# docs_fts_content

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=== Page 1 ===
From:
"
To:
"
Subject:
Date: Mon, 08 Jul 2019 22:19:34 +0000
Importance: Normal
Attachments: Epstein_Proposed_Press_Remarks_v3_large).docx
EFTA00028314


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From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Officers watching Epstein were on overtime due to jail staffing shortage, union president says
Date: Mon, 12 Aug 2019 01:52:32 +0000
Yup, in our outline
From:
(USANYS)
Sent: Sunday, August 11, 2019 9:38 PM
To:
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
Subject: Officers watching Epstein were on overtime due to jail staffing shortage, union president says
You may want to ask the Warden about this issue at least generally tomorrow.
https://www.washingtonpost.com/national-security/it-was-inevitable-officers-watching-epstein-were-on-
overtime-due-to-jail-staffing-shortage-union-president-says/2019/08/11/2b611404-bc5e-11e9-a5c6-
1e74f7ec4a93_story.html
Sent from my iPhone
EFTA00027266


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=== Page 1 ===
From:
To:
Subject: RE: Maxwell info
Date: Thu, 16 Jul 2020 18:05:12 +0000
Thanks very much
From:
Sent: Thursday, July 16, 2020 13:41
To:
Subject: FW: Maxwell info
For you.
From: Parry, Emma <emma.parry@thesun.co.uk>
Sent: Thursday, July 16, 2020 1:26 PM
To:
Subject: Maxwell info
Hi
I'm not sure if you are the right person to speak to so please redirect this email if necessary.
I am a reporter at The Sun and I recently did an interview with a source who has a lot of information about
Ghislaine Maxwell and Jeffrey Epstein. He is currently in prison but has cooperated on other cases with ATF and
now wants to cooperate with authorities on the Maxwell case. I believe he is credible.
He named many names to me which we didn't publish but he is happy to share with investigators.
https://www.thesun.co.uk/news/12091701/epstein-maxwell-people-sex-under-age-girls/
He has asked me to reach out to help facilitate this.
Can you help? Or advise on how I should proceed?
Thanks
Emma
Emma Parry
Digital US Correspondent, The Sun
646 544 6515
www.the-sun.com
"Please consider the environment before printing this e-mail"
This e-mail and any attachments are confidential, may be
legally privileged and are the property of News Corp UK & Ireland
Limited on whose systems they were generated. News Corp UK
& Ireland Limited is the holding company for the News UK group,
EFTA00028775

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EFTA00028776


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: US V Epstein
Date: Sat, 17 Aug 2019 18:08:48 +0000
FYI below, re: probating the estate. Based on a quick search I don't see any place where a probate petition would be
publicly filed, though entirely possible it's somewhere I couldn't find.
From: Martin G. Weinberg
>
Sent: Friday, August 16, 2019 08:30
To:
>;
>;
>; '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.
20 Park Plaza
Suite 1000
Boston, MA 02116
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.
EFTA00027176


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=== Page 1 ===
THE OTTY OF NEW YOUR
Office of Chief Medical Examiner
520 First Avenue, New York New York, 10016
OFFICE OF CRIBE
Evidence Department
Evidence Receipt
EU #:
19-28287
Subject(s) : M19-019432: Epstein, Jeffery(Decedent)
FB #:
Evidence Type: EU General
Voucher #:
Security Envelope :
# Package:
2 bags
Narcotic Envelope:
Item #
Qty
Desc
001
1
bedding
002
1
clothing
From:
To:
Date and Time
Badge
Sign
Detective
y
y
8/12/19 11:56 AM
6982
Monday 12 August 2019
Page 1 of 1
EFTA00027965


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=== Page 1 ===
From:
Cc:
Bec:
Subject: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL, TUESDAY, NOVEMBER
23, 2021
Date: Tue, 23 Nov 2021 13:24:13 +0000
Importance: High
Attachments: 2021.11.01_Pseudonym_ruling_from_Transcript.pdf
2021.11.10_Pseudonym_logistics_order.pdf,2 2021.11.18_Maxwell_- -
_Sketch_Artist_Order.pdf
Inline-Images: image001.png
In order meet the demand for the high volume of media requests we are already receiving, the following
guidance is being provided in advance of the trial to ensure efficient communications. Please take careful note.
UNITED QUI ORO DOMINA JUSTITIA OF JISTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
PRESS GUIDANCE
Tuesday, November 23, 2021
*OFF-THE-RECORD, AND FOR GUIDANCE ONLY: Several of the government's anticipated witnesses
will be testifying in this trial using a pseudonym or first name. The Court granted a Government motion
[attached] requesting that they be able to do so, because the victim witnesses are expected to describe alleged
sensitive, explicit and personal events concerning illegal sexual abuse, sexual contact and other acts of which
they have been victims. I believe most, if not all, news media outlets have a policy against identifying sex
crime victims without their consent, and urge you to abide by that policy with our witnesses and respect their
privacy.
9:30 a.m. - Final pretrial conference U.S. V. Ghislaine Maxwell - the defendant is charged in connection to
conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity - before Judge
Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood
Marshall U.S. Courthouse]).
EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share. If you are unable
to access this link to the file share (USAFx), you must establish an account to access the files. To establish an
EFTA00029582

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account, request access by email to me or my colleague, Jim Margolin, Cc'd here, prior to Wednesday,
November 29, 2021.
Please also note that all case filings in U.S. V. Maxwell are available in the Court's electronic filing system; we
encourage media representatives to establish a free PACER account, if they have not done so already.
Credentialing and other matters relating to in-person attendance for the trial are handled by the SDNY District
Executive's Office.
Periodic updates to follow.
Follow us on Facebook I Follow us on Twitter | SDNY website | YouTube
*** FOR PLANNING PURPOSES ONLY ***
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS
OFFICE AT (212) 637-2600.
EFTA00029583


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=== Page 1 ===
From:
"
To:
Subject: Re: Epstein attys
Date: Mon, 08 Jul 2019 17:04:17 +0000
Importance: Normal
Interesting choices
On Jul 8, 2019, at 12:53 PM,
wrote:
http://www.martinweinberglaw.com/
https://www.steptoe.com/en/lawyers/reid-weingarten.html
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00028313


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=== Page 1 ===
From:
To:
Cc:
Subject: Meet Jeffrey Epstein's gang of accused slave 'recruiters'
Date: Sun, 11 Aug 2019 13:01:54 +0000
This article says "A source told The Post that Maxwell is cooperating."
https://nypost.com/2019/08/10/meet-jeffrey-epsteins-gang-of-accused-slave-recruiters/
Sent from my iPhone
EFTA00027261


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From:
(NY) (OGA)"
To:
(USANYS)"
Subject: FW:
Date: Tue, 14 Jul 2020 20:31:34 +0000
I'm available
-
On Jul 14, 2020 4:12 PM,
(USANYS)"
wrote:
Hi
,
Hope all is well. Are you available for a quick call regarding this 302? Trying to run down how Lt.
got the number
for
Thanks in advance!
Original Message
From:
(NY) (FBI)
Sent: Tuesday, July 14, 2020 2:51 PM
To:
USANYS)
Subject:
Hey
When looking through my case file, this is where Mike documented the phone number and last call made by Epstein. Let
me know if you need anything else
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00028772


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From:
)"
To:
(NY) (FBI)"
Cc:
)"
Subject:
Date: Tue, 25 Feb 2020 20:24:08 +0000
Hi
I just spoke with
attorney (Jack Scarola), following up on our requests to interview her. Her attorney
thought she might want to reach out to our team directly, and asked for a number, so I've given him your contact
information, in case she wants to call our team directly. Just wanted to give you a heads up that there's a small chance
you'll hear from her.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00027345


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Draft SW for JE phone & ipad
Date: Sun, 14 Jul 2019 17:22:17 +0000
Importance: Normal
Sorry, disregard.
reminded me we want to include some additional items in this warrant. Will revise and resend.
From:
)
Sent: Sunday, July 14, 2019 1:18 PM
To:
^
>;
Cc:
Subject: Draft SW for JE phone & ipad
and
Attached for review is a draft search warrant application for the phone and ipad that were seized from Epstein on the day
of his arrest. Happy to discuss.
Thanks,
EFTA00029016


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From:
To:
Cc:
Subject: Re: Draft Statement
Date: Wed, 11 Nov 2020 17:19:00 +0000
Thanks very much for sending. Our team has reviewed your draft and is prepared to go forward with the call at
12:30pm today.
Best,
On Nov 11, 2020, at 12:08 PM,
wrote:
All:
We want to give you a draft of our suggested changes (attached) before our conversation this afternoon. We realize the
time is short before our scheduled call, so if you do not have sufficient time to review it in advance of our call, we are
happy to push the time for our call back until after you have had a chance to review it.
We have tried to work within the framework you provided. There are some allegations which we do not believe are
accurate. Given the long passage of time, however, we understand that there might be different recollections about
what occurred. We have tried to set forth both views of what occurred. We understand that you do not want a Fatico
hearing and are willing to agree that we will not ask for a Fatico hearing to attempt to resolve the different recollections.
With respect to the specific allegations abou
being present during massages when girls were sexually assaulted,
does not believe she was ever present during any of these incidents and believes that the girls misremember the
circumstances. We note that these events occurred a long time ago and were emotionally charged, a circumstance
which can cause people to have faulty memories.
Indeed, we think that some of the evidence seems to contradict the victim's claims that
was present when they, as
minors, were sexually molested by Epstein.
Specifically, based on allegations in a lawsuit, one of the victims referred to in the statement of facts states that she was
abused on Epstein's ranch when she was a minor and that
was present. But flight logs reflect that the first time
that the victim was on a flight to or from the ranch where she states the abuse occurred was in April 2003, after the
victim was 18 years old. Moreover, the victim's attorney has also stated that a photo of the victim and Epstein in which
the victim is smiling, taken in December 2002, was taken before the victim knew that Epstein would sexually abuse her.
This appears to contradict the victim's allegation that in the summer of 2002 she was flown to the ranch and abused by
Epstein in the presence of
To be clear, we are not asserting that this victim is lying about Epstein abusing her. Our point is simply that this occurred
18 years ago and that she appears to be confused about the timing of events and who was present.
Another victim claims that that
walked in on an incident where the victim was performing oral sex on Epstein in
his New York townhouse. This victim has named
as a defendant in her civil suit and has alleged that this incident
occurred in 2005. During this time period,
worked out of Maxwell's home and spent little time in Epstein's
townhouse. Staff, including
were never allowed to roam the halls or go into private areas of Epstein's Manhattan
home unless they were summoned there.
never walked in on someone when that person was giving Epstein oral
sex and believes that this victim must be confusing her with someone else.
does not doubt that Epstein abused these women, as he did with almost all young women and girls he came into
contact with, but the available evidence does not support the assertion that
was present for or witnessed any
EFTA00028120

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sexual abuse of these victims while they were minors. Accordingly, we do not object to allowing these women telling
their stories but we cannot agree that the allegations in their stories concerning
are correct.
Let us know what would work best for a call.
Thanks,
<2020.10.11 Defense edited SOF.docx>
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From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10982117 approved by
now awaiting further
approval
Date: Tue, 28 Jan 2020 20:12:01 +0000
Importance: Normal
Dear
Travel authorization 10982117 has been approved by
, now awaiting further approval.
Trip ID: 10982117
Traveler name:
Purpose: R20NYS13342 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-08
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/
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
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
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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.
EFTA00027841


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=== Page 1 ===
From:
To:
Subject: RE: Agenda
Date: Mon, 07 Dec 2020 16:40:11 +0000
Hi all checking in on this, I've highlighted tasks that are completed or in motion. Let me know if I've missed anything.
None of this is time-sensitive, I'm mostly just checking in to stay organized, so no rush on anything.
Relativity review of GM emails:
o Team will split a batch review as a shared project, which will commence after we complete all Relativity
review for discovery purposes.
Identify an Interlochen employee (likely retired) who managed donor relations with Epstein/can authenticate
documents
O Records custodian for student files can be dealt with closer to trial.
o
will contact counsel to begin discussing, and to follow up on our last conversation about records.
(Within two weeks)
Identify a PBPD detective who can authenticate items recovered from search of PB house
o
will handle outreach to PBPD (within one month)
Talk to
to make sure
has searched all her emails for relevant communications
O
will handle and give a heads up they will contact her mother (within two weeks)
Potentially interview
client
o
will review Relativity and set up interview (two weeks)
Potentially re-interview
0 Team will review 302 and schedule follow-up interview
o
will contact
regarding an interview (within two weeks)
Meet with
o Discuss with chiefs tomorrow re: superseder timing
Interview
o Ask agents to contact and interview him
(
- within 2 weeks)
Re-interview
(with counsel)
o Ask agents to contact him re: appointed counsel
(
-within two weeks)
Interview
o Talk to agents about an interview, not a high priority
(
Interview Jo Jo Fontanella
o
will contact his attorney re in person interview
Re-interview
O
will contact his attorney re in person interview in January
O
will review emails in Relativity
Interview
and
and other individuals on flights w/
o
will talk to agents about approaching them
Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including
(within one month)
O
:
o
O
Interview
mother
o
will ask agents to interview by phone
Investigate immigration records/travel records re:
EFTA00027433

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o
will take a look and work with agents
Interview
o
will call Sigrid about a potential interview
Review deposition transcripts for GM (keeping in mind
is approaching)
o
will send
reminder
Tip-line leads that
flagged
0
will flag for agents
From:
Sent: Wednesday, November 11, 2020 4:25 PM
To:
)
Subject: RE: Agenda
Here's the task list, based on our conversation:
Relativity review of GM emails:
0 Team will split a batch review as a shared project, which will commence after we complete all Relativity
review for discovery purposes.
Identify an Interlochen employee (likely retired) who managed donor relations with Epstein/can authenticate
documents
o Records custodian for student files can be dealt with closer to trial.
0
will contact counsel to begin discussing, and to follow up on our last conversation about records.
(Within two weeks)
Identify a PBPD detective who can authenticate items recovered from search of PB house
o
will handle outreach to PBPD (within one month)
Talk to
to make sure
has searched all her emails for relevant communications
o
will handle and give a heads up they will contact her mother (within two weeks)
Potentially interview
client
0
will review Relativity and set up interview (two weeks)
Potentially re-interview
Team will review 302 and schedule follow-up interview
o
will contact
regarding an interview (within two weeks)
Meet with
Discuss with chiefs tomorrow re: superseder timing
Interview
Ask agents to contact and interview him
(
- within 2 weeks)
Re-interview
(with counsel)
Ask agents to contact him re: appointed counsel
(
-within two weeks)
Interview
O Talk to agents about an interview, not a high priority
(
Interview Jo Jo Fontanella
O
will contact his attorney re in person interview
Re-interview
o
will contact his attorney re in person interview in January
o
will review emails in Relativity
Interview
and
and other individuals on flights w/
o
will talk to agents about approaching them
Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including
(within one month)
0
:
O
:
o
Interview
mother
0
will ask agents to interview by phone
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Investigate immigration records/travel records re:
o
will take a look and work with agents
Interview
o
will call Sigrid about a potential interview
Review deposition transcripts for GM (keeping in mind
is approaching)
o
will send
reminder
Tip-line leads that
flagged
o
will flag for agents
From:
Sent: Friday, November 6, 2020 2:12 PM
To:
>;
Subject: RE: Agenda
Thanks very much,
!
This all looks right to me and makes sense. If we are pushing this past Monday, I'd ask that it be
Wednesday afternoon, or anytime Thursday, please. I've got a lengthy grand jury presentation to make on Tuesday.
From:
Sent: Friday, November 6, 2020 2:09 PM
To:
is
Subject: Agenda
Team,
In preparation for our call (which we can reschedule to a time following the discovery deadline), I wanted to send around
a list of topics to discuss for potential next steps. I'm sure I've missed some items, but this is a starting point at a least.
For context, I think we currently expect to call at least the following witnesses at trial:
*Records custodian from Interlochen
*Records custodian from the Professional Children's School
*Court reporter(s) from GM depositions
*We haven't identified/spoken to these witnesses yet, so that's on the trial prep to-do list as well.
The following are some potential next steps - either individuals to interview or re-interview, records to search for/identify,
and so forth.
Relativity review of GM emails
Identify an Interlochen employee (likely retired) who managed donor relations with Epstein/can authenticate
documents
Identify a PBPD detective who can authenticate items recovered from search of PB house
Talk to
to make sure
has searched all her emails for relevant communications
Potentially interview
client
Potentially re-interview
Meet with
Interview
Interview
Interview Jo Jo Fontanella
Re-interview
EFTA00027435

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Interview
and
Review victim interview notes and interview any outcry witnesses we haven't spoken to yet, including
Interview
mother
Investigate immigration records/travel records re:
Re-interview
(with counsel)
Interview
Review deposition transcripts for GM (keeping in mind
is approaching)
Tip-line leads that
flagged
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00027436


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=== Page 1 ===
From:
To: Sigrid McCawley
Cc:
Subject: Local Criminal Rule 23.1
Date: Mon, 02 Aug 2021 15:08:56 +0000
Attachments: 2021.07.30_Order_Regarding_Local_Rule_23.1.pdf
Hi David and Sigrid,
We wanted to let you know about a recent order from Judge Nathan regarding Local Criminal Rule 23.1, which applies not
only to counsel of record in a criminal case, but also to attorneys associated with a case, such as attorneys for witnesses.
The order is attached, and the full text version of the local SDNY rules can be found on the court's website. If you have
any questions about the rule or the order, please let us know.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00027394


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: FW: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Fri, 15 Oct 2021 00:30:33 +0000
Attachments: Ltr_to_Ct_re_Legal_Mail_10-14-21.pdf
FYI, letter filed by Bobbi Sternheim tonight.
From: BOBBI C STERNHEIM
Sent: Thursday, October 14, 2021 7:46 PM
To:
>;
(USANYS)
i
is
Cc: Christian Everdell
>; Laura Menninger
>; Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good evening-
Attached is a courtesy copy of this evening's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
New York, NY 10007
Main:
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.
EFTA00029301


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=== Page 1 ===
From: Alex Conlon
@kaplanhecker.com>
To:
)"
Subject: Fwd: Epstein
Date: Sat, 10 Aug 2019 14:09:09 +0000
Hadn't gotten to connect with my colleagues yet but realizing I should have asked about the forfeiture issue. If you
have time to talk later today about this, let me know.
Thanks,
Get Outlook for iOS
From: Jenna Dabbs
@kaplanhecker.com>
Sent: Saturday, August 10, 2019 9:50:11 AM
To:
is
Cc: Alex Conlon
@kaplanhecker.com>
Subject: Epstein
We were certainly saddened to see the news this morning, as I know all of you were. I appreciate that you have more
pressing issues to deal with at the moment, but we are interested in whether you expect any aspect of the SDNY's
investigation/case to continue, potentially a separate civil forfeiture proceeding, or possible criminal prosecutions against
other defendants. We also understand that you may not be in a position to tell us anything at the moment, which is fine.
Just anticipating and preparing for questions we expect to be asked. Separately, having had the experience of a defendant in
a case I charged commit suicide, I wanted to add that it can be a complicated feeling, and to the extent it is helpful, I think
you brought a really important case and conducted yourselves in a professional, compassionate and impressive way. So
despite sad news, and frustrating news after putting so much work into filing a case and preparing to see it through, heads
should be held high.
Best,
Jenna
Jenna Dabbs Kaplan Hecker & Fink LLP
35° Fifth Avenue Suite 7110
New York New York 10118
(W)
EFTA00028541

=== Page 2 ===
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify the
sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00028542


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 19-2221 United States of America V. Epstein "Defective Document CURED"
Date: Mon, 05 Aug 2019 19:18:15 +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 08/05/2019
Case Name:
United States of America V. Epstein
Case Number: 19-2221
Docket Text:
CURED DEFECTIVE NOTICE OF ADDITIONAL COUNSEL [12], [13], on behalf of Appellant Jeffrey
Epstein, FILED.[2624392] [19-2221]
Notice will be electronically mailed to:
Reid Weingarten, -: rweingarten@steptoe.com, ehartman@steptoe.com, ocorn@steptoe.com
Notice will be stored in the notice cart for:
Quality Control 1
EFTA00028078


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=== Page 1 ===
From:
"
To:
Cc:
Subject: Jimenez 302
Date: Tue, 03 Sep 2019 13:30:13 +0000
Importance: Normal
Attachments: Jimenez_302.pdf
Please see attached. We have no issues with this being produced to the defense, but do you have a protective order in
your case? Thanks.
Assistant United States Attorney
Southern District of New York
EFTA00029259


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Cc:
(USANYS)"
)"
Subject: Re: draft response to Epstein defense preservation requests
Date: Fri, 09 Aug 2019 17:25:34 +0000
Okay, thanks.
is signed off but we may have to chat briefly with
when he's back on Monday.
Sent from my iPhone
On Aug 9, 2019, at 1:21 PM,
)
wrote:
I'm totally available to update it this afternoon if there are edits today, but realistically I don't think the defense can
make much more hay about having gotten a response on the 9th versus the 12th
From:
(USANYS)
Sent: Friday, August 09, 2019 13:20
To:
Cc:
(USANYS)
>;
is
Subject: Re: draft response to Epstein defense preservation requests
If we don't get this out until Monday is that a problem?
Sent from my iPhone
On Aug 8, 2019, at 5:56 PM,
wrote:
No problem, thanks, and the edits were all straightforward. Updated version attached, everything incorporated, and
can go to
- I'm out of commission the next couple hours but back after that.
thanks,
From:
(USANYS)
Sent: Thursday, August 08, 2019 16:36
To:
)
is
(USANYS)
Cc:
is
)
Subject: RE: draft response to Epstein defense preservation requests
Sorry for the delay. Combined edits from both of us, attached. Can you take a look and clean up - we would then like
to give
at least the option of weighing in before we send to defense counsel.
From:
Sent: Thursday, August 8, 2019 11:44 AM
To:
(USANYS)
is
(USANYS)
EFTA00027919

=== Page 2 ===
Cc:
is
Subject: RE: draft response to Epstein defense preservation requests
Wanted to bump this from Tuesday, especially since I know you guys are out tomorrow - hopefully we can send it out
today? Happy to incorporate any edits etc. Thanks.
From:
Sent: Tuesday, August 06, 2019 15:01
To:
(USANYS)
>;
(USANYS)
Cc:
in
Subject: RE: draft response to Epstein defense preservation requests
This has been in the works for a little while, due to various other things that have come up in the interim, but we
didn't want it to get lost given the discovery motion schedule. The attached is based on our conversations with
including his email with suggested language for the prefatory language, and responds to the two attached defense
letters. Happy to discuss anytime and to incorporate comments and suggestions.
thanks,
Assistant U.S. Attorney
Southern District of New York
<2019-08-08, JE, letter to defense re preservation requests.docx>
EFTA00027920


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=== Page 1 ===
From:
"
(USANYS)"
To:
(OIG)"
Cc:
,
(USANYS)"
Subject: FW: Subpoena
Date: Tue, 20 Aug 2019 15:28:45 +0000
Attachments: 2019.08.20._MCC_Subpoena.pdf
FYI.
From:
(USANYS)
Sent: Tuesday, August 20, 2019 11:28 AM
To:
is
Cc:
(USANYS)
Subject: Subpoena
and
Please see attached.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00027940


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=== Page 1 ===
From:
To:
Subject: Epstein Account Documents
Date: Mon, 04 Oct 2021 12:26:53 +0000
Attachments: JEJE_Account_Docs.pdf; Jeffery_Epstein_Account_Docs.pdf; Hyperion_Account_Docs.pdf
As a follow up to our conversation regarding Epstein accounts where Ghislaine Maxwell was a signer on the account, I
have compiled the attached documents for your review.
If you have any question, please contact me.
Best
Forensic Accountant
FBI New York Field Office
EFTA00029200


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=== Page 1 ===
From:
)"
To:
)
[Contractor]"
Subject: Letter to mail out
Date: Tue, 22 Oct 2019 20:06:55 +0000
Attachments: 2019-10-22,_letter_to_TD_Bank.pdf
Hi
Any chance you could please mail a copy of the attached letter (re the Epstein case) to the recipient listed at the top?
Thanks!
EFTA00028832


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re: MCC/Epstein - Prior 1001 Prosecution
Date: Fri, 16 Aug 2019 00:51:57 +0000
Nah, I get it. I've been replaced. You and
are besties now.
On Aug 15, 2019, at 8:37 PM,
(USANYS)
wrote:
FYI - I asked
if he wanted me to send him the cases, which he could send along, but he said I should just copy
him.
From:
(USANYS)
Sent: Thursday, August 15, 2019 8:36 PM
To:
Cc:
(USANYS)
is
(USANYS)
Subject: MCC/Epstein - Prior 1001 Prosecution
Following up on our conversation from earlier today, please find attached the charging instruments from the Northern
District of Texas case that we referenced. I'm also attaching the Fifth Circuit's opinion affirming the conviction in that
case. Please let us know if you have any questions. Thank you.
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
Tel:
EFTA00027153


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS) [Contractor]"
)"
Cc:
)"
(USANYS)"
Bec:
Subject: RE: Help with Epstein Privilege Review
Date: Wed, 28 Oct 2020 13:30:11 +0000
Embedded: RE:_Help_with_Epstein_Privilege_Review.msg
Sender:
Subject: RE: Help with Epstein Privilege Review
Message-Id:
<DM3P110MB057099A657359F206BFEFBA98F170@DM3P110MB0570.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
Cc:
Cc:
EFTA00028757


