th
Circuit. We need to pin this information down so it can be addressed in the government's response which
is due on 10/31.
Again, we apologize for the fire drill but this issue was just raised within the last 48 hours. If you can
provide this information before noon tomorrow it will be greatly appreciated.
From:
(USANYS)
Sent: Wednesday, October 30, 2019 4:34 PM
To:
(ODAG)
EFTA00023930

=== Page 2 ===
Cc:
(ODAG)
Subject: RE: Epstein Victim Impact Statements
Hi
-
We reached out to at least 39 victims, either directly or through attorneys. The number could be higher, but that is the
best as I can confirm today.
At least 17 victims attended the hearing because that is the number that spoke, either directly or through counsel. We
believe there may have been additional who were present but did not speak, based on what their attorneys said.
We are not aware of victims who complained about not having an opportunity, but I'd be hesitant to make a categorical
statement about that, as its possible I am missing something or the Bureau heard any complaints.
From:
(ODAG)
Sent: Wednesday, October 30, 2019 2:04 PM
To:
(USANYS)
Cc:
(ODAG)
Subject: RE: Epstein Victim Impact Statements
Thanks,
If you know of any victims that complained about not having an opportunity to speak in
court or to submit a written letter, that information would be helpful as well.
Thanks
From:
(USANYS)
Sent: Wednesday, October 30, 2019 1:25 PM
To:
(ODAG)
Cc:
(ODAG)
Subject: RE: Epstein Victim Impact Statements
Hi
- I will try to figure out the rough numbers for you. (1) and (2) should be doable, but I am not sure about (3).
From:
(ODAG)
Sent: Wednesday, October 30, 2019 12:53 PM
To:
(USANYS)
Cc:
(ODAG)
Subject: Epstein Victim Impact Statements
Importance: High
,
The Petitioner in the Epstein CVRA case has filed an appeal to the 11th Circuit. One of their issues is the
District Court's refusal to hold a hearing allowing the Epstein victims to "have their day in court." The
Court's ruling is, in part, on the basis that a hearing held in SDNY satisfied this request. The Petitioner has
alleged that not all of the Epstein victims who wanted to speak were able to do so at the New York hearing
because they did not have sufficient notice and were unable to travel to NY.
Can your office provide us some details about the following: 1) how many victims were contacted about
making a victim impact statement; 2) how many victims were able to travel and make an in-person victim
impact statement; and 3) how many victims indicated they wanted to make a victim impact statement but
were unable to do so given the notice/timing of the hearing?
EFTA00023931

=== Page 3 ===
Please provide as much of this information as possible today. I'm very sorry for the quick turnaround but
the Department's response to the mandamus petition is due tomorrow.
I really appreciate your assistance.
National Coordinator for Child Exploitation Prevention & Interdiction
Office of the Deputy Attorney General
Direct:
EFTA00023932


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=== Page 1 ===
From:
To:
Subject: FW: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Date: Mon, 14 Sep 2020 19:32:43 +0000
Attachments: FINAL_LETTER.PDF
PBSA is giving us their entire Epstein file.
Will, when I get the email with the info about how to download the file, I'll forward it to you. Would you please download
everything and save it on the share? You can put it here:
USvEpstein-
2018R01618\Investigation\PBSA Epstein File
Original Message
From:
Sent: Monday, September 14, 2020 3:23 PM
To:
Subject: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
The attached document is in regard to the above referenced case, to which you are a party of or have an interest in. If
you have any questions, please contact our office at
EFTA00023542


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=== Page 1 ===
From:
"
To: "Weinstein, Marc A."
Subject: Accepted: Epstein estate call
Date: Mon, 25 Nov 2019 14:50:35 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: reply brief
Date: Wed, 27 Oct 2021 16:07:36 +0000
Attachments: !Maxwell's_Response_to_Govs_Omnibus_Motns_in_Limine.pdf Govt_Reply_v2.docx;
Government_MIL_[final,_unredacted].pdf
Hi
Here's the latest version of our brief. l'll give you a call in a second to make sure it's on your radar.
Thanks!
From:
Sent: Tuesday, October 26, 2021 9:30 PM
To:
Cc:
is
^
Subject: reply brief
Hi
Judge Nathan has given us 48 hours (i.e. until midnight tomorrow) to write a reply brief. Attached is a partial draft and
their motion. Part I of their brief has a bunch on MV-4, especially at pp. 12-15 and 18. We respond primarily at pp. 10-
11. Would you take a look and see if what we're saying is accurate?
Thanks!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00025146