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=== Page 1 ===
From:
]"
To:
)"
(USANYS)"
Cc:
)"
Subject: RE: 3500 production
Date: Wed, 10 Nov 2021 00:09:39 +0000
Attachments: U.S._v_Ghislaine_Maxwell_3500_Index_(Internal).xlsx;_3502-039.pdf
Hi team - I've added and stamped
notes from today (see attached). The TW Production
and NTW Production 7
are up to date, and the updated index is also attached (and also saved here). Everything is ready for your review. Should
these productions go out tonight? Thanks so much!
From:
Sent: Tuesday, November 9, 2021 12:49 PM
To:
>;
(USANYS)
>;
Cc:
in
Subject: RE: 3500 production
Thanks,
!
I've added the notes to
originals and witness folders, and I've stamped it as part of the latest
pending production of 3500 here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\!Trial\3500\1
Testifying\Production 3527 Visoski, Larry.
Thanks!
From:
Sent: Tuesday, November 9, 2021 12:26 PM
To:
is
(USANYS)
;
Cc:
>;
)
Subject: RE: 3500 production
Thanks so much,
!
Attached is the first bit of TW 3500 from me for today. Would you please save this in
folders?
From:
Sent: Tuesday, November 9, 2021 12:25 PM
To:
(USANYS)
i
Cc:
is
is
Subject: RE: 3500 production
Hi team - the latest 3500 (TW Production and NTW 3500 Production 7) are organized and stamped on the shared.
I
know there will likely be additional 3500 to add today, and I will add those materials when I receive them. The current
index is also attached for your reference. Thanks!
EFTA00029576

=== Page 2 ===
From:
(USANYS)
Sent: Tuesday, November 9, 2021 10:25 AM
To:
is
Cc:
is
is
Subject: 3500 production
Because of the Daubert hearing tomorrow, we should get another production of 3500 out later today. Can you work on
getting that organized, please? I expect we will have more notes from our meetings today.
Than
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00029577


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: RE:
Date: Wed, 21 Aug 2019 21:28:26 +0000
Okay, thanks.
From:
Sent: Wednesday, August 21, 2019 4:58 PM
To:
(USANYS)
Subject: FW: RE:
FYI
From:
Sent: Wednesday, August 21, 2019 16:57
To: Brown, Jeffrey
Subject: RE: RE:
Jeff,
The reference to not seeking a response from Governor Richardson at this time about current allegations is correct, and I
believe accurately conveys what I said on the phone. What I think remains inaccurate is the statement that I said he was
neither a target, subject, or witness in the case - in response to your question about his status, what I said was that in the
general sense, anyone who we don't have reason to know has no exposure (witness), or believe does have exposure
(target), would be a subject, and that specifically with respect to Governor Richardson, we do not currently intend to
subpoena or request to speak with him based on our investigation at this time. That's directly from my contemporaneous
notes. I think you could reasonably infer from my description that we don't currently consider him a witness or target,
but I don't think it's accurate to infer or interpret from my description on Sunday of the three categories that Governor
Richardson is in none of them. If you had asked me to specifically place Governor Richardson in one of those categories,
separate from a general description, I would have, and if that would be useful now, I can; similarly, if it would be useful for
me to give you our specific view on just whether he is currently a target, I can do that.
With respect to the quote, I don't have a view on anyone expressing their own personal inferences, and I recognize the
revision that limits the view to this particular moment in the investigation; that said, I expect that if asked whether the
Office in fact does believe at this time that the Governor did not participate in or witness the alleged criminal activity by
Jeffrey Epstein, we likely would simply say that the investigation is ongoing and we are pursuing all possible leads.
I hope this is useful.
thanks,
From: Brown, Jeffrey
Sent: Wednesday, August 21, 2019 13:20
To:
Subject: Re: RE:
EFTA00027244

=== Page 2 ===
Governor Bill Richardson offered his assistance in the Jeffrey Epstein investigation through his lawyer, Jeff
Brown of Dechert LLP, to the US Attorney for the Southern District of New York. In response to this offer, Mr.
Brown was informed by the Assistant US Attorney responsible for the case that Governor Richardson is neither
a target, subject, nor witness in the case and that there is no allegation against Governor Richardson about
which the government is seeking a response from Gov. Richardson at this time.
"It's fair to conclude that the federal prosecutors investigating this matter do not believe at this time the
Governor participated in or witnessed the criminal activity Jeffrey Epstein is alleged to have committed," said
Mr. Brown.
Furthermore, Governor Richardson has never been contacted by any party to a lawsuit involving Epstein, nor
by any law enforcement investigating Epstein. Governor Richardson hopes that the investigation continues so
that Epstein's victims can finally have their day in court and see the justice they deserve.
Jeffrey Brown
Dechert LLP
1095 Avenue of the Americas
New York, New York 10036
Direct:
Fax:
On Aug 21, 2019, at 1:12 PM,
)
wrote:
Hey no attachment, please re-send? Thanks.
From: Brown, Jeffrey
Sent: Wednesday, August 21, 2019 13:00
To:
Subject:
is this the edit you are looking for? I apologize again for this.
Jeffrey Brown
Dechert LLP
1095 Avenue of the Americas
New York, New York 10036
Direct:
Fax:
This e-mail is from Dechert LLP, a law firm, and may contain information that is confidential or privileged. If
you are not the intended recipient, do not read, copy or distribute the e-mail or any attachments. Instead, please
notify the sender and delete the e-mail and any attachments. Thank you.
EFTA00027245

=== Page 3 ===
This e-mail is from Dechert LLP, a law firm, and may contain information that is confidential or privileged. If
you are not the intended recipient, do not read, copy or distribute the e-mail or any attachments. Instead, please
notify the sender and delete the e-mail and any attachments. Thank you.
EFTA00027246


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=== Page 1 ===
February 12, 2015
Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, P.L.
425 North Andrews Ave, Suite 2
Fort Lauderdale, FL 33301
Re:
/ File# 14-000107
To Whom it May Concern:
Please be advised that the historical employment records you are requesting, for the time
period of "1999-2001" are no longer available.
I can confirm that a
appears on a spreadsheet dated back to 2000 which
lists terminated employees for that time (year 2000). Unfortunately, I am unable to
confirm whether or not this is the same person due to the fact no other information is listed
such as a social security number, address, position, etc. The only information listed is a
first and last name.
Should you have any further questions, please feel free to contact me at
Sincerely,
Director of Human Resources
PALM BEACH, FLORIDA
1100 South Ocean Boulevard, Palm Beach, Florida 33480 (561) 832-2600 Fax (561) 832-2669
MAR-A-LAGO 0156
EFTA00029389


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject:
Date: Sat, 14 Dec 2019 02:51:42 +0000
Don't know if you caught this but one of the non/minor Epstein victims alleges that Jes Staley (reads in memo as
"Jess Daily") raped her during a massage. P. 31
Sent from my iPhone
EFTA00029358


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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 11, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are
stamped with control numbers SDNY_GM_02771981 through SDNY_GM_02771983.
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:
EFTA00027659

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02771981
SDNY GM 02771983
Amazon records
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,
United States Attorney
by:
s/
Assistant United States Attorneys
EFTA00027660


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: travel approval request
Date: Fri, 24 May 2019 18:57:06 +0000
Importance: Normal
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
EFTA00028673

=== Page 2 ===
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00028674


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From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Revised MILs and letters
Date: Mon, 18 Oct 2021 20:36:02 +0000
OK will do.
From:
(USANYS)
Sent: Monday, October 18, 2021 4:35 PM
To:
(USANYS)
Subject: RE: Revised MILs and letters
Go ahead - I'm not in them. I didn't have comments. And agree with the below.
From:
(USANYS)
Sent: Monday, October 18, 2021 4:34 PM
To:
(USANYS)
Subject: RE: Revised MILs and letters
Here are a few comments on the motion. I looked at the two letters also, and have one suggestion on each (I'm happy to
propose language in redline, but you may be in the docs)
1. On the "key" letter - would it be possible to include a sentence on
pointing to Judge Nathan to whatever
the article(s) in which she has made comments about Epstein that are far more limited than what she will say in
court?
2. On the sealing letter - I think we should add a sentence explaining why we think the claim of Maxwell abuse will
cause prejudicial publicity. Namely, to air that issue in a public filing when there may well be no good faith basis for
it would potentially taint the jury pool.
From:
)
Sent: Monday, October 18, 2021 3:46 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
Subject: Revised MILs and letters
Hi
and
Attached for your review are:
1. Revised MILs
2. A redline
3. A draft cover letter
4. A draft index letter with victim information
Thanks!
Assistant United States Attorney
Southern District of New York
EFTA00027701

=== Page 2 ===
New York, New York 10007
EFTA00027702


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=== Page 1 ===
From:
To:
)"
)"
(USANYS)"
Subject: RE: Daubert motion
Date: Mon, 08 Nov 2021 04:25:54 +0000
Attachments: Motion_to_preclude_Dietz_and_Loftus_v5_-pm.docx
For whatever reason I convinced myself that version control would be easier if I put my comments in comment form
instead of in tracked changes, so here are a few nits (mostly catching my own errors). I will have the bandwidth to help
finalize tomorrow; will start by proofing and cite-checking the version that goes to the chiefs and then can help
incorporate any of their comments/do other revisions/etc.
From:
Sent: Sunday, November 7, 2021 11:20 PM
To:
)
is
(USANYS)
is
Subject: RE: Daubert motion
Here are one or two very small things. This looks great to me, and I defer to you guys on the bigger picture stuff, since
you're closer to the facts and the law here. Thanks so much for everyone's excellent work on this-really impressive stuff.
From:
)
Sent: Sunday, November 7, 2021 10:04 PM
To:
(USANYS)
is
Subject: RE: Daubert motion
Hi all,
Here's a version that incorporates the Loftus section. The plan is to have a draft in the chiefs' inbox when they wake up,
so if folks are still up, would love comments as you can.
I'm going to write the Rocchio section now, so that will come later
Thanks
From:
Sent: Sunday, November 7, 2021 8:00 PM
To:
>;
Subject: Daubert motion
Hi team,
In the interest of expediency, here is the Daubert motion for your comments. I still need to write my section, and I'm
doing some significant revisions to the Loftus section, but the Dietz section is done
crushed it. That's the bulk of
the motion, so feel free to read that over, and l'll send you the rest in a second round later.
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Thanks,
Assistant United States Attorney
Southern District of New York
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Subject: RE: Epstein FOIA
Date: Thu, 01 Jul 2021 15:14:43 +0000
Sounds good. Thanks,
From:
Sent: Thursday, July 1, 2021 11:14 AM
Subject: RE: Epstein FOIA
Yes, please. That'd be very helpful. Much appreciated,
From:
Sent: Thursday, July 1, 2021 11:08 AM
Subject: RE: Epstein FOIA
Thanks,
Yes, we will make the production tomorrow. We anticipate it will take the Times at least a few days to get
through it (although we don't know for sure on that front). We can let you know once we've released it tomorrow if that'd
be helpful.
From:
Sent: Thursday, July 1, 2021 11:06 AM
Subject: Epstein FOIA
Morning. Just for your awareness, I got a call regarding the FOIA litigation from one of our press counterparts at Main.
She asked if it would be okay to refer press inquiries to SDNY, I told her it wasn't a problem. Other than process
questions,
and I anticipate declining to comment anyway.
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Do we have a sense of timing as to when this will happen? (I was having a hard time hearing during the call, but my
impression was tomorrow and it would be voluminous and take the Times a while to get through?) Thanks.
Spokesman
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 1 of 12
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 3/22/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
Defendant Ghislaine Maxwell has been indicted by a grand jury on charges of conspiracy
to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. $ 371; enticing a
minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy
to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. $ 371; transporting
minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423 and 2; and two charges
of perjury, in violation of 18 U.S.C. $ 1623.
On July 14, 2020, the Court held a lengthy bail hearing and concluded that the Defendant
was a clear risk of flight and that no conditions or combination of conditions would ensure her
appearance. It therefore denied bail. On December 8, 2020, the Defendant filed a renewed
motion for release on bail pending trial, which was entered into the public docket on December
14, 2020. Dkt. No. 96. On December 28, 2020, the Court denied that motion, concluding that
the Defendant posed a risk of flight and that no combination of conditions could ensure her
appearance. Dkt. Nos. 104, 106.
The Defendant then filed a third motion for release on bail on February 23, 2021. Dkt.
No. 160. In this motion, the Defendant attempts to respond to the reasons that the Court
1
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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 2 of 12
provided in denying bail, proposing two additional conditions to the ones she proposed in her
second motion for bail. Specifically, she offers to renounce her French and British citizenship,
and she also proposes to have her and her spouse's assets placed in a new account that will be
monitored by a retired federal judge. See Dkt. No. 160 at 2.
As set forth below, the Court concludes that none of the Defendant's new arguments and
proposals disturb its conclusion that the Defendant poses a risk of flight and that there are no
combination of conditions that can reasonably assure her appearance. Thus, for substantially the
same reasons that the Court denied the Defendant's first and second motions for release, the
Court DENIES the Defendant's third motion for release on bail.
I.
Background
On July 14, 2020, this Court held a hearing regarding the Defendant's request for bail.
After a thorough consideration of all of the Defendant's arguments and of the factors set forth in
18 U.S.C. § 3142(g), the Court concluded that no conditions or combination of conditions could
reasonably assure the Defendant's appearance, determining as a result that the Defendant was a
flight risk and that detention without bail was warranted under 18 U.S.C. $ 3142(e)(1). The
Defendant has been incarcerated at the Metropolitan Detention Center since that time.
The Defendant renewed her motion for release on bail on December 8, 2020. The Court
again denied the Defendant's motion. In doing so, the Court explained that none of the
Defendant's new arguments materially impacted its conclusion that the Defendant posed a risk of
flight. It noted that the charges, which carry a presumption of detention, are serious and carry
lengthy terms of imprisonment if convicted; the evidence proffered by the Government,
including multiple corroborating and corroborated witnesses, remained strong; the Defendant's
substantial resources and foreign ties created considerable uncertainty and opportunities for
2
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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 3 of 12
escape; and that the Defendant's lack of candor regarding her family ties and financial situations
raised serious doubts as to her willingness to comply with any conditions imposed by the Court.
See Dkt. No. 106.
On February 23, 2021, the Defendant filed a third motion for release on bail. Dkt. No.
160 ("Def. Mot."). The Government opposed the Defendant's motion on March 9, 2021. Dkt.
No. 165 ("Gov't Opp'n"). The Defendant filed her reply under temporary seal on March 16,
2021.
II.
Legal Standard
The parties dispute whether the divestiture of jurisdiction rule precludes this Court from
granting the Defendant's third bail motion while Defendant's bail appeal is pending. See Gov't
Opp'n at 2-3; Reply at 2-3; see also United States V. Rodgers, 101 F.3d 247, 251 (2d Cir. 1996)
("As a general matter, 'the filing of a notice of appeal is an event of jurisdictional significance-
it confers jurisdiction on the court of appeals and divests the district court of its control over
those aspects of the case involved in the appeal.") (citation omitted). Under Rule 37(a) of the
Federal Rules of Criminal Procedure, however, the Court unquestionably has authority to defer
considering the motion, deny the motion, or state either that it would grant the motion if the court
of appeals remands for that purpose or that the motion raises a substantial issue. Fed. R. Crim. P.
37(a). Because the Court denies the Defendant's motion, it does not resolve the question of
whether it would have jurisdiction to grant it.
Pretrial detainees have a right to bail under the Eighth Amendment to the United States
Constitution and under the Bail Reform Act, 18 U.S.C. § 3141, et seq. The Bail Reform Act
requires that a court release a defendant "subject to the least restrictive further condition, or
combination of conditions, that [it] determines will reasonably assure the appearance of the
3
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person as required and the safety of any other person and the community." 18 U.S.C. $
3142(c)(1)(B). The Court may order that the defendant be held without bail only if, after
considering the factors set forth in 18 U.S.C. $ 3142(g), the Court concludes 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." 18 U.S.C. $ 3142(e)(1).
After a court has made an initial determination that no conditions of release can
reasonably assure the appearance of the Defendant as required, the Bail Reform Act allows the
Court to reopen the bail hearing if "information exists that was not known to the movant at the
time of the hearing and that has a material bearing on the issue" of whether pretrial detention is
warranted. 18 U.S.C. $ 3142(f). The Court is not required to do so if it determines that any new
information would not have a material bearing on the issue. See United States V. Raniere, No.
18-CR-2041 (NGG) (VMS), 2018 WL 6344202, at *2 n.7 (E.D.N.Y. Dec. 5, 2018) (noting that
"[a]s the court has already held one detention hearing, it need not hold another"); United States V.
Havens, 487 F. Supp. 2d 335, 339 (W.D.N.Y. 2007) (electing not to reopen a detention hearing
because the new information would not have changed the court's decision to detain the defendant
until trial). In addition, the Court may also revisit its own decision pursuant to its inherent
authority, even when the circumstances do not match $ 3142(f)'s statutory text. See, e.g., United
States V. Rowe, No. 02-CR-756 (LMM), 2003 WL 21196846, at *1 (S.D.N.Y. May 21, 2003)
(noting that "a release order may be reconsidered even where the evidence proffered on
reconsideration was known to the movant at the time of the original hearing."); United States V.
Petrov, No. 15-CR-66 (LTS), 2015 WL 11022886, at *3 (S.D.N.Y. Mar. 26, 2015) (noting the
"Court's inherent authority for reconsideration of the Court's previous bail decision").
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If, as here, there is probable cause to find that the defendant committed an offense
specifically enumerated in $ 3142(e)(3), a rebuttable presumption arises "that no condition or
combination of conditions will reasonably assure" the defendant's appearance or the safety of the
community or others. 18 U.S.C. $ 3142(e)(3). In such circumstances, "the defendant 'bears a
limited burden of production to rebut that presumption by coming forward with evidence that
he does not pose a danger to the community or a risk of flight." United States V. English, 629
F.3d 311, 319 (2d Cir. 2011) (quoting United States V. Mercedes, 254 F.3d 433, 436 (2d Cir.
2001)); see also United States V. Rodriguez, 950 F.2d 85, 88 (2d Cir. 1991) ("[A] defendant must
introduce some evidence contrary to the presumed fact in order to rebut the presumption.").
Nonetheless, "the government retains the ultimate burden of persuasion by clear and convincing
evidence that the defendant presents a danger to the community,' and 'by the lesser standard of a
preponderance of the evidence that the defendant presents a risk of flight." English, 629 F.3d at
319 (quoting Mercedes, 254 F.3d at 436); see also United States V. Martir, 782 F.2d 1141, 1144
(2d Cir. 1986) ("The government retains the burden of persuasion [in a presumption case].").
Even when "a defendant has met his burden of production," however, "the presumption favoring
detention does not disappear entirely, but remains a factor to be considered among those weighed
by the district court." United States V. Mattis, 963 F.3d 285, 290-91 (2d Cir. 2020).
III.
Discussion
The Defendant bases her third motion for bail on the Court's inherent powers to review
its own bail decisions, arguing that the new conditions she proposes warrant reconsideration of
the Court's earlier rulings. See Def. Mot. at 4. She also argues that the strength of the
Government's case is diminished in light of the arguments she advances in her pre-trial motions,
which are currently pending before the Court. Id. at 7. Having considered those arguments, the
5
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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 6 of 12
Court's view has not changed. The Court again concludes that the Government has shown by a
preponderance of the evidence that the Defendant presents a risk of flight and that there are no
set of conditions, including the Defendant's third set of proposed conditions, that are sufficient to
reasonably assure her appearance. The presumption in favor of detention, the weight of the
evidence, and the history and characteristics of the Defendant all continue to support that
conclusion. The Defendant's proposed conditions do not alter the Court's determination.
A. The Court's assessment of the 18 U.S.C. § 3142(g) factors has not changed
To begin with, the presumption in favor of detention continues to apply with equal force.
See Dkt. No. 106 ("Dec. Op.") at 7-8. And though the Court again concludes that the Defendant
has met her burden of production, the presumption "remains a factor to be considered among
those weighed by the district court." Mercedes, 254 F.3d at 436 (quoting Martir, 782 F.2d at
1144). The Court is mindful "that Congress has found that these offenders pose special risks of
flight, and that 'a strong probability arises' that no form of conditional release will be adequate
to secure their appearance." Martir, 782 F.2d at 1144 (citation omitted).
The Court's analysis of the 18 U.S.C. $ 3142(g) factors also remains unchanged.
Because the nature and circumstances of the offenses charged include crimes involving a minor
victim, the first 18 U.S.C. $ 3142(g) factor continues to weigh strongly in favor of detention.
And the Court remains of the opinion that the Defendant does not pose a danger to any person or
to the community. The fourth $ 3142(g) factor thus weighs against detention.
With respect to the second $ 3142(g) factor, none of the Defendant's new arguments alter
the Court's conclusion as to the weight of the evidence. The Defendant argues that the pre-trial
motions "raise serious legal issues that could result in dismissal of charges, if not the entire
indictment," and she contends that "[t]hese motions cast substantial doubt on the alleged strength
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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 7 of 12
of the government's case and warrant granting bail on the conditions proposed." Def. Mot. at 7.
Those motions became fully briefed one week ago and are now pending before this Court. The
Government strenuously contests each of the motions and the Court has not yet adjudicated
them. Without prejudging the merits of any of those pending motions and mindful of the
presumption of innocence, the Court remains of the view that in light of the proffered strength
and nature of the Government's case, the weight of the evidence supports detention. See Dec.
Op. at 9-10.
The Court's assessment of the Defendant's history and characteristics has not changed.
See Dec. Op. at 10-16. The Defendant continues to have substantial international ties, familial
and personal connections abroad, substantial financial resources, and experience evading
detection. Id. at 10-11. And the Court's concerns regarding the Defendant's lack of candor
regarding her assets when she was first arrested have also stayed the same. As the Court
emphasized in its denial of the second motion for release on bail, the discrepancies between the
information presented to the Court and to Pretrial Services in July 2020 and the information
presented to the Court in December 2020 raised significant concerns about candor. See Dec. Op.
at 16. There remains considerable doubt as to the Defendant's willingness to abide by any set of
conditions of release. Id. While there continue to be certain mitigating circumstances cutting in
the opposite direction, including the Defendant's family ties in the United States, these do not
overcome the weight of the considerations that lean in favor of continued detention.
As a result, none of the evidence or arguments presented in this third motion for bail alter
the Court's assessment of the 18 U.S.C. $ 3142(g) factors. While the fourth factor continues to
favor release, the first three factors and the presumption of detention all support the conclusion
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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 8 of 12
that the Defendant poses a significant risk of flight. Thus, the Court again concludes that there
are no conditions of release that will reasonably assure her appearance in future proceedings.
B. Pretrial detention continues to be warranted
The thrust of the Defendant's argument in her third motion for bail is that the two new
proposed conditions vitiate the Court's concerns regarding the risk of flight. The Defendant first
offers to renounce her French and British citizenship. Def. Mot. at 2. And she also proposes to
have most of her and her spouse's assets placed in a new account that will be monitored by a
retired federal judge, who would function as an asset monitor and will have co-signing authority
over the account. Id. Those conditions are offered in addition to the bail package she proposed
in December. See Dec. Op. at 16-17; see also Def. Mot. at 2. The new bail package does not
disturb the Court's conclusion that the Government has carried its burden of showing that these
conditions are insufficient to mitigate the flight risks, and the Court again determines that no set
of conditions-including the two new ones-can reasonably assure her future appearance.
The Court begins with the Defendant's offer to renounce her French and United Kingdom
citizenship. She notes that she can renounce her UK citizenship "immediately upon granting of
bail," and she informs the Court that "[t]he process of renouncing her French citizenship, while
not immediate, may be expedited." Def. Mot. at 4. As the Government notes, the offer is of
unclear validity, and the relevance and practical impact of the renunciations is, at best, unclear.
See Gov't Opp'n at 5. With respect to her offer to renounce her French citizenship, the Court is
again confronted with dueling opinions on the correct interpretation of French law. The
Government relies on the position of the head of the International Criminal Assistance Bureau of
the French Ministry of Justice, who argues that "the fact that the wanted individual is a French
national constitutes an insuperable obstacle to his/her removal," and that "[a]s long as said
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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 9 of 12
nationality is assessed at the time the offense was committed, any loss of nationality subsequent
to said offense has no bearing upon the removal proceedings and shall not supersede said
assessment of nationality." Gov't Opp'n, Ex. A at 2. The Defendant, meanwhile, relies on the
opinion of a French legal expert who argues that nationality is assessed at the time of the
extradition request. See Reply, Ex. A 1 11. The Defendant's expert concedes that there is no
case law addressing this precise issue. Id. 1 21.
Exacerbating the uncertainty is the fact that the relevant legal materials also lend
themselves to multiple interpretations. For instance, Article 3(1) the Extradition Treaty between
the United States and France of April 23, 1996 provides that "[t]here is no obligation upon the
Requested State to grant the extradition of a person who is a national of the Requested State, but
the executive authority of the United States shall have the power to surrender a national of the
United States if, in its discretion, it deems it proper to do so. The nationality of the person
sought shall be the nationality of that person at the time the offense was committed." See Reply,
Ex. A 9 (emphasis added)). Article 694-4 of the French Code of Criminal Procedure similarly
provides that "Extradition shall not be granted
[w]hen the person claimed has French
nationality, the latter being assessed at the time of the offense for which extradition is
requested." Id. 1 10; see also Gov't Opp'n, Ex. A at 2. Thus, there is considerable uncertainty
as to the relevance of the Defendant's offer of renunciation of her French citizenship to her
ability to frustrate, if not entirely bar, extradition. The Court's assessment of the risks largely
1 The Court cites the translated version of the letter, though the original letter is in French.
2 Here, there are minor discrepancies between the two sides' respective translations. The
translated letter from the Ministry of Justice cites Article 694-4 as reading, "When the individual
claimed to have French citizenship, said citizenship having been assessed at the time of the
offense on the basis of which removal is being requested." Gov't Opp'n, Ex. A at 2.
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parallel those that the Court articulated when the Defendant proposed signing an extradition
waiver. See Dec. Op. at 12-13.
Similar doubts exist as to the Defendant's offer to renounce her UK citizenship. The
Court is persuaded by the Government's arguments that even if the Defendant were to renounce
her UK citizenship, she would still likely be able to delay or resist extradition from the UK. See
Gov't Opp'n at 6-7. And for largely similar reasons, the Court again concludes that the
proposed conditions do not meaningfully diminish the Court's concerns regarding the
Defendant's ability to flee and to frustrate or impair any subsequent extradition attempts. The
possibility that the Defendant could successfully resist or forestall extradition heightens the
Defendant's incentive to flee.
To summarize, the Defendant's willingness to renounce her French and UK citizenship
does not sufficiently assuage the Court's concerns regarding the risk of flight that the Defendant
poses. Considerable uncertainty regarding the enforceability and practical impact of the
renunciations cloud whatever relevance they might otherwise have to the Court's assessment of
whether the Defendant poses a risk of flight. See United States V. Cohen, No. C 10-00547 (SI),
2010 WL 5387757, at *9 n.11 (N.D. Cal. Dec. 20, 2010). And that same uncertainty-and the
possibility that she will be able to successfully resist, or at least delay, extradition-incentivizes
flight, particularly because of the Defendant's substantial international ties.
Nor does the second proposed condition materially alter the Court's determination that no
condition or combination of conditions can reasonably assure the Defendant's appearance. The
Defendant proposes to have a retired federal judge provide oversight authority over her financial
affairs, and, if granted, he would have the authority to restrain, monitor, and approve
disbursement of assets requiring his signature. See Reply at 5. The Court continues to have
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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 11 of 12
concerns about whether the full extent of the Defendant's assets have been disclosed in light of
the lack of transparency when she was first arrested. But the Court assumes, for purposes of
resolving this motion, that the financial report that it reviewed in December is accurate and that it
accounts for all of the Defendant's and her spouse's assets. See Dec. Op. at 16-17.
The monitorship condition does not reasonably assure the Defendant's future appearance,
even when viewed in combination with the rest of the Defendant's bail package. The Defendant
would continue to have access to substantial assets-certainly enough to enable her flight and to
evade prosecution. These include the $450,000 that the Defendant would retain for living
expenses and any future salaries for her or her spouse, along with other assets, including jewelry
and other chattels, that are potentially worth hundreds of thousands of dollars. See Def. Mot. at
5-6; see also Dkt. 97, Ex. O at 9. While those amounts may be a small percentage of the
Defendant's total assets, they represent a still-substantial amount that could easily facilitate
flight. When combined with the Court's weighing of the $ 3142(g) factors and the presumption
of detention, the Court concludes that the proposed restraints are insufficient to alter its
conclusion that no combination of conditions can reasonably assure her appearance.
If the Court could conclude that any set of conditions could reasonably assure the
Defendant's future appearance, it would order her release. Yet while her proposed bail package
is substantial, it cannot provide such reasonable assurances. As a result, the Court again
determines that "no condition or combination of conditions will reasonably assure the
appearance of" the Defendant, and it denies her motion for bail on this basis. 18 U.S.C. $
3142(e)(1).
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IV. Conclusion
Defendant Ghislaine Maxwell's third motion for release on bail, Dkt. No. 160, is
DENIED. The parties are ORDERED to meet and confer and propose and justify any redactions
to the Defendant's reply brief by March 24, 2021. If they conclude that redactions are
unnecessary, the Defendant is ORDERED to docket the unredacted version of the brief by March
24, 2021.
so ORDERED.
Alim D. Netto
Dated: March 22, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
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UNITED STATES DISTRICT COURT
USDC SDNY
SOUTHERN DISTRICT OF NEW YORK
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 9/3/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
Defendant seeks the Government's "disclosure of the identities of the unnamed co-
conspirators alleged in the S2 indictment." Dkt. No. 331 at 1. In its August 13 Opinion &
Order, this Court noted that the Government had not objected to Defendant's two prior requests
that the Government identify the unnamed co-conspirators. Dkt. No. 317 at 12 n.1; see also Dkt.
No. 331 at 1. On August 18, 2021, the Government filed a letter stating that it "objects to any
requirement that it provide an exhaustive list of co-conspirators, whether in a bill of particulars
or otherwise absent further order of the Court." Dkt. No. 320 at 1. The Court concludes that
the Government's objection comes too late as the Government had multiple opportunities to raise
its objection before this Court issued its opinion. For this and the foregoing reasons, the Court
concludes that at the same time that the Government discloses Jencks Act materials, the
Government must also disclose to the Defendant the identities of all unnamed co-conspirators
alleged in the S2 indictment to whom it will refer at trial. See United States V. Bin Laden, 92 F.
Supp. 2d 225, 241 (S.D.N.Y. 2000).
Even if the Court were to find that the Government had not waived its objection, it would
find unpersuasive the Government's justifications for withholding this information. "In
considering whether to grant a request for identification of unnamed co-conspirators, 'the Court
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must balance the risk of surprise to the defendant, which is enhanced if 'there are a large number
of co-conspirators and a long-running conspiracy' with legitimate law enforcement concerns,
such as the potential danger to co-conspirators and the risk of compromising continuing
investigations." United States V. Akhavan, No. S3 20-CR-188(JSR), 2020 WL 2555333, at *2
(S.D.N.Y. May 20, 2020) (quoting United States V. Pinto-Thomaz, 352 F. Supp. 3d 287, 303
(S.D.N.Y. 2018).
The conspiracies charged are long-running, increasing the risk of surprise to the
Defendant. See Akhavan, 2020 WL 2555333, at *2. Count Three charges Maxwell with a
conspiracy running from 1994 to 2004 and Count Five charges a conspiracy running from 2001
to 2004. Dkt. No. 187 17, 23. And as the Court has previously found, Maxwell is likely able
to determine the names of the alleged victims described in the Indictment due to the
Government's extensive discovery, see Dkt. No. 207 at 20; however, this logic does not
necessarily extend to the identities of alleged co-conspirators. See Bin Laden, 92 F. Supp. 2d at
241.
The Government argues that there is no risk of surprise because "it currently intends" to
introduce the alleged co-conspirator statements of only two individuals. Dkt. No. 320 at 2. At
the same time, however, the Government proffers that it "may change its view as it prepares for
trial." Dkt. No. 320 at 2. The Court thus finds the Government's reassurance hollow and
insufficient to ensure that the Defendant may adequately prepare her defenses. See Pinto-
Thomas, 352 F. Supp. 3d at 301-02.
Moreover, the Government has not alleged that disclosure here would create "potential
danger to co-conspirators" or risk "compromising continuing investigations." See Akhavan,
2020 WL 2555333, at *2. It merely argues that disclosing the identities risks "harm to the
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Case 1:20-cr-00330-AJN Document 335 Filed 09/03/21 Page 3 of 3
Government from restricting its proof at trial." Dkt. No. 320 at 3. The Government provides no
explanation for this purported harm and none is apparent to the Court. Thus, the Court finds that
this concern alone does not outweigh the risk of surprise to the Defendant in this case or the need
for the parties to litigate co-conspirator issues in advance of trial to ensure the absence of delay.
In light of the interests discussed above and consistent with other courts that have required
disclosure of co-conspirator identities to the defense, the Court will require the Government to
disclose the identities of any unnamed co-conspirators who allegedly participated in the
conspiracies charged in the S2 indictment whom the Government intends to refer to at trial.
Accordingly, the Court ORDERS that at the same time that the Government discloses
Jencks Act material, the Government shall also disclose to the defense the identities of any
unnamed co-conspirators who allegedly participated in the conspiracies charged in the S2
indictment to whom the Government will refer at trial. The Government is FURTHER
ORDERED to disclose all co-conspirator statements it intends to offer at trial no later than
October 11, as consistent with this Court's scheduling order. Dkt. No. 297 at 1.
so ORDERED.
Dated: September 3, 2021
Alim New
New York, New York
ALISON J. NATHAN
United States District Judge
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
Subject: FW: Discovery Issues
Date: Mon, 29 Mar 2021 18:59:01 +0000
Attachments: SDNY_Production_Issues_20210329.xlsx; SlipsheetExample-SDNY_GM_00541380.pdf
Inline-Images: image002.jpg; image004.jpg
Hi
We just received the below and attached regarding discovery in the Maxwell case. Many of these questions relate to
productions that PAE prepared. Would you please take a look and let me know when would be a good time this week for
a call to discuss?
Thanks,
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
EFTA00027864