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell Order on Flashlights/Sleep Disruptions
Date: Fri, 14 May 2021 21:05:59 +0000
Seems reasonable. Thanks!
From:
Sent: Fridav. May 14. 2021 5:05 PM
To:
Cc:
Subject: Maxwell Order on Flashlights/Sleep Disruptions
FYI, Judge Nathan denied Maxwell's request to direct the MDC to stop the flashlight checks, but (reasonably)
directed the MDC to consider whether sleep disruptions can be reduced for pretrial detainees, and to ensure that
Maxwell is only subjected to necessary security protocols.
ORDER as to Ghislaine Maxwell: On April 29, 2021, counsel for Ghislaine Maxwell wrote to the
Court requesting that the Court address her sleeping conditions, with particular emphasis on
counsel's representation, unsupported by affidavit or other factual showing, that guards are
shining a flashlight in Maxwell's eyes every 15 minutes at night. Dkt. No. 256. Defense counsel
claims that the flashlight surveillance in Maxwell's eyes is disrupting her sleep, which in turn is
impacting her ability to prepare for and withstand trial. The Court sought more information by
ordering the Government to confer with legal counsel for the Bureau of Prisons and to respond
to certain questions. Dkt. No. 257. In response, the Government states that MDC staff conduct
flashlight checks of all inmates as a matter of course. Dkt. No. 270. As reported by the
Government, inmates housed with cell mates in the Special Housing Unit are checked with
flashlights every 30 minutes. Inmates housed with others in the general population are
checked multiple times per night at regular intervals. The Government further reports that to
conduct the checks, flashlights are pointed at the ceiling of the cell to confirm that the inmate
is present, breathing, and not in distress. As the Government explains, there are a number of
neutral reasons why BOP's flashlight checks of Maxwell are relatively more frequent than those
of other inmates, including that Maxwell is housed alone, the nature of the charges, and the
potential stress for inmates that can arise in high-profile cases. The MDC has determined that
these factors necessitate more frequent safety and security checks. The Government also
indicates that the prohibition on eye masks is a generally applicable policy, but that Maxwell,
like other inmates, may use other noncontraband items to cover her eyes. To the extent that
Maxwell's April 29, 2021 letter asks the Court to override BOP's determination as to the
frequency of appropriate safety and security check procedures, that request is denied as
factually unsubstantiated and legally unsupported. Certainly nothing in the record plausibly
establishes that current protocols interfere with Maxwell's ability to prepare for her trial and
communicate with her lawyers. Defense counsel's May 7, 2021 letter, Dkt. No. 272, describes
generalized grievances but makes no additional specific and supported application for relief.
Nevertheless, the Court urges the MDC to consider whether sleep disruption for pretrial
detainees can be reduced. The Court also admonishes the MDC and the Government to
continue to ensure that Maxwell is subjected to only those security protocols that BOP
determines are necessary for her safety and security, based upon neutral and applicable
EFTA00024706

=== Page 2 ===
factors, and consistent with the treatment of similarly situated pre-trial detainees. The
Government shall provide a copy of this Order to the Warden and General Counsel for the
MDC. so ORDERED. (Signed by Judge Alison J. Nathan on 5/14/2021) (Inl)
EFTA00024707