=== Page 2 ===
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
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PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00027865


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Voucher for Trip 10621156 is late
Date: Mon, 23 Sep 2019 04:02:48 +0000
Importance: Normal
Dear
Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
Trip ID: 10621156
Traveler name
Destination: West Palm Beach
Purpose: R19NYS13832 - U.S. V. Epstein (2018R0618) - Victim Interviews
Trip Dates: 2019-09-09 - 2019-09-10
Current status: Authorization Approved
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
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
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Reference ID# V0013
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.
EFTA00029483


c1: EFTA00028564
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028564.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "postmaster@usdoj.gov" <postmaster@usdoj.gov>
To:
Subject: SecureMail Encryption Response
Date: Mon, 29 Jun 2020 13:33:43 +0000
Your message was successfully encrypted.
Message Details:
From:
To:
Subject: RE: Epstein
EFTA00028564


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=== Page 1 ===
From: Christian Everdell
To: ""NathanNYSDChamber
Cc:
"
)"
i
(USANYS)"
)"
>, 'BOBBI C STERNHEIM'
X
"Jeff Pagliuca"
, 'Laura Menninger
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Pretrial Motion Reply Memoranda and
Exhibits (to be Filed Under Seal)
Date: Tue, 16 Mar 2021 02:19:19 +0000
Attachments: 2021.03.15_Filing.zip
Inline-Images: image003.gif; image005.jpg; image006.jpg; image005(1).jpg; image006(1).jpg
Dear Judge Nathan -
As set forth in the attached cover letter and pursuant to Rule 2(B) of the Court's individual rules, attached for the Court
and government are two versions (redacted and unreacted) of Ms. Maxwell's reply memoranda in support of her pretrial
motions and accompanying exhibits. A redacted cover letter is being filed on the public docket.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
CG
COHEN & GRESSER LLP
EFTA00028849


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027706.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS) [Contractor]"
Cc:
(USANYS)"
)"
)"
Subject: RE: [EXTERNAL] Fwd: Request for Comment
Date: Thu, 21 Oct 2021 15:55:06 +0000
Embedded: Fwd:_Request_for_Comment.msg
Response attached.
From:
Sent: Thursday, October 21, 2021 11:42 AM
To:
(USANYS)
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
)
>;
Subject: FW: [EXTERNAL] Fwd: Request for Comment
Hi
Passing this on. It's pretty aggressive to try to contact me through the school where I teach, but defer to you on how to
respond, if at all.
Thanks,
Begin forwarded message:
From: Monique Beals
Date: October 21, 2021 at 11:36:34 AM EDT
To:
Subject: Request for Comment
Hello,
I am a reporter from The Hill, and I wanted to seek any comment you may have on Ghislaine Maxwell seeking private
screenings of potential jurors.
If you have any statement on this, please feel free to reach out.
I apologize for reaching out to you via your Columbia University email address, but wanted to be sure to reach you in the
event you would like to provide a statement.
Best,
Monique Beals
EFTA00027706


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=== Page 1 ===
Subject: Re: Epstein FOIA
Date: Thu, 01 Jul 2021 17:18:56 +0000
Great, good to know. We'll continue to coordinate with their press folks. Thanks very much.
Sent from my iPhone
On Jul 1, 2021, at 1:16 PM,
wrote:
All,
FYI,
just called from Main (I believe she's still at Fed Programs). She said there was interest from the AG's
Office in the release and had some questions. We talked through things, and she said she'd carry the info back. She said
she or someone else from DC might follow up.
Thanks,
Subject: Epstein FOIA
Morning. Just for your awareness, I got a call regarding the FOIA litigation from one of our press counterparts at Main.
She asked if it would be okay to refer press inquiries to SDNY, I told her it wasn't a problem. Other than process
questions,
and I anticipate declining to comment anyway.
Do we have a sense of timing as to when this will happen? (I was having a hard time hearing during the call, but my
impression was tomorrow and it would be voluminous and take the Times a while to get through?) Thanks.
Spokesman
United States Department of Justice
EFTA00029455

=== Page 2 ===
U.S. Attorney's Office I Southern District of New York
EFTA00029456


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=== Page 1 ===
From: Nicole Simmons <nsimmons@hmflaw.com>
To:
111
,
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, Laura Menninger <Imenninger@hmflaw.com>,
"ceverdell@cohengresser.com" <ceverdell@cohengresser.com>, "bcsternheim@mac.com"
<bcsternheim@mac.com>
Subject: [EXTERNAL] United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Mon, 08 Nov 2021 17:25:19 +0000
Attachments: 2021.11.08_JSP_Ltr_re_Rule_801(d)(2)(e).pdf
Inline-Images: image001.jpg
Dear Counsel:
At the request of Jeffrey Pagliuca, please see the attached correspondence of today's date.
Thank you,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
150 East 10th Avenue
Denver, Colorado
80203
PH 303.831.7364 FX
303.832.2628
DIRECT: 720.287.5835
www.hmflaw.com
nsimmons@hmflaw.com
EFTA00028215


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
(NY) (FBI)"
Subject: RE: Maxwell Travel Information
Date: Tue, 30 Jun 2020 17:53:40 +0000
Thank you! This is very helpful, much appreciated.
From:
(NY) (FBI)
Sent: Tuesday, June 30, 2020 1:43 PM
To:
Cc:
(NY) (FBI)
is
Subject: Maxwell Travel Information
Hi
In summary: Travel review for Ghislaine Maxwell, DOB:
from 1/1/2017 to 6/29/2020 identified the following
information:
Traveled 15 times with 7 OUTBOUND flights
United Kingdom: 5 times
Japan: 1 time
Qatar: 1 time
I have attached two travel records showing international travel with both a UK passport and a French Passport.
I have also attached two inspection documents citing her citizenship in both the UK and France.
Thanks,
EFTA00028563


c1: EFTA00029484
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029484.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Hi
The payment system is down we are holding all vouchers - You are fine
Date: Thu, 03 Oct 2019 15:58:46 +0000
Got it - thanks!!
Sent from my iPhone
> On Oct 3, 2019, at 14:56,
wrote:
>
> Hi
The payment system is down we are holding all vouchers - You are fine.
>
>
Thanks
V
>
Original Message
> From:
>
Sent: Thursday, October 03, 2019 5:50 AM
> To:
> Cc:
V
Subject: Re: Voucher for Trip 10643456-2 is late
V
V
I keep getting these emails. Do I need to submit anything else? Please advise - thanks.
>
>
Sent from my iPhone
>
On Oct 1, 2019, at 05:03, "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com> wrote:
Dear
>> Your travel voucher for the trip below is now late based on your customer settings. Please submit your
voucher for this trip and mark it as Final if you have no additional expenses to claim.
>>
Trip ID: 10643456-2
>>
Traveler name:
Destination: Santa Monica
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews Trip
Dates: 2019-09-17 - 2019-09-20 Current status: Authorization Approved
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.
EFTA00029484

=== Page 2 ===
>>
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change
your email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0013
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.
EFTA00029485


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c0:
=== Page 1 ===
From:
To: Christian Everdell
BOBBI C STERNHEIM
, Laura Menninger
, Jeff Pagliuca
Cc:
Subject: Redactions: Government motion in limine
Date: Fri, 29 Oct 2021 20:54:50 +0000
Attachments: Government_MIL_[redacted]_Final.pdf; Government_MIL_Exhibit_A_[redacted].pdf;
!Maxwell's_Response_to_Govs_Omnibus_Motns_in_Limine_[redacted]_Final.pdf;
Govt_Reply_Brief_[redacted]_Final.pdf
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
3
EFTA00028102


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=== Page 1 ===
From:
"
To:
Subject: PC.pdf
Date: Tue, 13 Apr 2021 12:52:45 +0000
Attachments: PC.pdf
This is the case list as of a few months ago. Let's chat later.
EFTA00027292


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=== Page 1 ===
From:
)"
To:
)"
Subject: Re: updates
Date: Fri, 30 Aug 2019 19:10:16 +0000
No problem! Just wanted to make sure I wander missing something.
On Aug 30, 2019, at 3:08 PM,
)
wrote:
Oh, sorry if I mixed that up.
Sent from my iPhone
On Aug 30, 2019, at 2:36 PM,
)
wrote:
I thought we were meeting with
in person, no?
From:
Sent: Friday, August 30, 2019 2:07 PM
To:
(USANYS)
Cc:
(USANYS)
is
>;
Subject: updates
Below is a summary update you requested regarding the investigation of co-conspirators. This does not include
everything the team is working on (for example, we have a list of legal research issues we are working through as we
canvas charging theories), and we're assuming familiarity with our recent memorandum regarding potential co-
conspirators. Please let us know if you need any additional information.
On August 27th, the team met separately with
and
and
are Victim-2
and Victim-3 in the Indictment. During the meetings,
and
both conveyed that they are willing to
cooperate in an ongoing investigation.
and
have previously described
as the individual
through whom they scheduled all of their encounters with Epstein.
On August 27th, the team met with
who reported being sexually assaulted at several of
Epstein's properties while she was an adult.
described being recruited to perform massages for Epstein
by Ghislaine Maxwell.
indicated that she would cooperate with our ongoing investigation.
On August 27th, the team interviewed
who described being recruited by Ghislaine
Maxwell and caused to engage in sexualized massage sessions with Epstein, during which she was sexually
assaulted. These assaults occurred in London, Florida, the USVI, and New York, beginning when
was 17 and continuing into her early twenties. These incidents occurred in the 1990s, before the sex
trafficking statutes were enacted.
indicated that she would cooperate with our ongoing
investigation.
EFTA00027947

=== Page 2 ===
On August 27th, the team met with
who has previously been interviewed and has described
being sexually assaulted by Epstein at several of his properties when she was 17.
has reported that
was present during one of these encounters.
has indicated that she will cooperate with
our ongoing investigation.
On August 29th, the team met with
, and
, who have each
reported being sexually abused by Epstein while they were adults. We are in the process of scheduling an
interview with
,
who has accused Ghislaine Maxwell of being involved in her abuse. We anticipate
that the interview will occur by videoconference, likely during the next two weeks.
Next week, the team hopes to travel to Florida for two meetings, subject to weather issues arising from
Hurricane Dorian. First, we hope to meet with
(
)
for a second proffer.
worked as
an assistant to Epstein in 2004, reporting to
Her duties included scheduling two to three
"massages" for Epstein each day he was in Florida. Second, we hope to meet with
for a reverse
proffer. When
was 16, Epstein proposed that she recruit girls for him, and
brought her young
friends to Epstein for "massages" for several years.
was granted immunity by SDFL and provided grand
jury testimony, and we hope to pursue
as a witness in this case. Our understanding is that
coordinated appointments for the victims through
On September 6th, we are scheduled to meet with
defense counsel for an attorney proffer.
On September 9th, we are scheduled to interview
by videoconference.
has
accused Ghislaine Maxwell of recruiting her when she was 16.
On September 16th, we are scheduled to interview
,
who worked as Epstein's "house man" in
New York for many years. To our knowledge,
has never been interviewed before.
During the week of September 16th, the team hopes to travel to California for several meetings. We hope to
meet with
,
a victim who is described in our previous memorandum regarding co-
conspirators. We have previously interviewed
and we hope to discuss whether
is willing to
cooperate with our ongoing investigation. While we are in California, we also hope to schedule follow-up
interviews with
and
described above.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00027948


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization
has received final approval
Date: Wed, 23 Oct 2019 23:03:59 +0000
Importance: Normal
Dear
Travel authorization
has received final approval.
Trip ID:
Traveler name:
Minor Customer name:
Purpose:
- U.S. V. Epstein - Witness Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-11-04 - 2019-11-04
Current status: Authorization Approved
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
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0006
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.
EFTA00028835


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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
August 15, 2019
VIA ECF
The Honorable Richard M. Berman
United States District Judge
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
As the Court is aware, on about the morning of August 10, 2019, Jeffrey Epstein died while
in custody at the Metropolitan Correctional Center. On August [], the Office of the New York
City Medical Examiner issued its report concluding that the defendant's cause of death was
suicide. In light of the death of the defendant prior to a conviction becoming final, the Government
must request the Court approve the attached proposed order of nolle prosequi.
Consistent with our practice throughout this case and our obligations under the Crime
Victims' Rights Act, the Government has made efforts to contact all identified victims since
learning of the death of the defendant and will similarly notify all known victims of the attached
order, once entered. As this Office has previously stated publicly, it remains committed to doing
its utmost to stand up for the victims who have already come forward, as well as for the many
others who have yet to do so.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney
By:
/s
/
/
Assistant United States Attorneys
Southern District of New York
Tel:
Cc:
All counsel of record (Via ECF)
EFTA00027154


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=== Page 1 ===
From:
)"
To:
)"
Cc:
Subject: Fwd: [EXTERNAL] information
Date: Tue, 26 Oct 2021 00:36:07 +0000
FYI- we discussed this over the summer but I guess he never submitted the request. I know you're no longer on
the case but let me know who I should forward this to in the event I receive a copy of his request. Copying
for his awareness.
Begin forwarded message:
From:
)"
Date: October 25, 2021 at 8:33:40 PM EDT
To:
Subject: Re: [EXTERNAL] information
Hi Mr.
As I discussed with Ms.
over the summer, you would need to submit a FOIA request to the BOP and
note that you are specifically requesting what they released to the NYT. You can send me copy of that request
once it has been submitted to the BOP and as a courtesy I will ensure that the correct recipient in the Civil
Division of our Office has received it. We do not handle FOIA requests in our division.
Best,
On Oct 25, 2021, at 12:40 PM,
wrote:
Hi,
Hope this finds you well.
I would like to get a copy of ALL of the records that were released to the New York Times on their FOI request
regarding my brother's case (Jeffrey Epstein).
Please advise the quickest way to accomplish this.
Thanks,
EFTA00028026

=== Page 2 ===
Scanned by McAfee and confirmed virus-free.
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=== Page 1 ===
From:
To:
Subject: Fwd: Epstein victim meeting
Date: Thu, 17 Oct 2019 22:13:28 +0000
Sent from my iPhone
Begin forwarded message:
From:
Date: October 17, 2019 at 6:01:25 PM EDT
To:
Subject: Epstein victim meeting
Guys,
Continue to hear positive comments coming from attendees of the meeting in Florida. FYSA, we are currently
expecting 15 victims, 3 support persons, and 8 attorneys at the meeting here on the 23rd.
EFTA00028331


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=== Page 1 ===
From:
Jeevacation
To:
Jes Staley
Sent:
12/4/2009 4:25:38 AM
Subject:
Re:
We are going to have fun
Sent from my iPhone
On Dec 3, 2009, at 11:05 PM, Jes Staley
<
wrote:
> I realize the danger in sending this email. But is was great to be
> able, today, to give you, in New York City, a long heartfelt, hug.
>
> To my friend,
> Thanks.
>
> Jes
> This email is confidential and subject to important disclaimers and
> conditions including on offers for the purchase or sale of
> securities, accuracy and completeness of information, viruses,
> confidentiality, legal privilege, and legal entity disclaimers,
> available at http://www.jpmorgan.com/pages/disclosures/email.
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-00000550
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From:
To:
Subject: Phone call
Date: Sun, 11 Aug 2019 18:52:43 +0000
It appears there is new information about the phone call at 7:17pm Friday night.
The Warden briefed OIG SAC Modano that the call was 19 minutes long. I did not brief the Warden on any
information regarding that call.
Epstein was never in general population, because of that he did not need an approved list of people to call.
On Friday he had a legal visit that lasted from 8:00ish an until almost 7:00pm. He was supervised the entire time
by BOP staff.
Sent from mobile device, please excuse typos.
Special Agent
Office of the Inspector General
1 Battery Park Plaza, 29th floor
New York, NY 10004
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From:
(USANYS)"
To:
)"
Cc:
)"
)"
(USANYS)"
Subject: RE: RE: attorneys asking about confidentiality
Date: Mon, 10 Feb 2020 23:06:33 +0000
Sorry, I just realized I mixed up
and
All three witnesses have not met with us but
has indicated she won't
come in, right?
From:
(USANYS)
Sent: Monday, February 10, 2020 5:50 PM
To:
Cc:
>;
is
(USANYS)
Subject: RE: RE: attorneys asking about confidentiality
Is the following fair/accurate? If there are specific concerns they raised, feel free to add/edit as appropriate. Thanks
Following
comments about Prince Andrew on January 27, the team heard from counsel for several witnesses who
had seen
remarks and had concerns. Specifically, the team heard from counsel for
and
each of whom referenced
comments about Prince Andrew and sough to confirm that their own
communications with the team about their clients would remain confidential.
as you know, has already met with us
several times.
and
- both of whom are believed to have worked in some capacity for Maxwell/Epstein
during relevant time periods - have never been interviewed before but have expressed a willingness to come in, and we
have been working with their counsel now to arrange for interviews.
From:
Sent: Monday, February 10, 2020 5:34 PM
To:
(USANYS)
Cc:
is
Subject: RE: attorneys asking about confidentiality
Following up on our discussion earlier, the attorneys who have asked about confidentiality since the public comments
about Prince Andrew include counsel for
counsel for
and counsel for
Separately, just a reminder to please send us
email on the Maxwell depositions? We're going through them
separately as well, but would be helpful to know what jumped out to him in his read.
thanks,
Assistant U.S. Attorney
Southern District of New York
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From:
To:
Subject: Call with
Date: Wed, 22 Sep 2021 19:40:42 +0000
doesn't remember the name
but has a memory of being involved in the Epstein litigation as a
court reporter. She thinks she may have been the reporter on a deposition or two of Jeffrey Epstein.
will check her files to see if she has the original copy of the transcript but will be able to authenticate the
transcript from looking at it.
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From: BOBBI C STERNHEIM <bcsternheim@mac.com>
To:
)"
)"
(USANYS)"
,
)"
Cc: Christian Everdell <CEverdell@CohenGresser.com>, Laura Menninger
<lmenninger@hmflaw.com>, Jeff Pagliuca <jpagliuca@hmflaw.com>
Subject: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Wed, 18 Aug 2021 18:42:06 +0000
Attachments: Letter_re_VTCs_8-18-18.pdf; ATT00001.htm
Good afternoon-
Attached please find a courtesy copy of today's ECF filing.
Regards-
Bobbi
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From:
)"
To:
N. (NY) (FBI)"
Subject: property return
Date: Thu, 01 Aug 2019 19:06:30 +0000
Hey defense counsel will be at his desk for the next hour if you're able to give him a call? He's at
Or if not,
let me know what a good time to do a conference call would be. Thanks!
From: Miller, Michael
Sent: Thursday, August 01, 2019 14:36
To:
Subject: RE: Epstein
- We have not been able to connect yet. I'm at my desk for the next 1.5 hours if that works for Agent
Mike
From:
Sent: Thursday, August 1, 2019 12:23 PM
To: Miller, Michael
Subject: RE: Epstein
Hi Mike,
Thanks for following up, and I connected with Agent
about reaching out to you - I think she may have left a
message. Let me know if you and she aren't able to connect up by the end of the day? If you're still not by then, I can try
to set up a specific time.
thanks,
From: Miller, Michael
Sent: Thursday, August 01, 2019 10:40
To:
Subject: Epstein
Hello
-
Any word on when I can send someone by to pick up the ring, diamonds, and funds?
Many thanks.
Mike
Michael C. Miller
Partner
www.steptoe.com/mmiller
Steptoe
Steptoe & Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
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www.steptoe.com
This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you
are not the intended recipient, please do 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.
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From:
)"
To:
(USANYS)"
Cc:
)"
(USANYS)"
)"
Subject: Maxwell trial fact witness travel -
Date: Tue, 09 Nov 2021 19:08:14 +0000
Attachments:
-_Fact_Witness_Travel_Request.docx
Hi
Attached please find a fact witness travel request for another witness in the Maxwell trial
I expect
he'll testify on 12/2, but he could possible bleed over into 12/3, so I'd like to have him fly in on 12/1 and out on the
evening of 12/3. Please let me know if you have any questions, and thank you, as always, for your help.
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From:
"
)"
To:
"
(
)"
Subject: Accepted:
Date: Mon, 10 Jun 2019 17:40:24 +0000
Importance: Normal
Attachments: unnamed
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From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein accounts
Date: Mon, 10 Aug 2020 14:33:15 +0000
Thanks, will do.
From:
Sent: Thursday, August 06, 2020 14:57
To:
is
Cc:
is
Subject: RE: Epstein accounts
I would recommend we push back on them producing the subpoena itself. I don't know if we listed a statute in our
subpoena that would trigger the mandatory non-disclosure provision USVI was able to rely on, but if we listed money
laundering that would get us there.
As for the documents we received pursuant to subpoena, I don't really see a basis to push back on that, but let me know if
you disagree.
From:
Sent: Thursday, August 6, 2020 2:31 PM
To:
(USANYS)
Cc:
is
Subject: Re: Epstein accounts
Refreshing this - please let us know? Or happy to discuss if necessary. Thanks.
On Aug 3, 2020, at 18:56,
wrote:
FYI, below - the AG's office at USVI is basically just trying to copy our investigation. Do we care if DB provides our
subpoenas, what they produced to us, to USVI AG?
From: Moyne, Parvin
Sent: Monday, August 03, 2020 12:12
To:
Cc: DiPiero, Joseph
Moyer, Thomas
is
Subject: RE: Epstein accounts
I hope you are well and getting some time "off" this summer. I'm reaching out via email as it may be the most efficient
way to tee-up the inquiry we have received, but we can circulate a dial-in at a convenient time for you if you'd like to
discuss anything.
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Deutsche Bank has received a third-party subpoena from the Attorney General's Office of the U.S. Virgin Islands in
connection with a pending civil suit they have filed against Jeffrey Epstein's estate, the executors of the estate, and
others. One of the requests is for a copy of any government subpoenas received by the Bank relating to Epstein, and a
copy of any productions made pursuant to the subpoenas. Do we have your permission to disclose your subpoena and
our production to you to the U.S.V.I. AG? Would you prefer us to refer the office to you directly or provide you with
contact information? I'm happy to send you a copy of the U.S.V.I. AG subpoena if helpful in evaluating the request.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
Direct:
Internal:
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.
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From:
)"
To: Jack Scarola
Cc:
)"
)"
Subject: RE: Epstein
Date: Sun, 15 Sep 2019 21:38:06 +0000
Understood-thanks very much.
From: Jack Scarola
Sent: Sunday, September 15, 2019 17:37
To:
Cc:
is
Subject: Re: Epstein
Mr. Tom's message is unrelated to
I am awaiting a response from
On Sep 15, 2019, at 5:05 PM,
)
wrote:
Jack,
This looks like it's on a separate subject from Ms.
so we wanted to make sure you had seen
email about
our interest in meeting with her - can we set up a date and time to do that?
thanks,
From: Jack Scarola
Sent: Sunday, September 15, 2019 17:01
To:
Cc:
is
Subject: Re: Epstein
Ms. Moe-
I received the information described in the message below, and I am passing it on to you with the permission of
Mr. Toma. I have conducted no assessment of the statements made by Mr. Toma and I have had no direct contact
with him.
On Sep 14, 2019, at 7:20 PM,
)
wrote:
Thanks for confirming. Would it be possible to set up a meeting with her? We would be interested in speaking
with her, and if she is willing to speak with us we can discuss logistics (in particular, we can come to Florida if
that is her preference).
Thanks,
EFTA00027949

=== Page 2 ===
Sent from my iPhone
On Sep 13, 2019, at 7:53 PM, Jack Scarola
wrote:
I do.
On Sep 13, 2019, at 4:09 PM,
)
wrote:
Mr. Scarola,
Following up on this, we wanted to check to see whether you represent Ms.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
From: Jack Scarola
Sent: Wednesday, August 7, 2019 6:40 PM
To:
Cc:
is
Subject: Re: Epstein
I have forwarded your message to
On Aug 7, 2019, at 4:48 PM,
)
wrote:
Mr. Scarola,
We have had difficulty contacting Ms.
in connection with our investigation. Are you in touch with her and able
to set up a meeting with us? We would be interested in speaking with her and can travel to Florida to do so.
thank you,
From: Jack Scarola
Sent: Wednesday, August 07, 2019 08:54
To:
>
Cc: ROBERT C. JOSEFSBERG RJOSEFSBERG@podhurst.com Brad Edwards <brad@pathtojustice.com>
Subject: Re: Epstein
For whatever value it may have in connection with your pending prosecution of Jeffrey Epstein, one of his
victims,
,
who was repeatedly molested in Florida beginning at age 14, received multiple gifts
of lingerie from Epstein shipped to her in Florida from NY.
may be reached at
, and is
willing to speak to investigators.
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=== Page 3 ===
*
I Privileged and Confidential I Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud.
Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of
this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
*
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From:
To:
Cc:
Subject: RE: Brief
Date: Tue, 26 Oct 2021 03:08:08 +0000
Attachments: Govt_Omnibus_Opp_v4.docx
Hi
Brief attached. Before you make the TOC, will you do a quick scroll through to confirm that (1) there's no weird spacing
issues, and (2) the only highlighting is green? I just did that but could use someone double-checking.
Thanks!
From:
Sent: Monday, October 25, 2021 9:53 PM
To:
Cc:
Sub,
Sounds good!
From:
Sent: Monday, October 25, 2021 9:51 PM
To:
Cc:
Subject: RE: Brief
OK! Just TOC this time. Thanks!
From:
Sent: Monday, October 25, 2021 9:51 PM
To:
Cc:
Subject: RE: Brief
You can send it to me, thanks. Are you going to need a TOA and TOC or just one or the other?
From:
Sent: Monday, October 25, 2021 9:48 PM
To:
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=== Page 2 ===
Cc:
Subject: Brief
Hi all,
Just checking in to see who I should send the brief to tonight when it's ready to be finalized. Thanks!
Andrew
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Fwd: Epstein trustees' counsel
Date: Thu, 19 Dec 2019 18:53:08 +0000
Let's discuss.
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: December 19, 2019 at 12:31:44 PM EST
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein trustees' counsel
In our call today with counsel for the respective Trustees of the Epstein estate, they asked that we convey a request to
meet with
,
and anyone else she would want to include in such a meeting, to discuss the Trustees' interest in
resolving the Government's potential civil forfeiture claims against the estate. They said they appreciated our (the line
assistants') willingness to hear their regular updates, but that they understand we're not in a position to negotiate, or
even to provide feedback on the proposed plan for the fund, and so they'd like the opportunity to elevate that
discussion and convey why they believe it would be in all parties' interests, including the victims, to engage in
meaningful discussions about a possible resolution. When you've spoken with
, could you please let us know
whether she's willing to meet with them? And we can convey the response, unless you and/or she would prefer to do
so directly. If she is willing to meet with them, they were hoping to put a date and time on the calendar as soon as is
convenient for her after the holiday.
thanks,
Assistant U.S. Attorney
Southern District of New York
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From:
USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: RE:
Date: Tue, 14 Jul 2020 19:22:48 +0000
Anything that might be outside of sentry, like pen data?
Original Message
From:
(USANYS)
Sent: Tuesday, July 14, 2020 3:17 PM
To:
(USANYS)
(USANYS)
Subject: RE:
I've never seen it. We did ask about 302s, but this is a good reason to re-ask and request the full sentry file
(which we didn't do previously unless I'm forgetting).
Original Message
From:
(USANYS)
Sent: Tuesday, July 14, 2020 3:16 PM
To:
(USANYS)
(USANYS)
Subject: RE:
I agree on both points. Did we initially ask FBI for their entire SENTRY file? I think we may want to do that to
be safe.
Original Message
From:
(USANYS)
Sent: Tuesday, July 14, 2020 3:12 PM
To:
(USANYS
(USANYS)
Subject: FW:
See attached - I think we need to ask
what Lt.
reviewed to get this information.
Also, I don't think I've seen this 302 before.
I thought we had asked FBI for all 302s, but I could be mis-
remembering. Either way, I think we should do so again.
Original Message
From:
(NY) (FBI)
Sent: Tuesday, July 14, 2020 2:51 PM
To:
USANYS)
Subject:
Hey
When looking through my case file, this is where
documented the phone number and last call made by
Epstein. Let me know if you need anything else
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Special Agent
FBI New York Field Office
Violent Crimes Task Force
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
Defendant.
:
:
:
X
REPLY MEMORANDUM OF LAW IN SUPPORT OF MS. MAXWELL'S MOTION TO
DISMISS COUNTS ONE THROUGH SIX OF THE SUPERSEDING INDICTMENT FOR
PRE-INDICTMENT DELAY
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Attorneys for Ghislaine Maxwell
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The significant delay in prosecuting these charges has substantially prejudiced Ms.
Maxwell, and the government has offered no legitimate reason for the tactical delay. Indeed,
many of the arguments made by the government in response to Ms. Maxwell's motions reveal
new information that undercut its claims about the origins of, and motives behind, this
prosecution.
Ms. Maxwell raised this issue pretrial, as required by Fed. R. Crim. P 12(b)(3)(A)(ii). In
her opening memorandum Ms. Maxwell noted that significant discovery related to the
allegations had not yet been provided by the government, that her investigation is ongoing, and
requested that the Court defer ruling on this motion.
The government's responses to Ms. Maxwell's motions, including its response to this
motion, underscore the legitimacy of Ms. Maxwell's continued request that the Court hold this
issue open. As reflected in the various pleadings, the government did have communications with
lawyers for civil litigants and did have information about the allegations made in the indictment
well before it claims the investigation was opened. Ms. Maxwell learned about these things only
because the government felt the need to make partial disclosures in an attempt to defend its
actions.
In its response to the instant motion, the government, without actually disclosing the
witness's statements, selectively "proffers" "facts" to justify its position but tells Ms. Maxwell
and the Court that we should, apparently, just trust the government because "the underlying
information, which is contained in the FBI 302 reports of interviews with the victims, will be
produced to the defense as 3500 material in advance of trial." Resp. at 55 fn. 21.
As discussed in her Motions to Dismiss for Lack of Specificity, for a Bill of Particulars,
and for Pretrial Disclosures, the government's failure to provide adequate information about the
1
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=== Page 3 ===
allegations in the indictment continues to prejudice Ms. Maxwell's ability to investigate and
defend this matter. It is fundamentally unfair for the government to withhold basic information
while at the same time making representations about that information to the Court when
convenient. This type of selective disclosure by one party in litigation is disfavored. See,
e.g., United States V. Nobles, 422 U.S. 225, (1975); United States V. Bilzerian, 926 F.2d 1285 (2d
Cir. 1991); In re Grand Jury Proceedings, 219 F.3d 175, 182-84 (2d Cir.2000); Granite
Partners, L.P. V. Bear, Stearns & Co., Inc., 184 F.R.D. 49, 54 (S.D.N.Y. 1999); Worthington V.
Endee, 177 F.R.D. 113, 116-17 (N.D.N.Y. 1998); Peck V. United States, 514 F. Supp. 210, 213
(S.D.N.Y.), on reargument, 522 F. Supp. 245 (S.D.N.Y. 1981); State of N.D. ex rel. Olson V.
Andrus, 581 F.2d 177, 182 (8th Cir. 1978) (selective disclosure exhibited by the government in
this action is "intolerable as a matter of policy").
It would be inefficient and a waste of judicial resources to continue to litigate this issue
piecemeal. Moreover, until Ms. Maxwell has complete relevant information, she cannot precisely
identify the many witnesses and documents that are unavailable to her as a result of the pretrial
delay.
CONCLUSION
Accordingly, Ms. Maxwell requests that the Court defer consideration of her Motion to
Dismiss Counts One Through Six of the Superseding Indictment for Pre-Indictment Delay until
after the government has produced all of the discovery in this matter, including, but not limited
to any alleged F.R.E. 404(b) information, all witness statements, and all Brady and Giglio
material.
Dated: March 15, 2021
2
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=== Page 4 ===
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Attorneys for Ghislaine Maxwell
3
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=== Page 5 ===
Certificate of Service
I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the
Court's individual practices in criminal cases, the Reply Memorandum of Law in Support of Ms.
Maxwell's Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre-
Indictment Delay upon the following:
U.S. Attorney's Office, SDNY
s/ Christian R. Everdell
4
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From:
(USANYS)"
To:
)"
Subject: FW: Maxwell Suppression Opp
Date: Mon, 15 Feb 2021 18:50:43 +0000
Attachments: Motion_to_Suppress_Opp_v2.docx.
Hey - Hope you have been able to enjoy the long weekend! Here is what I sent
I don't think he has reviewed yet
and not sure what your timing is looking like, but figured I would forward. (Also happy to send to you once
has had a
chance to review)
From:
(USANYS)
Sent: Friday, February 12, 2021 4:25 PM
To:
(USANYS)
Subject: RE: Maxwell Suppression Opp
Thanks so much,
My apologies again for its length. I welcome all of your feedback, including where to trim this; if
the order in which I addressed her various arguments makes sense; and the due process points. Hopefully I didn't miss
the mark too badly on this! Thanks again.
From:
(USANYS)
Sent: Friday, February 12, 2021 2:06 PM
To:
(USANYS)
Subject: RE: Maxwell Suppression Opp
Sure.
From:
(USANYS)
Sent: Friday, February 12, 2021 2:05 PM
To:
(USANYS)
Subject: Maxwell Suppression Opp
Thanks again for all of your time over the past couple of weeks. I was hoping to send you my Maxwell opposition this
afternoon for your review given all of your incredibly helpful feedback and expertise in this area. It's on the lengthier side
given the complicated facts and the many arguments they made so my apologies in advance. I'm aiming to send it to my
chiefs early next week if at all possible, but totally understand if not. Happy to discuss.
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:
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From:
"
]"
To:
)"
(
)"
Subject: Fwd: US V Maxwell TRIAL
Date: Thu, 11 Nov 2021 02:47:13 +0000
Attachments: LBAAMAXH.pdf
Please find the transcript from today attached.
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: November 10, 2021 at 9:45:17 PM EST
To:
"
(
)
[Contractor]"
)"
Cc:
)"
)"
Subject: FW: US V Maxwell TRIAL
Today's transcript attached.
From:
Sent: Wednesday, November 10, 2021 6:24 PM
To:
)
is
)
;
Subject: [EXTERNAL] US V Maxwell TRIAL
EFTA00029578


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=== Page 1 ===
From:
"
)"
To:
"
(NY) (FBI)"
i
Cc:
"
(USANYS)"
"
II
Subject:
Date: Fri, 02 Oct 2020 00:48:01 +0000
and
Is there a 302 for this witness that you could send us please? Thanks.
Sent from my iPhone
EFTA00029041


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=== Page 1 ===
From:
To:
Subject: Fwd: SDNY investigation / interview
Date: Tue, 21 May 2019 20:23:34 +0000
Importance: Normal
Just as a reminder,
is out Thursday/Friday.
Sent from my iPhone
Begin forwarded message:
From: Alex Conlon
Date: May 21, 2019 at 4:07:12 PM EDT
To:
Cc: Alexandra Elenowitz-Hess
Subject: RE: SDNY investigation / interview
Hi
I just tried to reach you at your desk, but missed you.
is available to meet this week at 4:30 at our office if that works for you. Also, she plans to make the phone calls
we discussed today and tomorrow on her own. She will contact me once she has connected with two individuals she's
reaching out to and I will reach out to you in turn.
Happy to discuss anything, if that's helpful.
Thanks,
Alex
Alex Conlon Kaplan Hecker & Fink LLP
From:
Sent: Tuesday, May 14, 2019 4:49 PM
To: Alex Conlon
Cc: Alexandra Elenowitz-Hess
Subject: RE: SDNY investigation / interview
Alex,
Just tried calling but missed you - wanted to briefly follow up on our conversation last week to let you know that we
certainly don't have any objection to someone from your firm (whether attorney or staff) taking notes in connection
EFTA00027773

=== Page 2 ===
with Ms.
conversations to tell the individuals we discussed that our office is interested in speaking with
them. I expect we might request a copy of the notes, and, as discussed, whoever is with her would be a potential,
theoretical witness, but no issue on our end with any of that.
Separately, if it's possible, could you please ask Ms.
if there is a time next week or the following that we could
meet with her? We're hoping to cover all the information we need to in this first set of discussions before June, when I
think it will be even more inconvenient for her to meet. I expect the next meeting will address difficult topics, including
Giglio subjects and some review of Epstein's conduct with Ms.
in particular; but, I also expect that once we
get through those issues, we won't need to meet with her again for at least a little while.
We can generally make ourselves available whenever works on her end, with some combination of our team (e.g., if it's
the latter half of next week, will likely be me and our new team member
but let us know if there are any
issues with that), and as always can work around her schedule. And happy to come to your office for the final push.
Don't hesitate to give a call if any other info would be helpful, or if any questions or issues, and thanks very much.
Assistant U.S. Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure,
dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in
error, please notify the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00027774


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=== Page 1 ===
From:
To:
Subject: FW: United States V. Ghislaine Maxwell --
pens
Date: Sun, 28 Nov 2021 22:52:30 +0000
Good luck!!!!
o
C:
From
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS
>; ; USANYS-CRIMINAL PARALEGALS
>; USANYS-INVESTIGATORS
Cc:
Subject: United States V. Ghislaine Maxwell --
opens
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
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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 10, 2021
BY EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint
letter regarding protections for witness identities at trial. In particular, the Court directed the
parties to: (1) provide nomenclature for witnesses whose identities should be protected, (2) propose
procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury
regarding witnesses testifying under pseudonyms or under their first name only, and (4) address
the logistics of offering sealed or redacted exhibits containing personal identifying information.
Below are the positions of the parties regarding these logistical considerations. Because this letter
contains identifying information relating to victims, the Government respectfully requests that the
Court accept the Government's proposed redactions to this letter.
Government position:
I.
Nomenclature
With respect to nomenclature for witnesses whose identities should be protected at trial,
the Government respectfully submits the following chart, which provides the true names of
witnesses and the proposed nomenclature for those witnesses at trial.
EFTA00028260

=== Page 2 ===
Page 2
Witness Name
Nomenclature at Trial
The Government submits that this nomenclature can be used when trial begins on
November 29, 2021, but that the parties should be directed to continue referencing victims and
witnesses on the public record according to the nomenclature in the Superseding Indictment. The
Government further requests that the defense be directed to redact the true names of the witnesses
in this chart from all exhibits to filings, and to avoid using the true names of victims in filings with
the Court. Using the true names of victims delays public filings and creates otherwise unnecessary
redaction projects that waste the Government and the Court's time. Moreover, using victim names
in filings increases the risk that victim identities may become public, due to redaction errors or
other issues.
II.
Voir Dire
Regarding voir dire, the Government proposes that prospective jurors be handed a sheet
with a list of names and places that may come up at trial. That sheet, which would be filed under
seal, would contain the true names of witnesses. The sheet would not be read aloud; instead, the
EFTA00028261

=== Page 3 ===
Page 3
Government requests that the Court direct prospective jurors to read the sheet and to raise a hand
if they are familiar with the witnesses or locations. Examination of jurors on this subject would
then be conducted at sidebar, with the transcript redacted to remove witness identifying
information.
Similarly, with respect to employment information regarding witnesses, the Government
proposes that the list of names and places handed to prospective jurors should also contain a section
regarding entities, institutions, or programs with which jurors may be familiar. Examination on
this subject would similarly be conducted at sidebar, with the transcript redacted to remove witness
identifying information.
III.
Limiting Instruction
The Government requests that the Court give the jury an instruction that is similar to the
instruction Judge Garaufis gave the jury in United States V. Raniere, 18 Cr. 204 (E.D.N.Y.). In
that case, Judge Garaufis instructed the jury:
You may have noticed during yesterday's testimony that the witness used first
names of certain individuals. That is because the names of certain alleged victims
are being withheld from the public and the press to protect the privacy of those
individuals. I have therefore instructed the parties to refer to those individuals by
their first names only; however, those full names are known to the Government, the
defendant, and to the Court.
An excerpt of the relevant transcript is enclosed as Exhibit A. Here, the Government proposes that
the Court instruct the jury:
At this trial, certain witnesses will be testifying under their first name only. Other
witnesses will be testifying under pseudonyms - that is, under different names.
That is because the names of certain alleged victims and related witnesses are being
withheld from the public and the press to protect the privacy of those individuals. I
have therefore instructed the parties to refer to those individuals by their first names
only, or in some instances, by using a pseudonym. However, the full names of the
witnesses are known to the Government, the defendant, and to the Court.
The Government respectfully submits that the proposed instruction addresses any potential
EFTA00028262