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=== Page 1 ===
From:
To:
Subject: RE: U.S. V. Maxwell
Date: Tue, 20 Apr 2021 21:38:30 +0000
Inline-Images: image001.png
Thanks,
is on it.
From:
Sent: Tuesday, April 20, 2021 12:31 PM
To:
Subject: FW: U.S. V. Maxwell
Team, forwarding the below, just got it. Thanks.
From: Robert Y. Lewis
Sent: Tuesday, April 20, 2021 12:23
To:
Subject: U.S. V. Maxwell
Dear
: I represent
,
one of the victims of Jeffrey Epstein and his lieutenant
Ghislaine Maxwell.
would like to attend the upcoming trial of Ms. Maxwell. She will be coming from England, where
she lives.
is not asking the government to pay for any travel expenses, but would like to know if she can be
given any priority (along with other victims of course) in getting into the trial as a spectator, and if so, whether
she needs to make arrangements with your office in advance.
Thank you for all your hard work in bringing Ms. Maxwell to justice.
Best,
Robert Y. Lewis
The Marsh Law Firm PLLC
Cell:
Direct:
EFTA00026840

=== Page 2 ===
THE NATIONAL
CRIME VICTIM
BAR ASSOCIATION
CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential and may be
subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law. Any disclosure, distribution,
copying, or use of the information contained in this message or any attachment by anyone other than the intended recipient,
regardless of address or routing, is strictly prohibited. If you are not the intended recipient, please telephone or email the sender
and delete this message and any attachment from your system.
CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential and
may be subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law. Any
disclosure, distribution, copying, or use of the information contained in this message or any attachment by
anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not the
intended recipient, please telephone or email the sender and delete this message and any attachment from your
system.
IF YOU ARE NOT A CLIENT: This material is general information of an educational nature and is not legal advice.
This communication does not establish or constitute the retention of Marsh Law Firm PLLC for the provision of
legal services, unless explicitly so stated herein. Any attached items, including the content of this e-mail, are
offered "as is" with no guarantee as to their accuracy, timeliness, or completeness.
EFTA00026841


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=== Page 1 ===
From:
To:
Christian Everdell
>, BOBBI C STERNHEIM
"Laura Menninger"
>, Jeff Pagliuca
Cc:
Subject: RE: Redactions: Government motion in limine
Date: Fri, 29 Oct 2021 22:44:53 +0000
Attachments: 1._Motion_to_Preclude_the_Introduction_of_Alleged_Co-
Conspirator_Statements_[redacted].pdf;
1a_Ex._1_to_Motion_to_Preclude_the_Introduction_of_Alleged_Co-
Conspirator_Statements_[redacted].pdf;
2_Motion_to_Exclude_Evidence_Prsnt_to_Rule_404(b)_[redacted].pdf;
aa_Ex_A_to_Motion_to_Exclude_Evidence_Prsnt_to_Rule_404(b)_[redacted].pdf;
3._Motion_to_Exclude_Under_FRE_702_and_Daubert_[redacted].pdf;
3b._Ex._2_to_Motion_to_Exclude_Under_FRE_702_and_Daubert_[redacted].pdf;
4._Motion_to_Exclude_Accuser-3_Evidence_[redacted].pdf;
7._Motion_to_Exclude_Government_Exhibit_52_[redacted].pdf
8_Motion_to_Exclude_Items_Purportedly_Seized_During_Search_of_358_El_E
[redacted].pdf; 9_Motion_to_Suppress_Identification_[redacted]_Final.pdf;
10. _Motion_to_Preclude_Law_Enforcement_Witnesses_from_Offering_Expert_Opinion_Te
stimony_[redacted].pdf;
13._Motion_to_Preclude_Introduction_of_Government_Exhibits_251,_288,_294,_313_and_
606_[redacted].pdf Govt_Omnibus_Opp_[redacted]_Final.pdf;
!2021.10.27_Maxwell_Reply_ISO_Motns_In_Limine_[redacted]_Final.pdf
All,
For filing purposes, attached are redacted versions of the defendant's motions and exhibits, the government's omnibus
opposition, and the defendant's omnibus reply. Below are our notes on which exhibits should be sealed. Please let us
know if you would like to add any redactions or if you have any questions.
Defense Motions
Sealed
The following exhibits should be sealed
Exhibit A to Motion 4 (grand jury testimony)
Exhibit B to Motion 4 (grand jury testimony)
Exhibit 1 to Motion 7 (contact book)
Exhibit 2 to Motion 7 (deposition)
Exhibit A to Motion 8 (inventory)
Exhibit A to Motion 9 (photobook)
Exhibit to Motion 13 (various exhibits)
Redactions (attached)
Motion 1 and Exhibit 1 to Motion 1
Motion 2 and Exhibit A to Motion 2
Motion 3 and Exhibit 2 to Motion 3
Motion 4
Motion 7
Motion 8
EFTA00025062

=== Page 2 ===
Motion 9
Motion 10
Motion 13
No redactions
We are not seeking redactions to defense opening briefs for defense motions 5, 6, 11, and 12.
We are not seeking redactions to Exhibit 1 to Motion 3 (Government expert notice)
Government Opposition
We are not seeking to redact Government exhibits A and B (articles)
Defense Reply
Sealed
The following exhibits should be sealed
Exhibit A (tax documents)
Exhibit B (302)
Exhibit C (medical report)
Exhibit D (transcript)
No redactions
We are not seeking redactions to defense Exhibit E (English indictment)
From:
Sent: Friday, October 29, 2021 6:21 PM
To: Christian Everdell
is
>; BOBBI C
STERNHEIM
>; Laura Menninger
>; Jeff Pagliuca
Cc:
is
Subject: RE: Redactions: Government motion in limine
Happy to jump on a call. We're almost finished with the materials we'll be sending you in a second wave, so why don't we
get the first wave filed, and we'll send you the second set, and then we can get on the phone. Does that work?
From: Christian Everdell
Sent: Friday, October 29, 2021 6:19 PM
To:
is
>; BOBBI C
STERNHEIM
>; Laura Menninger
>; Jeff Pagliuca
Cc:
is
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
Got it. We are filing the response now.
I was thinking through the joint cover letter and I think there are a few more logistics we have to discuss. Can you jump
on a quick call?
From:
Sent: Friday, October 29, 2021 6:16 PM
To: Christian Everdell
is
>; BOBBI C
STERNHEIM
>; Laura Menninger
>; Jeff Pagliuca
Cc:
is
)
EFTA00025063

=== Page 3 ===
Subject: RE: Redactions: Government motion in limine
Thanks for asking - yes, that's correct.
From: Christian Everdell
Sent: Friday, October 29, 2021 6:06 PM
To:
is
>; ; BOBBI C
STERNHEIM
>; Laura Menninger
>; Jeff Pagliuca
Cc:
>;
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
Just so I am clear on sequencing, you are now waiting for us to file the redacted version of our response brief, correct?
From:
Sent: Friday, October 29, 2021 5:49 PM
To: Christian Everdell
is
>; BOBBI C
STERNHEIM
>; Laura Menninger
>; Jeff Pagliuca
Cc:
is
Subject: RE: Redactions: Government motion in limine
Thanks, Chris. We'll get this first group filed and then send you the next batch.
From: Christian Everdell
Sent: Friday, October 29, 2021 5:42 PM
To:
>; BOBBI C STERNHEIM
>; Laura
Menninger
>; Jeff Pagliuca
Cc:
is
is
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
The redactions are consistent with what the government had proposed before. We do not have any redactions to add to
these documents. But for the record, we object to all of the government's proposed redactions.
Please send me the next batch when you have them ready.
Thanks,
Chris
From:
Sent: Friday, October 29, 2021 4:55 PM
To: Christian Everdell
>; BOBBI c STERNHEIM
>; Laura Menninger
>; ; Jeff Pagliuca
Cc:
is
is
;
EFTA00025064

=== Page 4 ===
Subject: Redactions: Government motion in limine
All,
Thanks for the call this afternoon, it was helpful to work through the mechanics of filing redactions this afternoon. As we
discussed, we're sending you versions of the following documents, with redactions applied: (1) the Government's motion
in limine, (2) the defendant's opposition, and (3) the Government's reply.
Please let us know if you would like us to add any redactions to these versions, and we'll get them filed. With respect to
Exhibits:
We are attaching a proposed redacted version of Government exhibit A.
Only defense exhibits E and G can be filed publicly without redactions.
All other defense exhibits to the defense opposition should be filed under seal.
Best,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00025065