=== Page 4 ===
Page 4
prejudice to the defendant, as the instruction makes clear to the jury that the identities of the
witnesses are being protected from the public and press only, and that the true names of the
witnesses are known to the Government, the Court, and the defendant.
IV.
Sealed and Redacted Exhibits
The Government anticipates offering certain exhibits entirely under seal or with redactions
to protect the personal identifying information of witnesses and third parties. With respect to
logistics, the Government would propose submitting redacted versions of exhibits - along with an
index noting which of the Government exhibits will be offered under seal - no later than November
29, 2021. To the extent the defense takes issue with the sealing requests or the proposed redactions,
the Court may rule on those exhibits on case-by-case basis during the trial.
The Government has considered how best to publish sealed exhibits to the jury while
protecting the identities of witnesses and the privacy of third parties. On that score, the
Government is mindful that exhibits published in electronic format on screens in the courtroom
may be seen by the public, since the screens at counsel table - and potentially the jury box- are
visible to the public from certain angles. For this reason, the Government requests permission to
provide jurors with individual binders containing sealed exhibits. The Government expects that
jurors will follow the Court's instruction to only view items in the binder when the Court instructs
jurors to do so.
EFTA00028263

=== Page 5 ===
Page 5
Defense position:
In light of the Court's ruling on the government's motion in limine, the defense will accept
the government's proposed nomenclature for the witnesses referenced above. The defense has no
objection to the procedures proposed by the government for voir dire and for sealing and redacting
exhibits on the understanding that the defense will have the opportunity to object to particular
sealing and redaction requests. The defense also proposes the following limiting instruction in
place of the government's proposed instruction:
This case has received, and will continue to receive, significant attention in the
media. To minimize the inconvenience and potential harassment of any witness, the
Court has permitted witnesses, if they choose, to be referred to by either their first
name or a pseudonym. However, the full names of the witnesses are known to the
Government, the defendant, and to the Court, and were shown to you during jury
selection. This process should not bear in any way on your evaluation of the
evidence in this case.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (By email)
EFTA00028264


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=== Page 1 ===
Event: Jason Mojica Proffer (Ordered) (re Epstein)
Organizer:
Class: X-PERSONAL
Date Created: 2025-11-26 15:56:17 +0000
Date Modified: 2025-11-26 15:56:17 +0000
Priority: 5
D.
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Tue, 13 Aug 2019 16:55:22 +0000
Thanks
- I just tried you, could you call me back? Thanks.
From:
Sent: Tuesday, August 13, 2019 12:19 PM
To:
Cc:
Subject: Epstein
Good afternoon
I hope all is well. I understand the prosecution team has been walled off from the investigation. Do you have access to his
records from his prior incarceration? If not, do you have a contact for his prior facility or the USAO in Florida? I have been
asked to track down certain documentation in reference thereto in relation to the various investigations into the incident
this past weekend.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
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=== Page 1 ===
From:
To:
Cc:
Subject: 19-cr-00830-AT, All Defendants
Date: Sat, 13 Mar 2021 16:53:19 +0000
Attachments: epstein.mp4
Dear investigators,
Came across a purported video of Epstein's suicide (leaked by anonymous source). I attached it, but if your email strips
attachments, you can also download it from Google Drive here:
https://drive.google.com/file/d/1wKRXM8sJ7RujKXWnGfwqyTr-_oOjHAvN/view
Is this real??? There is another version, better quality less choppy (as my re-encoding software seems to have made it
choppy).
I have been documenting a substantial cover-up of a suicide scandal at FDC Miami by both the BOP and also high-level
DOJ officials, so I find it to be a joke that the DOJ is bringing charges in this SDNY case concerning the Epstein suicide while
simultaneously acting to illegally cover up misconduct in other similar cases. I have network of sources and based upon
the information they have provided me, I was able to trace some of the incidents at FDC Miami as follows:
#15412-104 Latitia Houser, Suicide in SHU (hanging), 2018-11-14
#17880-104 Orlando Lorenzo, Attempted Suicide in Unit 8 WEST, approximately August 2019
#17883-104 Pedro Rene Gonzalez, Suicide in SHU (hanging), 2019-08-24
#14325-104 Anibal Mustelier, Suicide in Unit 7 EAST (hanging), 2020-09-18
#00000-000 Suicide/Death Unit 9 EAST approximately Feb 2021 (Inmate name unknown)
#00000-000 Suicide/Death SHU approximately Feb 2021 (Inmate name unknown)
#00000-000 Suicide/Death, Inmates witnessed body being removed in body bag approximately 2 days ago.
There may be other deaths/suicides that I don't know of, but certainly there are numerous other attempted
(unsuccessful) suicides at FDC Miami due to substantial corruption by BOP, DOJ, Court, Prosecutors and Defense
Counsels. In one instance the inmate was found brain dead (but still alive) so they rushed him to a hospital to make sure
he died at the hospital (so that they didn't have to count him as one of the dead at the prison). The situation is so bad
that even as I continue to investigate this matter (while the government instead acts to cover it up), I continue to run
across inmates who express suicidal ideations and still (even with the Attorney General and FBI directly involved in this
investigation) they refuse to place the inmates on suicide watch and are still gambling with their lives. The decision to
gamble with these inmate's lives is not being made by some low-level guards who refused to do their rounds, but rather
by the FBI Director, Attorney General, BOP Director (which are job positions that are subject to "rolling coverup" and thus
even though new individuals are installed into these positions, they are still somehow compelled to cover up crimes of
their predecessors). So there is a unit of the FBI (overseen by the Attorney General) which is conducting a 24/7
surveillance operation over the FDC Miami because of several sensitive cases involving FBI corruption (that they are
fearful will come out) and they are witnessing the suicide epidemic in real-time and even when receiving information
about inmates threatening suicide in real time (through this illegal surveillance operation that they are trying to cover up
its existence), they still let the inmates return to their cells unsupervised and without following protocol to immediately
place them on suicide watch (as is required). And these people are killing themselves and once the FBI is implicated in
prior knowledge of their threats to suicide, they engage cover up immediately (which I have been actively documenting
since 2019).
How does the DOJ explain that?
EFTA00028840

=== Page 2 ===
The DOJ has absolutely no credibility to investigate/prosecute employees of the BOP in SDNY while at the same time in
SDFL, the Attorney General, the FBI Director, SDFL Prosecutors Office are directly obstructing the
investigation/prosecution of an even more serious suicide scandal occurring at FDC Miami for which they are all
responsible together (because they were certainly aware of it when Pedro Gonzalez killed himself a short time after
Epstein). You cannot be credible in New York when you are committing this level of crimes in Florida (on the same exact
category of cases). Furthermore, the very first case I investigated (which started my investigative career) was a BOP
scandal at Rochester Minnesota which occurred from January to May of 1998 concerning the physical abuse of Sheikh
Omar Abdel Rahman by prison guards (in an illegal conspiracy run by directors from Washington DC, ultimately resulting
in the 911 attacks). I think god is trying to tell America that the conditions occurring in the jails are absolutely the best
measure of the moral worth of an entire society. What type of message is America intending to send to the entire
universe when we take people (some of whom commit minor mistakes and can be salvaged) and subject them to torture
to the point they are killing themselves?
Regards,
Younes Ali Kabbaj
FedBOP.com
Lauderhill, FL
Or alternatively I am also known as "Q" from theinvestigation.org
Busting government pedophiles since 1987. Epstein was friend of a friend (although never heard of him until after).
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=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
Subject: FW: Epstein video/autopsy
Date: Thu, 15 Aug 2019 21:14:15 +0000
From:
(NY) (OGA)
Sent: Thursday, August 15, 2019 5:12 PM
To:
;
(OCME)
Cc:
(USANYS)
>;
(OIG)
is
(NY) (FBI)
Subject: Epstein video/autopsy
/
,
It was relayed that either yourself or reps from your office would like to view the surveillance footage on file for
Epstein. The files at this point cannot be viewed outside of FBI space due to software issues. If you would like
to view at 290 Broadway please let me know and I will coordinate.
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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 19-2221 United States of America V. Epstein "Form B FILED"
Date: Mon, 05 Aug 2019 17:11:57 +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 08/05/2019
Case Name:
United States of America V. Epstein
Case Number: 19-2221
Document(s): Document(s)
Docket Text:
FORM B, on behalf of Appellant Jeffrey Epstein, FILED. Service date 08/05/2019 by CM/ECF.[2624204] [19-
2221]
Notice will be electronically mailed to:
Reid Weingarten, -:
ehartman@steptoe.com, ocorn@steptoe.com
Donnell G. Bolden, Deputy Clerk: Donnell_Bolden@ca2.uscourts.gov
Notice will be stored in the notice cart for:
Donnell G. Bolden, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Form B
Original Filename: Form B.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=08/05/2019] [FileNumber=2624204-0]
[2f29e0582a1f209490e952bb31e94fa2093935d249b531cc9047fbaa90b6daf6b5a2b36912776090bac0dc74ac437
253041d67797c9b5945a993cad60e67391b]]
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From:
"
Cc:
Subject: Photos for next GM discovery production
Date: Sun, 22 Aug 2021 18:17:25 +0000
Attachments: 2019-12-13,
_defense_submission_to_us_attorney.pdf
Hi
Hope you are having a nice weekend (and staying dry)! Can you please pull the photographs in the attached document
and include them in the next production? Do not include the photograph of the deposition testimony on page 5.
Thanks,
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From:
)"
To:
)"
(USANYS)"
Subject: FW: Amazon return
Date: Thu, 11 Nov 2021 20:25:52 +0000
Attachments: 2021.11.11_Maxwell_Discovery_Letter.docx
Hey team,
Does one of you mind taking a quick look at the Amazon return? I'm not sure we should mark them as confidential (and,
if so, we should also unmark the letter too).
Thanks,
From: D
USANYS) [Contractor]
Sent: Thursday, November 11, 2021 1:43 PM
To:
)
(USANYS) [Contractor]
Cc:
(USANYS)
Subject: RE: Amazon return
These returns have been stamped here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\Discovery\GM\37 Twenty-Eighth Production
Draft discovery cover letter is attached and saved here for your review.
From:
Sent: Thursday, November 11, 2021 9:46 AM
To:
(USANYS) [Contractor]
USANYS) [Contractor]
Cc:
(USANYS)
)
Subject: RE: Amazon return
Thanks, Sunny! Yes, good to go with this production.
From:
(USANYS) [Contractor]
Sent: Thursday. November 11, 2021 9:29 AM
To:
(USANYS) [Contractor]
Cc:
USANYS)
Subject: RE: Amazon return
I've added it to the pending Rule 16 production and have saved it to the trial subpoena returns folder here:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Trial\Trial Subpoena Returns\Amazon\2021.11.10
Let me know if you want this pending Rule 16 production prepped to go out today with the 3500 and GX (right now the
pending production just has these Amazon returns).
EFTA00027657

=== Page 2 ===
From:
Sent: Wednesday, November 10, 2021 11:09 PM
To:
(USANYS) [Contractor]
(USANYS) [Contractor]
Cc:
USANYS)
Subject: Amazon return
Hey
and
Thanks again for all the help today! When you have a chance, would one of you mind adding this to the next Discovery
folder and to a folder for Amazon subpoena returns?
Thanks!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York. New York 10007
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=== Page 1 ===
Event: Accepted:
Start Date: 2019-06-11 17:00:00 +0000
End Date: 2019-06-11 18:00:00 +0000
Organizer:
(
)
Location: Brass meet re Epstein
Class: X-PERSONAL
Comment:
Date Created: 2019-06-10 17:52:54 +0000
Date Modified: 2019-06-10 17:52:54 +0000
Priority: 5
DTSTAMP: 2019-06-10 17:40:24 +0000
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=== Page 1 ===
Case 9:08-cv-80736-KAM Document 463-3 Entered on FLSD Docket 07/08/2019 Page 1 of 50
1
1
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT
2
IN AND FOR PALM BEACH COUNTY, FLORIDA
CRIMINAL DIVISION
3
4
STATE OF FLORIDA
)
5
)
vs
)
CASE NO. 06 CF9454AMB
6
)
08 9381CFAMB
JEFFREY EPSTEIN
)
7
)
Defendant.
)
8
)
9
PLEA CONFERENCE
10
11
PRESIDING: HONORABLE DEBORAH DALE PUCILLO
12
APPEARANCES:
13
ON BEHALF OF THE STATE:
BARRY E. KRISCHER, ESQUIRE
14
State Attorney
401 North Dixie Highway
15
West Palm Beach, Florida 33401
By: LANNA BELOHLAVEK, ESQUIRE
16
Assistant State Attorney
17
ON BEHALF OF THE DEFENDANT:
ATTERBURY, GOLDBERGER & WEISS, P.A.
18
250 Australian Avenue South
Suite 1400
19
West Palm Beach, Florida 33401
By: JACK GOLDBERGER, ESQUIRE
20
CERTIFIED COPY
21
22
23
June 30, 2008
24
Palm Beach County Courthouse
West Palm Beach, Florida 33401
25
Beginning at 8:40 o'clock, a.m.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027591

=== Page 2 ===
Case 9:08-cv-80736-KAM Document 463-3 Entered on FLSD Docket 07/08/2019 Page 2 of 50
2
1
BE IT REMEMBERED that the following
2
proceedings were had in the above-entitled cause
3
before the HONORABLE DEBORAH DALE PUCILLO, one of
4
the judges of the aforesaid court, at the Palm
5
Beach County Courthouse, located in the City of
6
West Palm Beach, State of Florida on June 20, 2008
7
beginning at 8:40 o'clock, a.m. with appearances
8
as hereinbefore noted, to wit:
9
THEREUPON:
10
MR. GOLDBERGER: Good morning, Judge,
11
Jack Goldberger on behalf of Jeffrey
12
Epstein.
13
THE COURT: Good morning.
14
MR. GOLDBERGER: Your Honor, we are
15
here for a plea conference.
16
THE COURT: Raise your right hand.
17
THEREUPON:
18
JEFFREY EPSTEIN,
19
after being called as a witness by the Defense and
20
after being first duly sworn by the Court, was
21
examined and testified as follows:
22
THE DEFENDANT: Yes, ma'am.
23
THE COURT: Is this one case or two?
24
MS. BELOHLAVEK: Two.
25
THE COURT: May I see the PC
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027592

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1
affidavit in both cases, please?
2
MS. BELOHLAVEK: There are no PC
3
affidavits. There was originally an
4
Indictment, the second charge was filed
5
arising out of the booking. It was all
6
testimony presented to the grand jury.
7
THE COURT: Let me see the Indictment
8
then?
9
I have one Indictment, one
10
Information?
11
MS. BELOHLAVEK: Correct.
12
THE COURT: So one case is charged by
13
Indictment, one is charged by Information?
14
MS. BELOHLAVEK: Correct.
15
THE COURT: In case 2006036744 you
16
are charged with procuring a person under
17
18 for prostitution, a second degree
18
felony, maximum penalty of fifteen years
19
Department of Corrections; minimum, some
20
period of probation. No mandatory minimum
21
apply, is that correct, State?
22
MS. BELOHLAVEK: Correct.
23
THE COURT: And in case number 06
24
9454CF, you are charged with felony
25
solicitation to prostitution, a third
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027593

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1
degree felony, punishable by a maximum
2
penalty of five years in the Department of
3
Corrections, and a minimum, probation. No
4
mandatory minimums, correct?
5
MS. BELOHLAVEK: Correct.
6
THE COURT: The defendant has no
7
prior criminal record?
8
MS. BELOHLAVEK: Correct.
9
MR. GOLDBERGER: Yes, Your Honor.
10
THE COURT: You checked the NCIC as
11
well as State records?
12
MS. BELOHLAVEK: Yes.
13
THE COURT: And the guideline score
14
sheet I have before me shows 21.5 months in
15
the Department of Corrections as the lowest
16
permissible prison sentence in months.
17
Both sides agree to the preparation of the
18
guideline score sheet?
19
MR. GOLDBERGER: We so agree, Your
20
Honor.
21
MS. BELOHLAVEK: Yes.
22
THE COURT: What is proposed -- it
23
goes on for pages.
24
MR. GOLDBERGER: Your Honor, much of
25
the documentation is acknowledgement by my
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027594

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1
client to community control, sex offender
2
status.
3
THE COURT: I understand.
4
Okay. What is proposed -- those
5
are the maximums and minimums, Mr. Epstein.
6
What is proposed is that you will be
7
pleading guilty to felony solicitation to
8
prostitution and procuring a person under
9
18 for prosecution. A PSI would be waived,
10
you would be adjudicated guilty of both
11
felonies, is that correct?
12
MS. BELOHLAVEK: Correct.
13
THE COURT: And on 06 9454, the
14
defendant to be sentenced to 12-months in
15
the Palm Beach County -- detention
16
facility? He's going to do time in the
17
jail?
18
MS. BELOHLAVEK: Yes.
19
THE COURT: With credit for one day
20
served. And on 08 9381, he is to be
21
sentenced to six months in the Palm Beach
22
County jail detention facility, with credit
23
for one day served. And the six month
24
sentence is to be served consecutive to the
25
12 month sentence?
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027595

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1
MS. BELOHLAVEK: Correct
2
THE COURT: Following the six months
3
sentence, the defendant will be placed on
4
12-months of community control one. The
5
conditions of the community control are
6
attached hereto and incorporated herein.
7
As a special condition of
8
community control, he's to have no
9
unsupervised contact with minors and the
10
supervising adult must be approved -- and I
11
would say, pre-approved, approved ahead of
12
time, not after the fact by the Department
13
of Corrections. And you would mean by that
14
his community control officer?
15
MS. BELOHLAVEK: Correct.
16
THE COURT: The defendant is
17
designated as a sexual offender pursuant to
18
Florida Statute 943.0435. and must abide by
19
all the corresponding requirements of the
20
statute, a copy of which is attached hereto
21
and incorporated herein. The defendant
22
must provide a DNA sample in court at the
23
time of this plea. Is this the -- and the
24
attachments are the terms and conditions of
25
community control. There are some
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027596

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1
squiggles on the bottom of the page, what
2
would those squiggles be?
3
MR. GOLDBERGER: Thank you, Your
4
Honor, those are my client's signature
5
acknowledging that we have gone over all
6
the conditions.
7
THE COURT: One page after the plea
8
sheet that really spells out the terms and
9
conditions of community control, Florida
10
Statute 948.101, Mr. Epstein, is that
11
squiggle at the bottom your squiggle?
12
THE DEFENDANT: Yes, ma'am.
13
THE COURT: Would those be your
14
initials?
15
THE DEFENDANT: Yes, ma'am.
16
THE COURT: Did you read all of that
17
page?
18
THE DEFENDANT: Yes, ma'am.
19
THE COURT: Can you read?
20
THE DEFENDANT: Yes, ma'am.
21
THE COURT: How far did you go in
22
school?
23
THE DEFENDANT: High school.
24
THE COURT: That's your highest
25
degree?
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027597

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1
THE DEFENDANT: Yes.
2
THE COURT: And is this your
3
signature on the plea sheet that recites
4
the terms of the plea I just read?
5
THE DEFENDANT: Yes, ma'am.
6
THE COURT: Did you read that
7
document as well?
8
THE DEFENDANT: Yes, ma'am.
9
THE COURT: You understand once you
10
do your 12 months followed by your six
11
months all in the Palm Beach County jail
12
you will then be put on community control
13
which involves having an electronic monitor
14
attached to you and --
15
MR. GOLDBERGER: Actually Your Honor,
16
the agreement of the parties is to, it!s
17
community control one which is not monitor.
18
THE COURT: Oh, community control
19
one, is that spelled out in here?
20
MS. BELOHLAVEK: Yes.
21
MR. GOLDBERGER: Yes, it is, Your
22
Honor.
23
MS. BELOHLAVEK: He does not fall
24
under the Jessica Lunsford Act which
25
requires the bracelet.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027598

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1
THE COURT: Community control two.
2
MS. BELOHLAVEK: Correct.
3
THE COURT: Community control one --
4
that would be no electronic monitor?
5
MR. GOLDBERGER: That is correct.
6
THE COURT: Now which of the terms
7
and conditions of community control one are
8
you incorporating?
9
MR. GOLDBERGER: I can go through
10
them with Your Honor.
11
THE COURT: None of the them appear
12
to be articulated in the plea sheet which
13
is why I'm asking.
14
MR. GOLDBERGER: These are the
15
standard conditions of community control by
16
statute would apply to anyone that goes on
17
community control and out of an abundance
18
of caution, we simply memorialized those
19
standard conditions in the plea sheet
20
agreement.
21
THE COURT: The Court shall require
22
intensive supervision and surveillance for
23
an offender placed on community control
24
which may include but is not limited to
25
specified contact with the parole and
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027599

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1
probation officer, specified by who?
2
PROBATION OFFICER: Specified by you,
3
Your Honor.
4
THE COURT: I don't see that in the
5
plea sheet. That's why I'm asking the
6
questions. No one has specified how often,
7
how frequently he is to have contact with
8
his parole and probation officer.
9
Confinement to an agreed upon residence
10
during the hours away from employment and
11
public service activity, has that been
12
articulated?
13
MS. BELOHLAVEK: I believe
14
Judge McSorley has a standard order
15
somewhere on the bench up there regarding
16
this, I'm told by the prosecutor.
17
MS. LENHARDT: Judge, usually this is
18
the probation sheet she hands out to folks.
19
THE COURT: I have seen those
20
sheets -- I have seen them incorporated in
21
plea agreements which is why I'm asking.
22
MR. GOLDBERGER: I see.
23
THE COURT: Is there some reason you
24
didn't use this particular document in this
25
case?
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027600

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1
MS. BELOHLAVEK: I didn't realize
2
until Ms. Lenhardt just told me that Judge
3
McSorley has that.
4
MR. GOLDBERGER: We'd be happy to
5
execute that document, Your Honor. We were
6
:
we overreacted by just having him sign
7
off on all conditions of community control.
8
THE COURT: Well, this is --
9
MR. GOLDBERGER: Perhaps the better
10
practice would be --
11
THE COURT: This is, the reason
12
Judge McSorley does this which makes
13
ultimate sense is we're going to be here
14
half the morning if we're going to decide
15
among ourselves now what the --
16
MR. GOLDBERGER: That makes sense.
17
THE COURT: I'm not going to leave
18
this just unspecified.
19
MS. BELOHLAVEK: We can take care of
20
that right now if you could give us a few
21
minutes.
22
THE COURT: All right.
23
These are the standard conditions
24
that Judge McSorley normally uses. If you
25
like them, you need to circle the ones that
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027601

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12
1
apply and everyone must initial them. We
2
will go over it. If you wish to change --
3
you understand there is quite a bit of
4
latitude given the court in putting
5
somebody on community control. If you
6
agree to some change, let me know, but
7
understand at the outset that I'm a big fan
8
of specificity. I want to know what he
9
will be doing for employment. I want to
10
know exactly where he is going to be living
11
and I want it on the record now. It can
12
change but it can only change with
13
preapproval by DOC. I want it crystal
14
clear. I don't want the community control
15
officer who gets this case the day he walks
16
out the Palm Beach County to have any doubt
17
or confusion as to exactly what this
18
defendant is supposed to do, where he is
19
supposed to be when, exactly what I am
20
requesting that officer to supervise.
21
MS. BELOHLAVEK: Absolutely.
22
THE COURT: Okay.
23
MR. GOLDBERGER: We will work on it.
24
Thank you, Your Honor.
25
THE COURT: We will recall that case.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027602

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13
1
(Brief recess.)
2
MR. GOLDBERGER: Your Honor, we are
3
back on Jeffrey Epstein, actually it
4
worked, we had an opportunity to go through
5
Judge McSorley's conditions of community
6
control and we asked the Department of
7
Corrections representative to assist us to
8
make sure we did everything properly.
9
They were very helpful and we executed the
10
document.
11
MS. BELOHLAVEK: Yes, and Your Honor,
12
this defendant doesn't fall under the sex
13
offender probation but we have included
14
special sex offender conditions as part of
15
the community control and they are all
16
circled there.
17
THE COURT: The plea agreement stated
18
the defendant is designated as a sexual
19
offender pursuant to Florida Statute
20
942.035.
21
MS. BELOHLAVEK: Correct. But the
22
sex offender probation, the statute is
23
different and only applies to certain
24
offenses and this one was not enumerated.
25
THE COURT: Okay. I want to make
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027603

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14
1
sure both I and the defendant are clear.
2
The sexual offender statute you are
3
referring to in the plea sheet is the one
4
that requires registration?
5
MS. BELOHLAVEK: Correct.
6
MR. GOLDBERGER: Correct.
7
THE COURT: And we will talk about
8
that.
9
MR. GOLDBERGER: Okay.
10
THE COURT: But it is not the one
11
that requires the special conditions of sex
12
offender probation?
13
MS. BELOHLAVEK: Correct.
14
THE COURT: Now, rather than 948, do
15
you want me to disregard 948? He's read
16
it?
17
MS. BELOHLAVEK: He's read it.
18
THE COURT: We will leave it in
19
there. But these conditions we are going
20
to go over right now are going to be viewed
21
in my mind, yes, and they have been signed
22
by the defendant and we will go over that
23
in a second as a part of the whole plea.
24
MS. BELOHLAVEK: Correct.
25
THE COURT: So circled are
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
conditions, A, you will remain confined to
2
your residence except one half hour before
3
and after your approved employment,
4
community service work or any other
5
activity approved by your probation
6
officer.
7
B, you will maintain an hourly
8
accounting of all your activities on a
9
daily log which you will submit to your
10
supervising officer upon request.
11
My understanding about the daily
12
log, maybe I'm just confused from other
13
cases I've heard, is the daily log is a
14
weekly log, I guess it is submitted ahead
15
of time, is that correct?
16
PROBATION OFFICER: That is correct,
17
Your Honor.
18
THE COURT: So part A, where he has
19
to stay in his residence except for one
20
hour before and after the approved
21
employment, community service work and
22
other activity. All that's information
23
that will be recorded in writing and the
24
defendant will have a copy and he will know
25
exactly where he is supposed to be when.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027605