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=== Page 1 ===
From:
To:
Subject: SDNY Non-Public Investigations and Matters for Transition
Date: Wed, 13 Jan 2021 15:15:10 +0000
Attachments: SDNY_Non-public_Investigations_(1.13.21).pdf
Attached please find SDNY's response to the transition team's request for significant, non-public matters. Please let us
know if you need anything else.
I
Chief Counsel
U.S. Attorney's Office for the Southern District of New York
One St. Andrew's Plaza, New York, New York 10007
Desk:
EFTA00026964


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=== Page 1 ===
From:
)"
To: "Chris R. Rodgers"
Jack Scarola
Cc:
)"
(USANYS)"
, Mary McCann
"Wendy P. Calvet"
Subject: RE:
- Discovery Responses
Date: Wed, 20 Jan 2021 03:03:39 +0000
Received, thank you.
From: Chris R. Rodgers
Sent: Tuesday, January 19, 2021 1:50 PM
To:
>; Jack Scarola
Cc:
is
(USANYS)
>;
>; Wendy P. Calvet
Subject: RE:
- Discovery Responses
Attached please find the Discovery Responses filed on
behalf in her civil matter against Epstein.
| Privileged and Confidential | 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
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EFTA00024996


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=== Page 1 ===
From:
To:
Subject: Travel Authorization 10808018 approved by
, now awaiting further
approval
Date: Thu, 07 Nov 2019 14:05:14 +0000
Importance: Normal
Dear
Travel authorization 10808018 has been approved by
, now awaiting further approval.
Trip ID: 10808018
Traveler name:
Purpose: R20NYS13180 - U.S. V. Epstein (2018R01618) - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
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Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00025375


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=== Page 1 ===
From: Gloria Allred
To:
)"
)"
Cc:
)"
N. (NY) (FBI)"
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of
Epstein. She is willing to fly to New York for the victim meeting on Oct. 23. May I call you
at 5:45 P.M. to discuss ?
Date: Mon, 21 Oct 2019 16:01:22 +0000
Inline-Images: image001.jpg; image002.png; image003.jpg; image004.png
I believe we arranged travel for her on Friday. I will get back to you in a few hours to confirm.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
ALLRED. MAROKO & GOLDBERG
2019
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer
for
2019
From:
Sent: Monday, October 21, 2019 6:40 AM
To: Gloria Allred
is
Cc:
is
N. (NY) (FBI)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
We will make ourselves available to meet with your new client on 10/23. Because the victim meeting is being run by the
FBI, their victim services folks are handling travel logistics. I'm cc'ing
who should be able to hopefully help
coordinate travel. Would you please provide
with your new client's name as it appears on her ID, date of birth,
email address, and phone number?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
EFTA00024292

=== Page 2 ===
New York, NY 10007
From: Gloria Allred
Sent: Friday, October 18, 2019 5:02 PM
To:
Cc:
Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
ALLRED. MAROKO & GOLDBERG
2019
Best Lawyers
Martindale-Hubbell
PREEMINENT
AV
Peer Rated for Highest Level
of of Professional Excellence
2019
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
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.
EFTA00024293


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=== 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 18:25:26 +0000
Thanks so much,
Hope you have a great holiday weekend too C
From:
Sent: Thursday, July 2, 2020 1:28 PM
To:
Subject: Fwd: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Great job
Happy Fourth, I hope you get a little time to relax over the weekend.
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 1:22:25 PM EDT
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
cid:image001.png@01D53E43.CA2BB290
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-
EFTA00024535

=== Page 2 ===
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, 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
EFTA00024536

=== Page 3 ===
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.
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
<U.S. V. Ghislaine Maxwell Indictment.pdf>
<Ghislaine Maxwell Indictment PR.pdf>
EFTA00024537

=== Page 4 ===
[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.
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From:
To:
Subject: RE: NPA
Date: Tue, 23 Feb 2021 19:04:50 +0000
Attachments: 2021-02-26_GM_Government_Opposition_(NPA)_(MC)_(AR).docx
Hi all,
My comments attached. I think we're in great shape too - we have a lot of convincing reasons her motion should be
denied.
I'm around to discuss anytime.
Thanks,
From:
Sent: Tuesday, February 23, 2021 12:54 PM
To:
is
;
Subject: RE: NPA
Thanks for the close read - can the three of us chat after
and
have also reviewed? Thanks.
From:
Sent: Tuesday, February 23, 2021 12:46 PM
To:
is
is
Subject: RE: NPA
Thanks very much,
I think this is in great shape and is very compelling. Some small edits and my responses to your
comments attached. Happy to jump on a call if that would be useful.
From:
Sent: Tuesday, February 23, 2021 2:02 AM
To:
is
is
Subject: NPA
All,
Attached is the most recent draft of the NPA brief. Apologies for the delay, I really struggled with this one. I think our
arguments in the first half are strong, but I'm really not wild about the second half. Would very much appreciate your
comments/edits. I've also flagged a few issues for consideration/discussion. If you're able to review tomorrow morning,
that would be great.
Thanks,
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Assistant United States Attorney
Southern District of New York
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From:
To:
Subject: RE: BRITISH TV REQUEST Important
Date: Mon, 08 Jun 2020 19:45:37 +0000
yes
From:
Sent: Monday, June 8, 2020 3:43 PM
To:
Cc:
Subject: Re: BRITISH TV REQUEST Important
Did the tweet go out?
On Jun 8, 2020, at 3:36 PM,
wrote:
Will do.
Sent from my iPhone
On Jun 8, 2020, at 3:35 PM,
wrote:
Please decline for me.
Begin forwarded message:
From: kathryn milofsky <kmilofsky@aol.com>
Date: June 8, 2020 at 3:32:35 PM EDT
To:
"
,
Subject: BRITISH TV REQUEST Important
Reply-To: kathryn milofsky <kmilofsky@aol.com>
Dear Mr
I am Kathryn Milofsky a producer for ITV News based in NY.We are the largest commercial channel in
the UK similar in style stature to NBC.
We would be honored to do an interview with you today via Skype for about 10 minutes about your
request to interview Prince Andrew re the investigation into Jeffrey Epstein. The recent MLA request.
The interview would air on our flagship News at Ten Broadcast which is watched by millions.
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ITV News is made by ITN, which has a global reputation as a provider of independent,
objective broadcast news. We are known for delivering powerful, authoritative
coverage which is free from any political ownership.
ITV News has the biggest reach of any commercial news provider in the UK and
broadcasts to 8 million viewers each day. We are the main commercial competition to
the BBC. Our recent interview with Meghan Markle had 44million views and millions
watched the interview on tv.
We are proud to be the network that best reaches the non-metropolitan elite in the UK. Online, the
ITV News Facebook and Twitter pages are now at 1.8m followers each and growing, with Facebook
views pulling in an average of 55m average per month, with 5m monthly video views on Twitter. The
ITV News website has an average of 30m page views each month.
I so hope you can do an interview with us.
Kind Regards
Kathryn Milofsky
Producer ITV News
646 240 5544
kmilofsky@aol.com
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=== Page 1 ===
Jeffrey Epstein
457 Madison Avenue
New York, NY 10022
Vicky Ward
Vanity Fair
4 Times Square
New York, NY 10036
Dear Ms. Ward,
Thank you for your letter of December 19th further documenting your
reporting style. First with respect to my house. If you recall you asked me
on numerous occasions, whether I had purchased #9 outright. You followed
up with a similar question to Mr.
on at least 2 occasions, I have told
you repeatedly that, yes, in fact I did purchase it outright and you tirelessly
repeated "then why were there no transfer taxes paid?" I explained in
writing that transfer taxes are in most instances not made public. After
sending you documentation on #9's transfer taxes, you then continued on
#11. Also in writing, I told Graydon that I never owned #11. Add that to
the fact that Graydon has told me that #11 is not part of the story and once
again, like a Gospel choir, you chant: "but what about the transfer taxes?"
Enclosed please find a copy of the transfer taxes paid, given to you off the
record, confirming that I was only a trustee and once again requiring me to
spend more time on questions whose relevance you have yet to describe.
In regard your question in your latest letter regarding refuting the
claims of
Why don't you detail those claims to me so that I
and the State Trooper can respond to any factual claims? I hope the copy of
this letter, also given to you off the record, will be given to Vanity Fair's
lawyers, who should at last understand there is cause for concern. I think
you will agree that the only quote "claim" that you describe to me was that