=== Page 16 ===
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16
1
PROBATION OFFICER: That is correct,
2
Your Honor.
3
THE COURT: As will his supervising
4
probation officer. And then to document
5
that he's supposedly done all that he
6
himself will be keeping a daily log?
7
PROBATION OFFICER: That is correct,
8
Your Honor.
9
THE COURT: And the log form will be
10
provided by the department and he will be
11
turning that in every time he meets with
12
the probation officer?
13
PROBATION OFFICER: That is correct,
14
Your Honor.
15
THE COURT: Okay. So that applies
16
and F applies. Does E apply? No.
17
MS. BELOHLAVEK: Did I circle E?
18
THE COURT: No. F -- made one up,
19
the defendant will be residing at 358 El
20
Brillo Way, Palm Beach, Florida, 33480. He
21
knows now that that's where he will be
22
living when he is released after his 12
23
months and six months.
24
MR. GOLDBERGER: That is correct,
25
Your Honor.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027606

=== Page 17 ===
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1
THE COURT: That's a private
2
residence?
3
MR. GOLDBERGER: That is his home.
4
THE COURT: Does he own the
5
residence?
6
MR. GOLDBERGER: He does, Your Honor.
7
THE COURT: Is there any possibility
8
that he no longer owns the residence?
9
MR. GOLDBERGER: Not anticipated,
10
Your Honor.
11
THE COURT: Okay. Should he not be
12
for whatever reason -- 18-months is a long
13
time, should he not be owning that
14
residence or able to reside there, he will
15
have the obligation of notifying his
16
probation officer prior, and I emphasize
17
this, prior to his release from custody. I
18
assume that the department will be notified
19
prior to, to his release?
20
PROBATION OFFICER: That is correct,
21
Your Honor.
22
THE COURT: And then you would need
23
to send someone to meet with him before he
24
walks out of the Palm Beach County jail and
25
verify his address and employment
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027607

=== Page 18 ===
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18
1
information?
2
PROBATION OFFICER: That is correct.
3
THE COURT: All address -- I assume
4
all of this to and from work and any other
5
approved activities restricts him to Palm
6
Beach County, is that correct?
7
PROBATION OFFICER: That is correct,
8
Your Honor.
9
THE COURT: So let's be clear,
10
everything, from the day he walks out
11
occurs in Palm Beach County, is that clear?
12
MR. GOLDBERGER: We understand, Your
13
Honor. That's correct.
14
THE COURT: Then the additional
15
condition of his probation, they are not
16
sex offender standard conditions, they are
17
just conditions that are being imposed
18
especially in this case?
19
MS. BELOHLAVEK: Correct.
20
THE COURT: They are as follows, you
21
shall submit to a mandatory curfew from 10
22
p.m. to 6:00 a.m. regardless of any other
23
restrictions regarding work or approved
24
activity, there will be no exceptions to
25
being at home in house from 10 p.m. to 6
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027608

=== Page 19 ===
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1
a.m., is that correct?
2
MS. BELOHLAVEK: Yes.
3
THE COURT: If the victim was under
4
age of 18 years which I gather is the case
5
because it's circled, you shall not live
6
within 1000 feet of a school, day care
7
center, park, playground or other place
8
where children regularly congregate.
9
Has someone verified that 358 El
10
Brillo is such a place?
11
MS. BELOHLAVEK: No, but that will be
12
done prior to his release.
13
THE COURT: So 358 El Brillo will not
14
be approved if it should happen to be one
15
thousand feet from a school, day care
16
center, park, playground or other place --
17
this is rather open.
18
MR. GOLDBERGER: Where children
19
gather.
20
THE COURT: Where children regularly
21
congregate.
22
MS. BELOHLAVEK: Right.
23
THE COURT: The Court knows 358 El
24
Brillo Way is a residential neighborhood,
25
are there areas there where children
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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20
1
regularly congregate?
2
MS. BELOHLAVEK: I personally do not
3
know.
4
THE COURT: Neither do I, which is
5
why I'm asking. Has that been
6
investigated?
7
MR. GOLDBERGER: We have done our due
8
diligence, for what it's worth, there is a
9
residential street. There are not children
10
congregating on that street. We think the
11
address applies, if it doesn't, we fully
12
recognize that he can't live there.
13
THE COURT: Okay. D is, you shall
14
not have any contact with the victim, are
15
there more than one victim?
16
MS. BELOHLAVEK: There's several.
17
THE COURT: Several, all of the
18
victims. So this should be plural. I'm
19
making that plural. You are not to have
20
any contact direct or indirect, and in this
21
day and age I find it necessary to go over
22
exactly what we mean by indirect. By
23
indirect, we mean no text messages, no
24
e-mail, no Face Book, no My Space, no
25
telephone calls, no voice mails, no
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027610

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1
messages through carrier pigeon, no
2
messages through third parties, no hey
3
would you tell so and so for me, no having
4
a friend, acquaintance or stranger approach
5
any of these victims with a message of any
6
sort from you, is that clear?
7
THE DEFENDANT: Yes, ma'am
8
THE COURT: And then it states,
9
unless approved by the victim, the
10
therapist and the sentencing court. Okay.
11
THE DEFENDANT: I understand.
12
THE COURT: And the sentencing court.
13
So, if there is a desire which, I would
14
think would be a bit strange to have
15
contact with any of the victims the court
16
must approve it.
17
MS. BELOHLAVEK: Correct.
18
THE COURT: If the victim was under
19
the age of 18, which was the case, you
20
shall not until you have successfully
21
attended and completed the sex offender
22
program. So, is this sex offender program
23
becoming a condition of probation?
24
MS. BELOHLAVEK: That is not. I
25
don't believe I circled that one.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027611

=== Page 22 ===
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1
THE COURT: You did.
2
MR. GOLDBERGER: That's a mistake on
3
our part. Actually the statute that he is
4
pleading guilty to does not require the --
5
THE COURT: I understand that, but
6
you circled it.
7
MS. BELOHLAVEK: I apologize, that
8
one is not. He has already been in
9
treatment with a private psychiatrist.
10
THE COURT: Which you find to be an
11
adequate substitute for sex offender
12
program?
13
MS. BELOHLAVEK: I -- it is not
14
required and based upon the evaluation and
15
my contact with that doctor, I don't
16
believe it's necessary at this point.
17
THE COURT: Has that been -- I assume
18
you have a law degree and do not have a
19
Ph.D in a psychology or MD in psychiatry?
20
MS. BELOHLAVEK: That is correct, I
21
don't.
22
THE COURT: So it is just your
23
judgement --
24
MS. BELOHLAVEK: Correct.
25
THE COURT: -- that his treatment
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027612

=== Page 23 ===
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1
with some fancy private psychiatrist or
2
psychologist in his case is okay?
3
MS. BELOHLAVEK: That is correct.
4
THE COURT: So you are not imposing
5
E?
6
MS. BELOHLAVEK: Correct.
7
THE COURT: F, if the victim was
8
under the age of 18, you shall not work or
9
play or as a volunteer in any school, day
10
care center, park, play ground or other
11
place where children regularly congregate,
12
is that understood?
13
THE DEFENDANT: Yes, ma'am.
14
THE COURT: Children will be defined
15
as anyone under the age of 18. There are a
16
lot of places where children regularly
17
congregate. What kind of work do you do?
18
THE DEFENDANT: Banking.
19
THE COURT: Here in Palm Beach
20
County?
21
THE DEFENDANT: Virgin Islands,
22
ma'am.
23
THE COURT: You understand you will
24
not travel from Palm Beach County for the
25
duration of this?
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1
THE DEFENDANT: Yes, ma'am.
2
MR. GOLDBERGER: Your Honor, I'm
3
sorry to interrupt, we do cover the
4
employment later in the agreement as to
5
what he is going to be doing during the one
6
year that he is on community control.
7
THE COURT: Okay. And let me --
8
condition G, which is circled, unless
9
otherwise indicated in the treatment plan
10
provided by sexual offender treatment
11
program.
12
MR. GOLDBERGER: That's not in there.
13
THE COURT: Is that what you want?
14
MS. BELOHLAVEK: No.
15
THE COURT: But you do want the, you
16
will not view, own or possess any obscene
17
pornographic --
18
MS. BELOHLAVEK: Correct.
19
THE COURT: Okay. But are you saying
20
that this therapist can okay him to own
21
certain pornographic material?
22
MS. BELOHLAVEK: No, not at all.
23
MR. GOLDBERGER: No, Your Honor.
24
THE COURT: Would be really helpful
25
if people read these things before they
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
signed them thoroughly.
2
Unless otherwise indicated in the
3
treatment plan. I'm just going to strike
4
out, provided by the sexual offender
5
treatment program. Is that what you
6
intend, that his therapist can --
7
MS. BELOHLAVEK: No.
8
THE COURT: No?
9
MS. BELOHLAVEK: No.
10
THE COURT: Unless otherwise
11
indicated.
12
MR. GOLDBERGER: The parties have
13
agreed that during the period that he is --
14
cannot be --
15
THE COURT: Condition G will now
16
read, you shall not view, own, possess any
17
obscene, pornographic or sexually
18
stimulating visual or auditory material
19
including telephonic, electronic media,
20
computer program or computer services that
21
are relevant to your deviant behavior
22
pattern. And who is going to enforce that?
23
MS. BELOHLAVEK: The community
24
control officer.
25
THE COURT: How?
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1
MS. BELOHLAVEK: They have the
2
obligation and included in there for
3
warrantless search to check at any time his
4
home, his computer, anything he has contact
5
with.
6
THE COURT: And do they regularly do
7
that?
8
PROBATION OFFICER: Yes, ma'am.
9
THE COURT: Since we have the
10
pleasure of having someone from the
11
Department of Corrections here.
12
Okay. H, you shall submit two
13
specimens of blood to the Florida
14
Department of Law Enforcement to be
15
registered in the DNA data bank.
16
J, you shall submit to a
17
warrantless search by your probation
18
officer or community control officer of
19
your person, residence or vehicle.
20
G -- where is the G?
21
MS. BELOHLAVEK: That was under the
22
original part, not under the sex offender
23
one.
24
THE COURT: Okay. Defendant to have
25
contact with the community control officer
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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at a minimum one time a week.
2
Defendant to work at Florida
3
Science Foundation, 250 Australian Avenue,
4
West Palm Beach, Florida. Is that
5
volunteer work or work for pay?
6
MR. GOLDBERGER: It is a 501C
7
corporation that he has formed, Your Honor,
8
that will be doing charitable work.
9
THE COURT: That he has formed?
10
MR. GOLDBERGER: Yes.
11
THE COURT: What exactly is Florida
12
Science Foundation?
13
MR. GOLDBERGER: Do you want to
14
explain?
15
THE DEFENDANT: It funds science
16
programs around the state and the country.
17
THE COURT: How long has it been in
18
existence?
19
THE DEFENDANT: Fifteen years.
20
THE COURT: How many programs has it
21
funded?
22
THE DEFENDANT: Numerous, more than
23
50.
24
THE COURT: What is your position
25
with the organization?
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THE DEFENDANT: President.
2
THE COURT: Is there a board of
3
directors?
4
THE DEFENDANT: Yes, ma'am.
5
THE COURT: Who's on the board of
6
directors?
7
THE DEFENDANT: Two attorneys.
8
THE COURT: What exactly do you do?
9
THE DEFENDANT: I'm an investment
10
banker but my --
11
THE COURT: No, no, I mean with the
12
science foundation.
13
THE DEFENDANT: We fund
14
science programs --
15
THE COURT: I don't want to know what
16
we do, I want to know what you do. How
17
often are you there?
18
THE DEFENDANT: I'm there every day,
19
I research, I take in people who want to
20
make presentations about why they need
21
money for funding medical research,
22
advanced science research. My background
23
is in physics. I go through all the
24
programs in detail, review the science work
25
potentials, I follow through on a daily
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
basis with what they have been given money
2
to do.
3
THE COURT: Who are some recent
4
grantees?
5
THE DEFENDANT: Harvard University.
6
There is a full program of Evolutionary
7
Dynamics, Neuro Science Institute of
8
California, the Physics Institute, MIT.
9
THE COURT: Do you ever have occasion
10
to deal with anyone under the age of
11
eighteen?
12
THE DEFENDANT: Not very often. It
13
is, if someone is in college -- sorry.
14
THE COURT: Right, that's why I'm
15
asking the question.
16
THE DEFENDANT: Most of the people I
17
fund are all usually professors.
18
THE COURT: Thank you. You
19
understand that you can't have contact with
20
anyone if -- this organization, do they
21
ever have any involvement with high
22
schools?
23
THE DEFENDANT: No, ma'am.
24
THE COURT: Students or teachers?
25
THE DEFENDANT: No, ma'am.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
THE COURT: Okay.
2
MS. BELOHLAVEK: Those are
3
duplicates, you will see those are the same
4
as the ones on the previous page, however,
5
it was reproduced.
6
THE COURT: The next condition, you
7
shall maintain a driving log. You shall
8
not drive a motor vehicle while alone
9
without prior approval of your supervising
10
officer.
11
If there was sexual contact, you
12
shall submit to at probationer's or
13
community controllee's expense an HIV test
14
with results to be released to the victims,
15
victim's parent or guardian -- will be
16
victims, plural. Has that been done?
17
MR. GOLDBERGER: Not yet.
18
THE COURT: Do we have a time frame
19
on that? I would think ASAP might be good
20
on something like that.
21
MS. BELOHLAVEK: I believe they can
22
actually do that at the jail.
23
THE COURT: At his expense?
24
MS. BELOHLAVEK: Yes.
25
THE COURT: I would request that that
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1
be done within 48 hours?
2
You shall not obtain or use a post
3
office box without prior approval of the
4
supervising officer.
5
Okay. Are all those conditions
6
you two have agreed to?
7
MS. BELOHLAVEK: Yes, Your Honor.
8
MR. GOLDBERGER: With the court's
9
amendments, yes.
10
THE COURT: Mr. Epstein, do you
11
understand?
12
THE DEFENDANT: Yes, ma'am.
13
THE COURT: I need the defendant to
14
sign number D where I had an S added to
15
victim, and G, we struck out the otherwise
16
indicated language. Otherwise, it is as
17
you agreed.
18
Mr. Epstein, do you understand
19
this is a somewhat complicated terms of the
20
plea that you've agreed to?
21
THE DEFENDANT: Yes, ma'am
22
THE COURT: Do you have any questions
23
about the terms of the plea?
24
THE DEFENDANT: No.
25
THE COURT: Can I ask the State why
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
you choose -- or defense and the State
2
together, why twelve months in the Palm
3
Beach County jail followed by six months?
4
Why not just send him to DOC?
5
MR. GOLDBERGER: It was the agreement
6
of the parties, Your Honor. We just
7
decided that was the best way to accomplish
8
what needed to be done here and the parties
9
agreed that that sentence satisfied
10
everyone's requirements.
11
THE COURT: The taxpayers of Palm
12
Beach County is going to pay 18 months to
13
house this guy instead of DOC?
14
MS. BELOHLAVEK: Right.
15
THE COURT: You understand we're
16
losing positions left and right in county
17
government because we haven't got enough
18
money but you want -- okay.
19
His requirement to register there
20
is many, many -- there is nine pages
21
outlining the sexual offender's requirement
22
to register with the department and
23
penalty, have you read all those,
24
Mr. Epstein?
25
THE DEFENDANT: Yes, ma'am.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
THE COURT: Do you understand you
2
will be required to register and this will
3
be an ongoing life long obligation?
4
THE DEFENDANT: Yes, ma'am.
5
THE COURT: And this registration
6
occurs when?
7
MS. BELOHLAVEK: Within 48-hours of
8
release.
9
THE COURT: So when he gets out of
10
the Palm Beach County jail, he needs to
11
register? Okay. And the department -- who
12
is going to provide him with the form?
13
MR. GOLDBERGER: He actually
14
registers out at the Sheriff's Office, Your
15
Honor, we can do it out there.
16
THE COURT: Okay. It has been
17
brought to my attention that FDLE is the
18
one who is statutorily required to handle
19
these registrations but some of our
20
municipal jurisdictions have taken it upon
21
themselves to impose additional
22
requirements, y'all understand that?
23
MS. BELOHLAVEK: Correct.
24
MR. GOLDBERGER: Right.
25
THE COURT: What you are telling him
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
he has to do is the official State of
2
Florida registration?
3
MS. BELOHLAVEK: Correct.
4
THE COURT: Mr. Epstein, I need to
5
make sure you understand that that's what's
6
required by this plea. Anyone on
7
probation, community control is required to
8
live and abide by the laws. So if a
9
jurisdiction you choose to reside in should
10
have some additional municipal requirements
11
you will be required in order to comply
12
with the law of living there, just like you
13
can't get a parking ticket or speeding
14
ticket, to comply with those regulations
15
but I want to make sure you understand
16
because I have seen some defendants who
17
have been confused about this. If you
18
don't, for example, if the Town of Palm
19
Beach has you register that does not take
20
care of your requirement. Your requirement
21
to register with FDLE through the Sheriff's
22
office is separate, distinct and must be
23
done on their form according to their
24
schedule.
25
THE DEFENDANT: Yes, ma'am.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
THE COURT: And if my experience the
2
last few months is of any value, they are
3
very serious about enforcing this. They
4
will be tracking you for the rest of your
5
life. Do not move. Do not go -- I don't
6
care when you are done with community
7
control, they need to know exactly where
8
you are and if you go anywhere without
9
registering, they will find and you will be
10
locked up.
11
THE DEFENDANT: Yes, ma'am.
12
THE COURT: Okay. Any questions
13
about that?
14
THE DEFENDANT: No, ma'am.
15
THE COURT: Did you read the plea in
16
the circuit court form that describes all
17
the rights you are giving up by entering
18
this plea?
19
THE DEFENDANT: Yes, ma'am.
20
THE COURT: I think I asked you
21
before, can you read?
22
THE DEFENDANT: Yes.
23
THE COURT: Are you under the
24
influence of alcohol, drugs or medication
25
today?
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
THE DEFENDANT: No, ma'am.
2
THE COURT: Normally taking any
3
prescribed medication?
4
THE DEFENDANT: Only for cholesterol.
5
THE COURT: Does that interfere with
6
your mental ability?
7
THE DEFENDANT: No.
8
THE COURT: Do you understand you
9
have an attorney, you have a right to trial
10
by jury, there is not going to be a jury
11
trial. There won't be witnesses called.
12
That your attorney and you would have a
13
right to confront and cross examine, do you
14
understand you have a right to call
15
witnesses of your own and the court would
16
issue subpoenas to compel their attendance
17
just like any other witness called by the
18
State, that you have the right -- absolute
19
right to remain silent and that you would
20
not have to say or do anything at the trial
21
if there were a trial, do you understand
22
those rights?
23
THE DEFENDANT: Yes, ma'am.
24
THE COURT: Do you understand if you
25
are not a United States citizen your plea
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
could subject you to deportation pursuant
2
to the laws and regulations governing the
3
United States Immigration and
4
Naturalization Service and this court has
5
no jurisdiction or authority in such
6
matters, do you understand that?
7
THE DEFENDANT: Yes.
8
THE COURT: Has anybody threatened
9
you, coerced you or promised you anything
10
other than the terms of this plea to get
11
you to enter this plea?
12
THE DEFENDANT: No.
13
THE COURT: Do you understand this is
14
a plea in criminal court?
15
THE DEFENDANT: Yes, ma'am.
16
THE COURT: This has -- in criminal
17
court in Palm Beach County, State of
18
Florida. I have absolutely nothing to do
19
with any civil matters or matters in any
20
other jurisdiction, do you understand that?
21
THE DEFENDANT: Yes, ma'am.
22
THE COURT: Is this plea in any way
23
tied to any promises or representations by
24
any civil attorneys or other jurisdictions?
25
MR. GOLDBERGER: May we come sidebar
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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=== Page 38 ===
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1
on that, Your Honor?
2
THE COURT: It is going to be
3
recorded.
4
MR. GOLDBERGER: That's fine.
5
THE COURT: Defendant needs to
6
approach as well.
7
(Whereupon, there was a conference at
8
the bench. )
9
MR. GOLDBERGER: The reason why I
10
asked to come sidebar, there is a
11
nonprosecution agreement with the United
12
States Attorney's office that triggers as a
13
result of this plea agreement. In other
14
words, they have signed off and said they
15
will not prosecute Mr. Epstein in the
16
Southern District of Florida for any
17
offense upon his successful taking of this
18
plea today. That is a confidential
19
document that the parties have agreed to.
20
Just in an abundance of caution, I wanted
21
to tell the court.
22
THE COURT: I understand, that would
23
also be invalidated should he violate his
24
community control?
25
MR. GOLDBERGER: Absolutely. That
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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39
1
nonprosecution agreement --
2
MS. BELOHLAVEK: They spell all that
3
out.
4
THE COURT: Mr. Epstein needs to come
5
closer.
6
Mr. Epstein, your attorney has
7
told me that in addition to everything, we
8
talked about another Inducement, shall we
9
say, to your taking this plea is that the
10
U.S. Attorney for the Southern District of
11
the State of Florida, federal prosecutor,
12
has agreed to a nonprosecution agreement
13
with you, meaning that if you successfully
14
complete probation and do everything you're
15
supposed to, they have, have agreed not to
16
prosecute you federally, did you understand
17
that?
18
THE DEFENDANT: Yes, ma'am.
19
THE COURT: And I would view that as
20
a significant inducement in accepting this
21
plea.
22
MS. BELOHLAVEK: They are actually in
23
court here today, also.
24
THE COURT: Okay.
25
MR. GOLDBERGER: And the plea
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
agreement very carefully spelled out if
2
there was a breach that would violate this
3
agreement, so we are well aware of it.
4
THE COURT: Okay. I would request
5
that a sealed copy of that -- Mr. Epstein
6
has signed that document?
7
MR. GOLDBERGER: Yes, I would like to
8
seal the copy.
9
THE COURT: I want a sealed copy of
10
that filed in this case. That is the only
11
other condition of the agreement that is
12
influencing this defendant to make this
13
decision?
14
MR. GOLDBERGER: Absolutely. I think
15
that's the right idea.
16
(Return to open court.)
17
THE COURT: Mr. Epstein, is there
18
anything else?
19
THE DEFENDANT: No, ma'am.
20
THE COURT: Because I don't take
21
these pleas unless they are freely and
22
voluntarily made.
23
THE DEFENDANT: I understand that.
24
THE COURT: I also don't want
25
somebody or anybody coming back a year,
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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41
1
two years from now saying, oh no, no, they
2
beat me over the head or if there is
3
anything else that is influencing you to
4
make this decision, then I need to know
5
about it.
6
THE DEFENDANT: I understand that.
7
MR. GOLDBERGER: Thank you.
8
THE DEFENDANT: Thank you very much,
9
Your Honor.
10
(Return to open court.)
11
THE COURT: All right, Mr. Epstein,
12
any questions about the rights you are
13
giving up by entering this plea?
14
THE DEFENDANT: No ma'am.
15
THE COURT: State, please give me a
16
factual basis.
17
MS. BELOHLAVEK: In 069454 CF AMB,
18
between August 1, 2004 and October 31,
19
2005, the defendant in Palm Beach County
20
did solicit or procure someone to commit
21
prosecution on three or more occasions.
22
And in 08 CF 9381 CF AMB between
23
August 1, 2004 and October 9, 2005, the
24
defendant did procure a minor under the age
25
of 18 to commit prostitution in Palm Beach
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
County also.
2
THE COURT: I find a sufficient
3
factual basis to support the pleas.
4
Are all of the victims in both of
5
these cases in agreement with the terms of
6
this plea?
7
MS. BELOHLAVEK: I have spoken to
8
several myself and I have spoken to
9
counsel, through counsel as to the other
10
victim, and I believe, yes.
11
THE COURT: And with regard to the
12
victims under age eighteen, is that
13
victim's parents or guardian in agreement
14
with the plea?
15
MS. BELOHLAVEK: That victim is not
16
under age 18 any more and that's why we
17
spoke with her counsel.
18
THE COURT: And she is in agreement
19
with the plea?
20
MS. BELOHLAVEK: Yes.
21
THE COURT: And community control
22
will be given information concerning how to
23
contact these victims?
24
MS. BELOHLAVEK: Yes.
25
THE COURT: Confidentially. That
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
information will not be related to the
2
defendant but will be used exclusively for
3
purposes of verifying compliance with this
4
agreement?
5
MS. BELOHLAVEK: Yes.
6
THE COURT: Is there anything else
7
from anybody else before I accept this
8
plea?
9
MR. GOLDBERGER: No, Your Honor.
10
THE COURT: Mr. Goldberger, if it is
11
your desire, you may enter your client's
12
plea.
13
MR. GOLDBERGER: Thank you, Your
14
Honor, at this time we would withdraw our
15
previously entered pleas of not guilty,
16
enter pleas of guilty pursuant to
17
negotiations with the State.
18
THE COURT: Mr. Epstein, I am going
19
to accept those pleas on your behalf. I
20
find you are intelligent, alert, you
21
understand what is going on here and the
22
consequence of entering this plea, you are
23
doing it freely and voluntarily.
24
Pursuant to the plea, I am waiving
25
a PSI, I will sentence you at this time
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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1
pursuant to it. I will adjudicate you
2
guilty of felony solicitation of
3
prostitution, a third degree felony, case
4
number 06 CF 00945A -- 454 AMB, and
5
procuring a person under 18 for
6
prostitution, a second degree felony 08 CF
7
009381AMB.
8
With respect to the solicitation
9
of prosecution, I will sentence you to
10
twelve months in the Palm Beach County
11
detention facility with credit for the one
12
day served.
13
With respect to 08 CF 009381, I
14
will sentence you to six months in the Palm
15
Beach County detention facility, with
16
credit for the one day served. That six
17
month sentence is to be served consecutive
18
to the twelve month sentence.
19
Following the six month sentence
20
you will be placed on 12 months of
21
community control. That will be on both
22
cases, I assume, to run concurrently,
23
correct?
24
MS. BELOHLAVEK: Only on the 08 case.
25
THE COURT: Only on the second degree
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027634

=== Page 45 ===
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50
1
felony?
2
MS. BELOHLAVEK: Correct, the one
3
that designates him a sexual offender.
4
THE COURT: Okay. So only on case
5
number 08 CF 009381AMB will you be on one
6
year community control which would then
7
invoke a potential penalty of fifteen years
8
were you to violate.
9
The special conditions are that
10
you are to have no unsupervised contact
11
with minors and the supervising adult must
12
be approved by the Department of
13
Corrections. You are to be designated a
14
sexual offender pursuant to Florida Statute
15
943.0435 and you must abide by all
16
requirements of that statute which I have
17
read and we have discussed.
18
You will remain confined to your
19
residence except one half hour before and
20
after your approved employment, community
21
service work or other activities approved
22
by your probation officer. You will
23
maintain an hourly accounting of all your
24
activity on a daily log which you submit to
25
the supervising officer upon request.
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027635

=== Page 46 ===
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50
1
You will be residing at 358 El
2
Brillo Way, Palm Beach, Florida 33480.
3
Should you desire to move or go to a
4
different location upon release from
5
custody, you will get preapproval of that
6
location from the Department of
7
Corrections. You will have to contact your
8
community control officer a minimum of once
9
a week, it can be more often at their
10
discretion and you are to work at the
11
Florida Science Foundation at 250
12
Australian Avenue in West Palm Beach,
13
Florida. You will submit to a mandatory
14
curfew of 10 p.m. to 6 a.m.
15
You shall not live within a
16
thousand feet of a school, day care center,
17
park, playground or other place where
18
children congregate. You shall not have
19
any contact with the victims, directly or
20
indirectly including through a third person
21
unless approved by victim's therapist and
22
the sentencing court.
23
You shall not work for pay or as a
24
volunteer at any school, day care center
25
park, play ground, other place where
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027636

=== Page 47 ===
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50
1
children may congregate. You shall not
2
view, own or possess any obscene
3
pornographic or sexually stimulating or
4
visual, auditory material including
5
telephone, electronic media, computer
6
programs, computer services that are
7
relevant to deviant behavior.
8
You shall submit two specimens of
9
blood to Florida Department of Law
10
Enforcement to be registered with the DNA
11
data bank. You shall submit to a
12
warrantless search by the probation officer
13
or community control officer of your
14
person, residence or vehicle.
15
You shall maintain a driving log.
16
You shall not drive a motor vehicle while
17
alone without prior approval of the
18
supervising officer.
19
You shall submit to, at
20
probationer or community control expense a
21
HIV test, the result of which is to be
22
released to the victims or victim's parent
23
or guardian. That has to be done within 48
24
hours.
25
You shall not obtain or a use post
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027637

=== Page 48 ===
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50
1
office box without the prior approval of
2
the supervising officer.
3
MS. BELOHLAVEK: You forgot one that
4
you may not possess, own or view sexually
5
stimulating -- I don't believe you read
6
that outloud just now.
7
THE COURT: Yes, I did.
8
MS. BELOHLAVEK: I'm sorry, I didn't
9
hear it. I just wanted to make sure.
10
THE COURT: And the warrantless
11
search by the community control officer of
12
the person, residence or vehicle --
13
understand the person, residence or vehicle
14
includes anything you might possess like
15
computer, a cell phone and whatever other
16
elaborate devices there are to communicate
17
electronically these days, okay. Good
18
luck.
19
MR. GOLDBERGER: Thank you.
20
MS. BELOHLAVEK: Thank you.
21
THE COURT: Is there a judgment?
22
MR. GOLDBERGER: Yes, there should be
23
judgments.
24
THE COURT: Was there a condition of
25
community control that he pay or is he
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027638

=== Page 49 ===
Case 9:08-cv-80736-KAM Document 463-3 Entered on FLSD Docket 07/08/2019 Page49 of
50
1
paying it?
2
MR. GOLDBERGER: Actually there is a
3
cash bond posted, court cost can be
4
deducted from the cash bond.
5
THE COURT: $574 is the total?
6
MS. BELOHLAVEK: Correct.
7
THE COURT: Is that to cover both
8
cases?
9
MR. GOLDBERGER: Yes.
10
THE COURT: Thank you.
11
MR. GOLDBERGER: Thank you, Your
12
Honor.
13
(Whereupon, at 9:48 o'clock a.m. the
14
proceedings before the Court concluded.)
15
16
17
18
19
20
21
22
23
24
25
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027639

=== Page 50 ===
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50
the
1
CERTIFICATE
2
3
THE STATE OF FLORIDA,
4
COUNTY OF PALM BEACH.
5
I, PHYLLIS A. DAMES, Official Court
6
Reporter for the Fifteenth Judicial Circuit,
7
Criminal Division, in and for Palm Beach County,
8
Florida; do hereby certify that I was authorized
9
to and did report the foregoing proceedings before
10
the Court at the time and place aforesaid; and
11
that the preceding pages numbered from 1 through 49,
12
inclusive, represent a true and accurate
13
transcription of my stenonotes taken at said
14
proceedings.
15
IN WITNESS WHEREOF, I have hereunto
16
affixed my official signature this 19th day of
17
July, 2008.
18
19
20
Raylis A -Dames
21
PHYLLIS A. DAMES
22
23
24
25
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
EFTA00027640


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EFTA00028809

=== Page 2 ===
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EFTA00028810

=== Page 3 ===
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=== Page 4 ===
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TD -00000455, TD-DOJ-001, IMAGES\001\TD-D0J-00000455.tif
-D0J-00000456, TD-DOJ-001, IMAGES\001\TD-D0J-00000456.tif
D-D0J-00000457, TD-DOJ-001, IMAGES\001\TD-D0J-00000457.ti
TD -00000458, TD-DOJ-001, IMAGES\001\TD-D0J-00000458.tif
TD-D0J-00000459, TD-DOJ-001, IMAGES\001\TD-D0J-00000459.tif
EFTA00028817

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TD - DOJ - 00000461, TD-DOJ-001, IMAGES\001\TD-D0J-00000461.tif
TD - DOJ - 00000462, TD-DOJ-001, IMAGES\001\TD-D0J-00000462.tif
TD - DOJ - 00000463, TD-DOJ-001, IMAGES\001\TD-D0J-00000463.tif
TD - DOJ - 00000464, TD-DOJ-001, IMAGES\001\TD-DOJ-00000464.tif
TD - DOJ - 00000465, TD-DOJ-001, IMAGES\001\TD-D0J-00000465.tif
TD - DOJ - 00000466, TD-DOJ-001, IMAGES\001\TD-D0J-00000466.tif,Y, 1
EFTA00028818


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=== Page 1 ===
From:
To:
Cc:
Subject: Meetings
Date: Fri, 03 Jul 2020 18:39:55 +0000
When you have a second, could you please add
to the Press Office and Epstein Trust meetings next
week? They were scheduled awhile back, so he didn't make the distribution list. Thanks,
Hope you're having a great weekend.
EFTA00027509


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re: Epstein FOIA Atty Visit Logs and Count Slips
Date: Sat, 09 Jan 2021 17:30:00 +0000
Ha! Thanks for thinking of me.
On Jan 9, 2021, at 12:21 PM,
(USANYS)
wrote:
I knew you wouldn't want to be left out
From:
(USANYS)
Sent: Saturday, January 09, 2021 9:13 AM
To:
(USANYS)
Cc:
(USANYS)
>;
Subject: Epstein FOIA Atty Visit Logs and Count Slips
Hi
Defense counsel in Tartaglione has requested to see the attorney visit logs and count slips that have Tartaglione's name
on them. Those documents may be covered by the attached protective order, and so we have asked
who is firewall counsel in Tartaglione, to receive the documents from you for potential production to defense counsel
(so that
and I do not see them).
is going to review the protective order first and determine whether
she needs Judge Karas to modify the order to allow her to receive the documents, so please don't send them to
until she reaches out. Thanks for helping with this - we know it is a pain.
Deputy Chief, White Plains Division
United States Attorney's Office
Southern District of New York
300 Quarropas Street
White Plains, New York 10601
Tel:
Cell:
<127124560313.pdf>
EFTA00028142


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=== Page 1 ===
From:
To:
Subject: FW: GM
Date: Fri, 20 Mar 2020 19:31:11 +0000
Attachments:2020-03-12_GM_prosecution_memo.RC+EBD.docx
I think these comments generally make sense, and I actually agree it makes sense to further flesh out some of the legal
issues, and I think the fact questions are relatively straightforward. I'm working through a draft
memo but let's talk
about if we need to reallocate resources on this at all.
From:
Sent: Friday, March 20, 2020 15:19
To:
Cc:
Subject: RE: GM
Thanks, guys, and sorry for the delay in turning this around. Our collective comments and questions in track. Happy to
discuss any of them after you've had a chance to review.
EFTA00027823


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=== Page 1 ===
From:
"
,
(USANYS)"
To:
(USANYS) 4"
>, "Berman, Geoffrey (USANYS)"
Subject: RE: Epstein
Date: Tue, 27 Aug 2019 23:11:08 +0000
Thanks for that input. The Epstein team was thanked by the victims repeatedly. Very proud of the team.
From:
(USANYS) 4
Sent: Tuesday, August 27, 2019 7:07 PM
To: Berman, Geoffrey (USANYS)
is
,
(USANYS)
Subject: Epstein
Geoff and
:
Just wanted you both to know that we've been receiving a positive response from NGOs on the Epstein case - not just in
terms of the charges brought, but also in terms of the opportunity created for victims to be heard. I was in court for part
of today, and I'm not sure that I've experienced anything like it. I am very proud of the way that our Office has handled
this case and investigation, and I hope that it encourages more victims to come forward.
Thank you.
Assistant United States Attorney
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Phone:
Email:
EFTA00028284


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=== Page 1 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case
No. 9MAG
)
See Attachment A
6573
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
7.20.19
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
days (not to exceed 30).
until, the facts justifying, the later specific date of
Date and time issued:
7.6.19
Robertlens
Judge signature
City and state:
New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00028523

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00028524

=== Page 3 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a nearly
19,000 square foot multi-story single-family residence located at
New York,
New York, and include all locked and closed containers found therein. A photograph of the front
entrance to the Subject Premises is included below:
Google
II. Items to Be Seized
1. This warrant authorizes executing agents to photograph, video record and otherwise
document the full interior of the Subject Premises, including any items, furnishings, or possessions
therein.
2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy or ownership of the Subject Premises,
including utility and telephone bills, mail envelopes, addressed correspondence,
diaries, statements, identification documents, address books, telephone
directories, and photographs of its occupant(s).
b. Evidence concerning the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2017.08.02
EFTA00028525


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=== Page 1 ===
From:
To:
Cc:
Subject: Booking travel for tomorrow
Date: Wed, 11 Sep 2019 13:58:34 +0000
Hi
I just spoke with
who approved the use of USAO funds to pay for an Epstein victim named
to fly from
Palm Beach to New York tomorrow 9/12 so that she can meet with us. She will be meeting with the Epstein team of
AUSAs and agents at 5pm tomorrow evening, and then will need to stay over in a hotel tomorrow night, flying back to
Palm Beach on Friday 9/13.
Would you please book her travel? Info is below:
Full name on ID:
DOB:
Flying from: Palm Beach, FL
Flying to: NYC (needs to arrive in SDNY in time for 5pm meeting on 9/12)
Hotel: Needed for one night 9/12 into 9/13, then flight back to Palm Beach on 9/13
Witness email address:
Please let me know if you have any questions or need any additional information.
Thanks so much,
EFTA00028193


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Thu, 29 Nov 2018 21:15:16 +0000
Importance: Normal
I don't really know him, let's call him now
From:
(USANYS)
Sent: Thursday, November 29, 2018 4:15 PM
To:
(USANYS)
Subject: FW: Epstein
Let me know when you do this, and I can join. I don't know
- would be good to "meet" him.
From:
(USANYS)
Sent: Thursday, November 29, 2018 4:13 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: RE: Epstein
I spoke with
- he agrees we should open.
he asked you to call
now.
From:
(USANYS)
Sent: Thursday, November 29, 2018 3:27 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: RE: Epstein
I think you should reach out in the first instance and then have the GS call me. We will want to see how quickly they can
gather the FBI investigative file from the old case. We should think about whether there is an immediate subpoena we
should cut to stake claim?
From:
(USANYS)
Sent: Thursday, November 29, 2018 3:14 PM
To:
(USANYS)
^
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
Subject: Re: Epstein
Agreed.
On Nov 29, 2018, at 2:58 PM,
(USANYS)
wrote:
My view is that we should open on this today, and bring in FBI-NY's sex crimes squad.
please let me know if you
want me to reach out to
,
or if you prefer to call
(the GS who overseas the squad).
EFTA00029074

=== Page 2 ===
From:
(USANYS)
Sent: Thursday, November 29, 2018 2:53 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: Epstein
As discussed: https://www.miamiherald.com/news/local/article220097825.htm
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
EFTA00029075


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=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
(USANYS)"
"
,
(USANYS)"
Subject: Pre-Meeting US V Noel/Epstein FOIA
Date: Sun, 27 Jun 2021 22:18:25 +0000
Importance: Normal
Attachments: unnamed
EFTA00029531


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=== Page 1 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
)
3 electronic devices seized on July 11, 2019 from
New York, NY
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
18 U.S.C. 1591; 18 U.S.C. 2422; 18 USC 2423; 18 U.S.C. 371
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
30
days (not to exceed 30).
Juntil, the facts justifying, the later specific date of
Date and time issued:
Judge's signature
City and state:
New York, NY
Hon. Alison J. Nathan, U.S. District Judge
Printed name and title
EFTA00029150

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00029151

=== Page 3 ===
Attachment A
I. Devices Subject to Search and Seizure
The devices that are the subject of this search and seizure warrant (the "Subject Devices")
are described as follows:
The Subject Devices were recovered from a search of JEFFREY EPSTEIN's private
residence located at
, New York, New York, which took place on July 11, 2019.
The Subject Devices are particularly described as follows:
a. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433822 ("Corrected Subject Device-32");
b. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433824 ("Corrected Subject Device-33");
and
c. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433821 ("Corrected Subject Device-34").
II. Review of ESI on the Subject Devices
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Device for evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors), 2422 (transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to
commit sex trafficking, transportation of minors, and enticement to travel) (the "Subject
Offenses"), for the period 1994 through August 8, 2019, described as follows:
1.
Evidence concerning the identity or location of the owner(s) or user(s) of the
Subject Devices.
2.
Evidence concerning the identity or location of co-conspirators of JEFFREY
EPSTEIN, including
and GHISLAINE MAXWELL.
3.
Evidence concerning communications to, from, by, and/or among co-conspirators
of JEFFREY EPSTEIN, including
and GHISLAINE MAXWELL.
4.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses.
2017.08.02
EFTA00029152

=== Page 4 ===
5.
Documents or records reflecting payments to victims and/or co-conspirators
including but not limited to bank and financial records, spreadsheets, ledgers, account listings,
check and wire records, and documents reflecting cash withdrawals.
6.
Documents or records reflecting travel plans or arrangements for victims or
potential victims of the Subject Offenses, or co-conspirators in those Subject Offenses, including
but not limited to itineraries, tickets, receipts, flight manifests, passport or identification
information, and related records.
7.
Any photographs of victims or potential victims of the Subject Offenses.
8.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
9.
Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usernames and passwords, user profiles, e-mail contacts, and photographs.
10.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. $ 2256(8).
If the Government determines that any of the Subject Devices is no longer necessary to retrieve
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject
Device, upon request.
2
2017.08.02
EFTA00029153


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=== Page 1 ===
From:
To:
Subject: RE: witness travel
Date: Fri, 12 Nov 2021 17:20:29 +0000
Attachments: Fact_Witness_Travel_Request.docx
H
Thanks for speaking earlier. Attached is the form for the witness I mentioned. I should be able to send you the other two
by Monday.
Thanks!
From:
Sent: Thursday, November 11, 2021 8:21 PM
To:
Subject: Re: witness travel
I will be in all day.
Sent from my iPhone
On Nov 11, 2021, at 6:51 PM,
wrote:
Hi
Do you have a few minutes tomorrow for a call about some of the trial witnesses who will be travelling for the Maxwell
case? I wanted to flag a few things. Thanks!
Assistant United States Attorney
Southern District of New York
EFTA00027662


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=== Page 1 ===
From:
"
(USANYS)"
To: "
(USANYS) 4"
Subject: RE: Paralegal for Epstein
Date: Fri, 18 Jan 2019 16:25:17 +0000
Importance: Normal
Will do!
From:
(USANYS) 4
Sent: Friday, January 18, 2019 10:54 AM
To:
(USANYS)
Subject: Paralegal for Epstein
Hey,
(paralegal in PC) is interested in working sex trafficking cases. If you need a para for Epstein, can you
keep her in mind? She is awesome. Thanks!
Assistant United States Attorney
Southern District of Ne
New York, New York 10007
Phone:
Email:
EFTA00029181


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "Motion FILED to seal document"
Date: Thu, 24 Sep 2020 23:53:41 +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 09/24/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
MOTION, to seal document, on behalf of Appellant Ghislaine Maxwell, FILED. Service date 09/24/2020 by
CM/ECF. [2938282] [20-3061]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Gerard Whidbee, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion FILED
Original Filename: 2020.09.24 Motion for Leave to File Under Seal.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=09/24/2020] [FileNumber=2938282-0]
[293d84f26794200eafdbd3c4a61cd532f4bae1e13bd10108e1cc5b7e8a8ed1bfa662284a4b005c37c3291cbcbc729
EFTA00028066

=== Page 2 ===
56ab83ed2d1132dc2b90d8c3a7e4b43751a]
EFTA00028067


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=== Page 1 ===
From: SAS Auto-messages <SAS-AUTONOTIFY@usdoj.gov>
To:
Subject: SAS: Request 21000415 routed to Intake
Date: Fri, 24 Sep 2021 17:54:00 +0000
OEO Special Approvals System - Status Message
This email serves as confirmation that your Witness Immunity request has been submitted with the following
information:
Request ID: 21000415
Request Type: Witness Immunity
Subject:
Submitted By:
District: NYS
EFTA00027575


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=== Page 1 ===
From:
To:
Subject: Re: Epstein Guards/ OIG Report
Date: Fri, 21 May 2021 20:41:35 +0000
Thank you. Have a nice weekend.
On May 21, 2021, at 4:37 PM,
wrote:
Hi
OIG has no objections. Thanks.
From:
Sent: Friday, May 21, 2021 4:29 PM
To:
Cc:
(USANYS)
Subject: RE: Epstein Guards/ OIG Report
Hi
Per our conversation just now, attached is a draft of the letter we intend to submit shortly. As you'll see in the first
bullet point, we reference the DOJ-OIG review. We do not plan to make mention of a report, although if asked at a court
conference whether there will be a report, we plan to say that we don't know, and that OIG's normal process is to
prepare a report but we don't know whether it will be made public or not.
Please let us know if you have any objections to the language in the letter. Thanks again for the speedy response, we
very much appreciate it.
From:
Sent: Friday, May 21, 2021 2:10 PM
To:
Cc:
(USANYS)
Subject: RE: Epstein Guards/ OIG Report
Thank you,
From:
Sent: Friday, May 21, 2021 2:09 PM
To:
EFTA00028699

=== Page 2 ===
Cc:
(USANYS)
Subject: RE: Epstein Guards/ OIG Report
,
I'm following up internally and will get back to you, or have someone from OIG get back to you. Thanks.
From:
Sent: Friday, May 21, 2021 1:46 PM
To:
Cc:
(USANYS)
Subject: Epstein Guards/ OIG Report
Hi
We were hoping you could assist us with getting in touch with the OIG lawyer who is responsible for preparing the
report on Epstein's suicide. We have been trying to get in touch with
who was previously handling the
investigation, but understand he may have left the office. The time sensitivity is that we plan to file a public letter by
close of business today regarding reaching a deferred prosecution agreement with the two guards on duty that night
who have been charged with falsifying records. The guards have agreed to sit for an interview with our office and DOJ-
OIG, and we'd like to state in the letter that the interviews would occur as part of an ongoing OIG investigation that we
expect would lead to a public report. However, we don't want to make this representation unless DOJ-OIG is
comfortable with it.
I'm happy to discuss by phone if convenient.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
EFTA00028700


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=== Page 1 ===
Event: Accepted: Epstein Oral Argument-- Second Circuit
Start Date: 2019-03-06 15:00:00 +0000
End Date: 2019-03-06 17:00:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-02-05 17:29:15 +0000
Date Modified: 2019-02-05 17:29:15 +0000
Priority: 5
DTSTAMP: 2019-02-05 17:12:11 +0000
EFTA00029469


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=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: Potential Victim
Date: Tue, 09 Jul 2019 01:06:33 +0000
Thanks
-
On Jul 8, 2019 8:59 PM,
wrote:
FYI. We can discuss tomorrow, but wanted to keep you in the loop.
Sent from my iPhone
Begin forwarded message:
From:
Date: July 8, 2019 at 8:38:24 PM EDT
To:
Cc:
Subject: Potential Victim
The CSOs received a telephone call from a female who identified herself as
who allegedly has
information about Epstein.
gave a return number of
EFTA00028376


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=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Municipal Credit Union
Research Department
22 Cortlandt Street
New York, NY 10007
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 201, 371, 1001, 1346, 1519, 2
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
Please see attached rider. Personal appearance is not required if the requested records are (1) produced on or
before the return date to Assistant U.S. Attorney
of the United States Attorney's Office, 1 St.
Andrew's Plaza, New York, NY 10007. Tel:
, email:
, and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records. Ref No. 2019R01059.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 17, 2019
Geoffey
S.
with
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
UNITED STATES DISTRICT COURT
Assistant United States Attorney
FOR
One St. Andrew's Plaza
THE
RICT
YORK
New York, New York 10007
or
NEW
Telephone:
Email:
rev. 02.01.12
EFTA00027204

=== Page 2 ===
RIDER
(Grand Jury Subpoena to MCU, dated August 17, 2019)
Ref. No. 2019R01059
REQUEST:
For the following account, and any other account controlled by the account holder of one of the below
accounts:
Please provide any and all documents, to include, but not limited to those identified below, for the period
January 1, 2019 until the present:
a. Account opening documents, including applications and signature cards;
b. Records of account holders for debit and credit cards liked to the accounts;
c. Account statements and ledgers;
d. Images of checks (both front and back) deposited in account;
e. Images of canceled checks (both front and back) drawn on account;
f. Images of cashier's checks (both front and back) and depositing bank account information;
g. Account deposit slips, withdrawal slips, debit & credit memos, and cash tickets;
h. Detailed wire transfer records, ACH transfer records (including routing/account numbers funds
transferred to/from), money orders, and traveler's check records;
i. All credit card and line of credit records, including, but not limited to: applications, monthly
statements, billing slips, and records evidencing the source of payment (copies of checks, ACH
records (including routing/account numbers funds transferred to/from), or cash received slips);
j. Customer information associated with the account, including name(s), address(es), telephone
number(s), e-mail address(es), and any other identifying or contact information.
INSTRUCTIONS FOR PRODUCTION OF DOCUMENTS:
1. All transactions-based information, include wire and ACH transfers, withdrawals/deposits,
charges/payments, and bank account activity should be provided in electronic spreadsheet
format (either Microsoft Excel or similarly compatible format). Specifically:
a. For wires and other types of transfers, the account holder name, account number, and bank
name of both the originator and beneficiary of the transaction should be clearly stated in
separate fields.
b. Cash and check transactions should be indicated within a transaction type field.
i. Check transactions should include the name of the payee in the recipient
field. Additionally, check images should be attached in graphic data files in a commonly
readable, non-proprietary format with the highest image quality maintained, and named in
a manner that uniquely associates them with the relevant transaction record(s).
EFTA00027205