had felt "uncomfortable" and asked her father to immediately
come and get her. Are you now asking me to refute how
felt"? A typical tabloid-like question. Or are you asking me whether she
left? You certainly did not ask me who paid for her move or when or how
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did she leave. (I paid.) The facts and circumstances surrounding
behavior, attitude and actions which include hundreds of dollars of
unauthorized country club charges for massages, misrepresentations and
erratic outbursts are easily verified by the former State Trooper, a highly
reputable source, who lived on the property the entire time
was in
residence. The trooper is a witness to what occurred during his stay in Ohio.
He could testify to what he saw, but certainly cannot testify to what she felt.
You have, at least until today, made no attempt whatsoever to contact this
person that I made known to Graydon in writing, who will attest to these
incidents and more. I can only believe the reason you have not is that
knowing his version would contradict your article. In addition, you have
already seen the letter
sent after she left Ohio suggesting the idea of
repaying her theft with paintings. Please find printouts of my message sheet
from July 1996. Specifically it refers to
message confirming
massage at the country club and the fact that she did not
immediately leave Ohio. You will also find country club bills detailing her
financial misdeeds. With respect to
, you will recall that you
specifically told me that there had been no allegations with respect
I
was shocked then, to say the least, when the fact checker then faxed
Ghislaine with the allegations regarding
, in a fax dated only last
Friday. You must admit that you had made no mention of this at any
previous time. I have already sent documentation from
comprising a postcard written from Thailand after her ranch visit confirming
her hardly disturbed attitude. Enclosed please find additional
correspondence from
and
who helped her research student
programs after her ranch visit. These are also given to you off the record.
I would like to point out to you that your statement the quotes were
read to me in context, could be best exemplified by your question, "have you
ever upgraded your friends to first class and why?" The context as you put it
was only made clear when Erin Gladney faxed me the question: "we are also
wondering if at any time you put upgrade stickers on airline tickets for any
employees or friends of yours, if so can you explain how they work". Not
exactly a quote read to me in context is it? If you truly believe that my
quotes were read to me in context, I see no reason why you would not now
send them to me in writing.
Please pay me the minimum courtesy and deny to me in writing the
fact, or as you wrote it, the allegation contained in my letter to Graydon, the
fact that on numerous occasions you have tirelessly repeated the sentence: "I
am only a journalist hired by my editor to do a story and then required to
publish what I hear". I am sure you now understand that this sentence
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denigrates both you, your magazine and your profession. So if you did not
on numerous occasions repeat this sentence to me I will accept your denial
in writing.
Last, is the sentence in your letter that illustrates the lack of care and
inattention to detail that you have so consistently portrayed. I know you can
do better. You state that you "have simply been investigating these matters
with people with knowledgeable sources". I am unqualified to comment on
the sentence's grammar, but can only assume this will in future allow you to
fall back on the idea that the inaccuracies and negligence weren't yours, they
weren't even your sources, they could only be attributable to the lack of care
of the so called people whose own sources must have misled them. For the
record, I would also suggest to you that you repeatedly gave me inaccurate
accounts of your deadline to, I believe, give me the false impression that
time did not allow me to adequately research and respond.
Sincerely,
Jeffrey Epstein
P.S. In one of your last calls you referred to Michael Stroll as one of my
clients. This was never true.
Reminder, this letter with its enclosures are all given to you off the record as
it's sole purpose is to correct inaccuracies in your story.
Dictated but not read
Enclosure: 7 pages
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On the basis of what I provided you off the record, you now understand that
alleged feelings of uncomfortablness grew out of her own
financial misdeeds. It is impossible to accurately tell this story without
including these financial facts that would be deeply embarrassing to
However if you choose to include this highly subjective and undocumented
material relating to her feelings you would have an obligation to tell the
whole story including her financial misdeeds based on her own admissions,
so long as you can do so without attributing the documents to me
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