=== Page 3 ===
ii. Cash withdrawals should be indicated with CASH written in the recipient field.
iii. Cash deposits should be indicated with CASH written in the sender/originator field.
c. Field headers should be included for each column of data, and a data dictionary or other
explanation of the contents of each column provided.
2. Where more than one account is being requested, each account's transaction records should be
returned in a separate file.
3. All document images are to be produced in electronic PDF format. Where images of checks,
deposit slips, withdrawal slips, or cash tickets are being produced, they should be produced no
more than two per page.
4. In lieu of an appearance you may comply with this subpoena by providing the requested
information, along with a business records certification pursuant to Fed. R. Evid. 803(6) to
Assistant U.S. Attorney
of the United States Attorney's Office, 1 St. Andrew's
Plaza, New York, NY 10007. Tel:
, email:
EFTA00027206

=== Page 4 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the
business named below, or I am otherwise qualified as a result of my position with the business named below to
make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 17, 2019, and signed by Assistant United States
Attorney
,
requesting specified records of the business named below. Pursuant to Rules 902(11) and
803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the
Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from
information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
-
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts,
events, conditions, opinions, or diagnoses. The term "business" as used in Fed. R. Evid. 803(6) and the above declaration
includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for
profit.
EFTA00027207

=== Page 5 ===
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
August 17, 2019
Re:
Grand Jury Subpoena
This letter describes the procedure for requesting reimbursement for subpoenaed records.
12 CFR part 219 (subpart A), issued by the Board of Governors of Federal Reserve System under section
1115 of the Right to Financial Privacy Act (12 U.S.C. $ 3415), sets the rates and conditions for reimbursement of
costs directly incurred by financial institutions in assembling or providing customer financial records to a
government authority pursuant to the Act. No costs are reimbursable if the records are those of a corporation or a
partnership comprised of more than five individuals.
If reimbursement is authorized, and the estimated billing to the government will exceed $500, advance
permission is necessary from
at
If the subpoenaed records indicated on the rider are eligible for reimbursement, please complete section B
of the enclosed form OBD-211, which will serve as your invoice, and return it with a copy of the subpoena to the
following address:
U.S. Attorney's Office - SDNY
Accounts Payable
86 Chambers Street, 3rd floor
New York, NY 10007
(212) 637-2662
Please send your invoice to the above address within 60 days of the submission of the subpoenaed records.
If no invoice is received within 120 days, funds will not be available to pay the invoice.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorney
Enclosure: OBD- 211
EFTA00027208


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=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
Subject: Accepted: Epstein T&E Meeting
Date: Wed, 08 Jan 2020 14:59:37 +0000
Importance: Normal
Attachments: unnamed
EFTA00028717


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Questionnaires are ready
Date: Fri, 12 Nov 2021 18:53:05 +0000
Attachments:US_v_Maxwell_Juror_Questionnaire_Review__MASTER_CHART_copyxlsx
Questionnaires from this morning saved here:
Assignments are in the attached spreadsheet. The questionnaires are uploaded to USAfx and are ready to be shared with
defense counsel once you email them to let them know.
Original Message
From:
Sent: Friday, November 12, 2021 12:07 PM
To:
is
is
>;
Cc:
Subject: RE: Questionnaires are ready
Thanks! Team, as a reminder for planning purposes: your comments/objections to your batch of jurors will be due to
by 11 a.m. tomorrow morning. I'll work with
today to get this out to the defense and the court and get the
juror numbers assigned out to the team to review.
Original Message
From:
Sent: Friday, November 12, 2021 12:03 PM
To:
is
is
is
Cc:
Subject: Questionnaires are ready
Well let you know when they're scanned and ready for you.
Sent from my iPhone
EFTA00027665


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=== Page 1 ===
From:
To:
Subject: RE: Epstein OIG/FBI--Document Preservation
Date: Wed, 14 Aug 2019 20:35:46 +0000
Belatedly, thanks.
From:
Sent: Tuesday, August 13, 2019 12:12 PM
To:
Subject: RE: Epstein OIG/FBI--Document Preservation
Attached please find my completed form. The USAO number for the portion of the case that I worked on is 2018R01618.
Throughout my participation in this case, I have, as a practice, saved all Epstein-related emails that I received in my email
archive in a folder entitled "Epstein". Any emails that I sent regarding the case would be in the sent items folder in my
email. I have not sent or received any substantive text messages regarding the case (any texts with other team members
are purely logistical-e.g., setting up a time to meet or for a call).
Please let me know if you need anything else.
Thanks,
From:
Sent: Monday, August 12, 2019 5:13 PM
Subject: RE: Epstein OIG/FBI--Document Preservation
Dear all,
As
explained, we are instituting a formal litigation hold in connection with Mr. Epstein's death at MCC. You have
been identified as having done work on or supervised the Epstein matter, and thus as possibly having responsive records.
Please note and preserve whatever you have about Mr. Epstein, not limited to his death and to the earlier reported
incident in which he suffered physical injuries. In addition, to the extent possible, please avoid altering any relevant
records. If you need to use existing documents, please save what you're working off of as a new document so that the
version that now exists remains preserved and available.
EFTA00027113

=== Page 2 ===
I attach a formal litigation hold notice, which as required is on an EOUSA-provided form. Please review the notice, fill out
the form to indicate whether and where you have responsive records, and sign and return it to me. In particular, be sure
to let me know by USAO number if possible what records and share directories we have that are likely to include relevant
information.
I prefer scanned and emailed return of the forms, but you can also use interoffice mail if you prefer.
Please let me know if you think other USAO personnel may have relevant documents or evidence.
And please let me know if you have questions or want to discuss.
Finally, I am copying
to inform him of the new litigation hold, and to ask him to ensure that all responsive
information on our electronic record systems is preserved, including by suspending the routine maintenance email
deletions for recipients of this email.
Many thanks,
Deputy Chief, Civil Division, and Litigation Hold Coordinator
U.S. Attorney's Office, S.D.N.Y.
New York, NY 10007
From:
Sent: Monday, August 12, 2019 4:46 PM
Subject: RE: Epstein OIG/FBI--Document Preservation
FYI, as a result of a preservation request Epstein's lawyers have made on behalf of the family, which indicates a
potential wrongful death case, you will shortly be receiving a formal litigation hold request from
our litigation hold coordinator.
From:
Sent: Monday, August 12, 2019 11:43 AM
EFTA00027114

=== Page 3 ===
Subject: FW: Epstein OIG/FBI--Document Preservation
All - Please see below and follow
instructions. Additionally, if you believe there are others at SDNY to whom this
email should be sent, please let me know immediately.
Thanks,
From:
Sent: Monday, August 12, 2019 11:35 AM
Subject: Epstein OIG/FBI--Document Preservation
Please forward this to everyone who might have any documents relating to the Epstein suicide, and cc me:
Please make sure to preserve any documents you may have relating to Epstein's conditions of confinement.
Your emails will be adequately preserved, for present purposes, by the regular three-year backup. But let
me know if you have any or not.
If you have any hard-copy notes, please scan them and send them to me. If you have none, let me know
that too.
Most particularly, please check to see if you have texted anything pertinent. If so let me know, one way
or the other. If you do have anything, we'll figure out how to preserve that.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
New York, NY 10007
EFTA00027115


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=== Page 1 ===
From:
"
(USANYS)"
To:
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: RE: [EXTERNAL] Focus Group Questionnaire
Date: Tue, 21 Sep 2021 18:05:04 +0000
Attachments: GM_jury_exercise_verdict_form.docx; GM_jury_exercise_RTC_ - revised.docx; Tyrrell -
_Focus_Group_Questionnaire_(LP.AM)_ - TAM.docx
Thanks for this. We've provided some proposed edits to the focus group questionnaire in the attached. Please confirm
these changes once you've had a chance to review.
I've also attached our proposed jury instructions and verdict sheet. We expect to have 8 attendees from the Government
on Saturday.
Thanks,
From: Paulette Taylor
Sent: Tuesday, September 21, 2021 11:45 AM
To:
(USANYS)
is
(USANYS)
Subject: [EXTERNAL] Focus Group Questionnaire
Good morning-
You asked to see the Focus Group Questionnaire before the research exercise on Saturday.
It is attached for you to review and comment.
Please try to keep comments to a minimum.
I will need to hear back from you by tomorrow Noon, so I can finalize it before I leave for NYC on Thursday.
Thanks.
Tavlor'd Trial Consulting
President
)
EFTA00027572


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject:
Date: Thu, 08 Apr 2021 14:35:26 +0000
Attachments: USGME01220266.doc
FYI, I came across this in relativity. I checked, and it isn't already in his witness folder. Just passing along in case you hadn't
seen it.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029240


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=== Page 1 ===
From:
"
(USANYS)"
To: "
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
N
i
"
(USANYS)"
(USANYS)"
(USANYS)"
)"
N
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Epstein FOIA case, Times V. BOP, 20-cv-833
Date: Tue, 05 Jan 2021 21:26:35 +0000
Embedded: RE:_Epstein_FOIA_case,_Times_v_BOP,_20-cv-833.msg
Sender:
Subject: RE: Epstein FOIA case, Times V. BOP, 20-cv-833
Message-Id:
<BN3P110MB0465D02CF7920737C0BBBF91FED10@BN3P110MB0465.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
EFTA00028139


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=== Page 1 ===
From:
To:
Subject: RE:
Date: Tue, 28 Jan 2020 17:02:21 +0000
Attachments:
pdf;
Hey
Attached are the notes from the
most recent interview, along with the 302.
From:
) [mailto:
Sent: Tuesday, January 28, 2020 11:00 AM
To:
Subject:
Hi
any chance you could please send me the notes from our most recent meeting with
? (For a
memo I'm writing). Thanks!
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00028558


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
)"
Subject: Fwd: US V Epstein
Date: Sat, 10 Aug 2019 23:47:42 +0000
Per the below, Epstein's counsel has asked to have a pathologist at the autopsy (and whether it can be delayed
until they're able to arrange for that. Anyone I can point them toward on that issue?? This seems way outside
our lane but not sure who else they could ask. Thanks and sorry for the unusual question.
Begin forwarded message:
From: "Miller, Michael"
Date: August 10, 2019 at 19:34:37 EDT
To:
)"
"Martin G. Weinberg"
"Weingarten, Reid"
Cc:
)"
)"
Subject: RE: US V Epstein
Thanks for being available today and for getting the wheels turning for an investigation into how he died.
On a related note, we are hearing that Jeffrey's autopsy may occur tomorrow morning. We would like to have
a pathologist present for his autopsy and cannot line up someone on such short notice. Is there any way to
push the autopsy off until Tuesday to give us time to do that?
Mike
From:
)
Sent: Saturday, August 10, 2019 7:31 PM
To: Miller, Michael
>; ; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: RE: US V Epstein
Mike, Marty, Reid,
I just wanted to let you know that I don't expect we'll have any further updates today, and so wanted to send you a brief
note to let you know that since we hadn't otherwise been in touch since earlier this afternoon. I imagine we will
continue to be in contact in the coming days; meanwhile, I appreciate you being in touch today, and I hope the
investigations of these events will be thorough and swift.
respectfully,
EFTA00027858


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein
Date: Fri, 18 Jan 2019 14:23:58 +0000
Importance: Normal
I am free at 11.
Sent from my iPhone
On Jan 18, 2019, at 9:10 AM,
wrote:
I was hoping we'd have time to catch up internally before meeting with chiefs but looks like that won't be
successful. You both available for a quick mtg later this morning and then we can debrief them? I think
has trial witness prep but maybe we can grab even ten mins. Ugh I'm so exhausted.
Sent from my iPhone
Begin forwarded message:
From:
Date: January 18. 2019 at 09:05:22 EST
To:
Cc:
Subject: Re: Epstein
I'm traveling back today, could we set a time for Monday? Once I get in later I'm slammed with stuff that
has come up the past few days in other cases.
Sent from my iPhone
On Jan 18, 2019, at 08:51,
wrote:
You guys back? Can we circle up this morning? Definitely want to hear more about the trip.
and I have
something at 11:30 but I at least am free before/after.
Sent from my iPhone
EFTA00028145


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=== Page 1 ===
From:
To:
)"
Subject: RE:
lawsuit
Date: Thu, 26 Mar 2020 14:59:04 +0000
Still, some details about Doe's lawsuit are raising eyebrows-in particular because
the allegations seem to match up with at least one of Epstein's alleged co-
conspirators.
If this complaint was filed by one of his co-conspirators,
who "played an outsized role in Jeffrey Epstein's
devastating abuse of minors for over a decade and
profited handsomely including owning a company
affiliated with Epstein, it is a brazen abuse of our civil
justice system," said Sigrid McCawley, a partner at
Boies Schiller Flexner LLP who represents multiple
victims of Epstein. "But above all, it is a shameless act
and a disgraceful insult to the real victims."
From:
Sent: Thursday, March 26, 2020 10:38
To:
is
-
Subject: RE:
lawsuit
I can't get past the paywall. What's the Sigrid quote?
EFTA00027824

=== Page 2 ===
From:
Sent: Wednesday, March 25, 2020 10:03 PM
To:
is
Subject:
lawsuit
Sigrid is displeased.
https://www.thedailybeast.com/is-one-of-jeffrey-epsteins-co-conspirators-saing-his-estate
EFTA00027825


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=== Page 1 ===
From:
To: Jeff Pagliuca
,
Laura Menninger
be
Subject: Sealed order in 20-cr-330, US V Ghislaine Maxwell
Date: Fri, 23 Apr 2021 14:29:59 +0000
Attachments: 20cr330_Sealed_Order_4.23.21.pdf
Counsel,
Please find attached an order signed by Judge Nathan, which will be filed under seal.
Respectfully,
The Chambers of the Hon. Alison J. Nathan
EFTA00027456


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=== Page 1 ===
From: Mark Peters
To:
Subject: Congratulations on the Epstein indictment.
Date: Tue, 09 Jul 2019 01:36:09 +0000
Congrats. It's a real public service.
Best,
MGP
Mark G. Peters
Partner - Peters Brovner LLP
O:
C:
E:
Disclaimer: This message is intended only for the use of the Addressee and may contain information that is
privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination
of this communication is strictly prohibited. If you have received this communication in error, please erase all
copies of the message and its attachments and notify us immediately.
EFTA00028283


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=== Page 1 ===
From:
To:
Subject: RE: Final Memos
Date: Thu, 23 May 2019 13:42:32 +0000
Importance: Normal
Of course.
From:
Sent: Thursday, May 23, 2019 9:42 AM
To:
Subject: Final Memos
Would you please take one last careful look? Check Epstein especially since you had not seen that.
Thanks
EFTA00029073


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re:
request
Date: Tue, 17 Sep 2019 13:43:13 +0000
Yes thanks we figured that out yesterday.
Sorry for the error.
Sent from my iPhone
On Sep 17, 2019, at 9:35 AM,
(USANYS)
wrote:
I just realized you may have wanted to send to
and not me.
From: Strauss,
(USANYS)
Sent: Monday, September 16, 2019 3:50 PM
To:
(USANYS)
is
(USANYS)
is
) 1
>;
(USANYS) 3
Subject:
request
requests Urgent report on the DB part of Epstein case (or the Epstein part of DB. This could be separate UMR or
tagged onto the DB/Kushner UMR, depending on how we see it-is it part of pre-existing DB SAR investigation or
separate?
Please let me know how you plan to proceed.
Thanks
Deputy United States Attorney
United States Attorney's Office
Southern District of New York
Tel.
EFTA00028194


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=== Page 1 ===
Event: Epstein Meeting
Start Date: 2020-01-06 17:30:00 +0000
End Date: 2020-01-06 18:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2020-01-06 21:42:04 +0000
Date Modified: 2020-01-06 21:42:04 +0000
Priority: 5
DTSTAMP: 2020-01-06 16:09:17 +0000
Attendee:
Alarm: Display the following message 15m before start
I
Reminder
EFTA00027741


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=== Page 1 ===
The Government expects Minor Victim-3 to testify, in substance and in part, that she met
the defendant when she was approximately 17 years old. Within a few weeks of meeting the
defendant, at the defendant's invitation, Minor Victim-3 went to the defendant's townhouse in
London for tea. The defendant expressed an interest in Minor Victim-3, talked with Minor Victim-
3 about Minor Victim-3's life and interests, and told Minor Victim-3 about her boyfriend Jeffrey
Epstein, who she wanted Minor Victim-3 to meet. Shortly after, the defendant invited Minor
Victim-3 to her home. During that first visit, the defendant introduced Minor Victim-3 to Epstein
and encouraged her to give Epstein a foot massage. Epstein instructed Minor Victim-3 to massage
his shoulders. Minor Victim-3 left the townhouse after she was excused.
Shortly thereafter, the defendant invited Minor Victim-3 to her home again and encouraged
Minor Victim-3 to provide Epstein with a massage. The defendant showed Minor Victim-3 to a
room in which a massage table was set up. Epstein was in the room. Epstein removed his robe
and was naked. The defendant handed Minor Victim-3 oil and closed the door. After the massage,
the defendant was outside the room and asked if Minor Victim-3 had fun and whether Epstein
liked the massage. The defendant subsequently told Minor Victim-3 that Epstein was impressed
with her and asked her to come back to her townhouse. The defendant encouraged Minor Victim-
3 to provide a massage to Epstein. The defendant thanked Minor Victim-3, indicating that if it
wasn't Minor Victim-3 or someone else, it would all fall to her (the defendant). The defendant
again showed Minor Victim-3 to a room with a massage table where Epstein was naked. Both
massages involved at least one sex act with Minor Victim-3.
Following those two encounters, the defendant and Epstein invited Minor Victim-3 to
travel with them to Florida, the U.S. Virgin Islands, and New York. Minor Victim-3 eventually
accepted these invitations, but she does not recall whether she was 17 or 18 when she took her first
trip at Epstein and the defendant's invitation. Minor Victim-3 traveled to visit the defendant and
Epstein in New York, Palm Beach, and Little Saint James. When Minor Victim-3 met the
defendant and Epstein in these locations, she provided additional massages to Epstein, during
which he engaged in sex acts with Minor Victim-3. Over the course of their interactions, the
defendant made multiple statements to Minor Victim-3 reflecting the defendant's awareness that
Epstein engaged in sex acts with Minor Victim-3. On at least one occasion, the defendant asked
Minor Victim-3 if she knew any other young females to bring to Epstein and made comments to
Minor Victim-3 about Epstein's significant sexual needs.
On one occasion in Palm Beach, the defendant provided Minor Victim-3 with a schoolgirl
uniform and told Minor Victim-3, in substance and in part, that she should bring Epstein his tea in
the uniform. After Minor Victim-3 brought Epstein tea that had been provided by the defendant,
Epstein raped Minor Victim-3.
EFTA00029538


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=== Page 1 ===
Event: Accepted: Epstein defense bail submission due
Start Date: 2019-07-11 16:00:00 +0000
End Date: 2019-07-11 16:30:00 +0000
Location: Berman
Class: X-PERSONAL
Comment:
Date Created: 2019-07-08 21:14:01 +0000
Date Modified: 2019-07-08 21:14:01 +0000
Priority: 5
DTSTAMP: 2019-07-08 20:41:41 +0000
Attendee:
EFTA00028378


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=== Page 1 ===
Event: Epstein T&E Meeting
Start Date: 2020-01-10 16:30:00 +0000
End Date: 2020-01-10 17:30:00 +0000
Organizer:
(USANYS)
Location:
's Office
Class: X-PERSONAL
Date Created: 2020-01-09 16:07:07 +0000
Date Modified: 2020-01-09 16:07:07 +0000
Priority: 5
DTSTAMP: 2020-01-08 14:55:08 +0000
Attendee:
(USANYS) [Contractor]
>;
(USANYS)
Alarm: Display the following message 15m before start
Reminder
EFTA00028719


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=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Mon, 02 Nov 2020 15:05:34 +0000
Yes - calling right now
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, November 2, 2020 at 10:04 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Does now still work? Thanks-
Sent from my iPhone
On Oct 30, 2020, at 11:14 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
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
EFTA00028690

=== Page 2 ===
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
-
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
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)"
EFTA00028691

=== Page 3 ===
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
EFTA00028692

=== Page 4 ===
H
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
EFTA00028693

=== Page 5 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
Cc:
is
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
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
EFTA00028694


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=== Page 1 ===
From: Christian Everdell
To:
Cc:
"Mark S. Cohen"
'BOBBI C STERNHEIM'
, 'Jeff
Pagliuca'
>, Laura Menninger
Bcc: "USAHUB-USAJournal111"
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Pretrial Motions and Exhibits (to be Filed
Under Seal)
Date: Tue, 26 Jan 2021 02:45:21 +0000
Embedded: U.S._v._Ghislaine_Maxwell,_20_Cr._330_(AJN)_-- --
_Pretrial_Motions_and_Exhibits_(to_be_Filed_Under_Seal).msg
Sender:
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Pretrial Motions and Exhibits (to be Filed Under Seal)
Message-Id:
Recipient:
EFTA00028137


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
)"
Subject: RE: draft response to Epstein defense preservation requests
Date: Fri, 09 Aug 2019 17:27:13 +0000
Sure - let us know if we're ultimately able to send today, otherwise we'll check back on Monday, thanks.
From:
(USANYS)
Sent: Friday, August 09, 2019 13:26
To:
)
Cc:
(USANYS)
is
is
Subject: Re: draft response to Epstein defense preservation requests
Okay, thanks.
is signed off but we may have to chat briefly with
when he's back on Monday.
Sent from my iPhone
On Aug 9, 2019, at 1:21 PM,
wrote:
I'm totally available to update it this afternoon if there are edits today, but realistically I don't think the defense can
make much more hay about having gotten a response on the 9th versus the 12th
From:
(USANYS)
Sent: Friday, August 09, 2019 13:20
To:
Cc:
(USANYS)
is
is
Subject: Re: draft response to Epstein defense preservation requests
If we don't get this out until Monday is that a problem?
Sent from my iPhone
On Aug 8, 2019, at 5:56 PM,
)
wrote:
No problem, thanks, and the edits were all straightforward. Updated version attached, everything incorporated, and
can go to
- I'm out of commission the next couple hours but back after that.
thanks,
From:
(USANYS)
Sent: Thursday, August 08, 2019 16:36
To:
is
(USANYS)
EFTA00027856

=== Page 2 ===
Cc:
is
Subject: RE: draft response to Epstein defense preservation requests
Sorry for the delay. Combined edits from both of us, attached. Can you take a look and clean up - we would then like
to give
at least the option of weighing in before we send to defense counsel.
From:
Sent: Thursday, August 8, 2019 11:44 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: draft response to Epstein defense preservation requests
Wanted to bump this from Tuesday, especially since I know you guys are out tomorrow - hopefully we can send it out
today? Happy to incorporate any edits etc. Thanks.
From:
Sent: Tuesday, August 06, 2019 15:01
To:
(USANYS)
is
(USANYS)
Cc:
in
)
Subject: RE: draft response to Epstein defense preservation requests
This has been in the works for a little while, due to various other things that have come up in the interim, but we
didn't want it to get lost given the discovery motion schedule. The attached is based on our conversations with
including his email with suggested language for the prefatory language, and responds to the two attached defense
letters. Happy to discuss anytime and to incorporate comments and suggestions.
thanks,
Assistant U.S. Attorney
Southern District of New York
<2019-08-08, JE, letter to defense re preservation requests.docx>
EFTA00027857


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=== Page 1 ===
Public Corruption Unit
Short Form Updates
November 6, 2020
A. SIGNIFICANT DEVELOPMENTS IN CASES
US V. Ghislaine Maxwell, USAO 2018R01618 (AUSAs
): On June 29, 2020 a grand jury returned a six count indictment charging
Maxwell for her role in facilitating Epstein's abuse of minor girls. Maxwell was
arrested on July 2 at a residence in New Hampshire and has been detained since.
The team made an initial discovery production on or about August 21, 2020, and is
working on a second discovery production of electronic materials in the coming
month. The team is also working with the USAO-SDFL, OPR and the West Palm
Beach Police Department among other sources to obtain and review materials
relevant to the prior investigation. Additionally, the team is in the process of
reaching out to counsel for
to begin initial discussions about the possibility of
a felony disposition. We are also continuing to pursue a potential interview with
Prince Andrew, and after his counsel declined to make him available for a voluntary
interview, we notified OIA that we wished to proceed with an MLAT. We
completed discovery in November 2020. Maxwell expects to make a renewed
bail application in the next weeks based in part on conditions at MDC and a
substantial bail package. We expect to oppose.
1
EFTA00027424

=== Page 2 ===

=== Page 3 ===

=== Page 4 ===

=== Page 5 ===


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=== Page 1 ===
From:
To:
Subject: FW: Paralegal for Epstein
Date: Fri, 18 Jan 2019 16:25:29 +0000
Importance: Normal
FYI.
From:
(USANYS) 4
Sent: Friday, January 18, 2019 10:54 AM
To:
Subject: Paralegal for Epstein
Hey,
(paralegal in PC) is interested in working sex trafficking cases. If you need a para for Epstein, can you
keep her in mind? She is awesome. Thanks!
Assistant United States Attorney
Southern District of New York
New York, New York 10007
Phone:
Email:
EFTA00029460


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=== Page 1 ===
PROFFER AGREEMENT
With respect to the meeting of
("Client") and her attorney Joseph
Nascimento, Esq., with Assistant United States Attorneys
and
to be
held on July 12, 2019 ("the meeting"), the following understandings exist:
(1) THIS IS NOT A COOPERATION AGREEMENT. The Client has agreed to
provide the Government with information, and to respond to questions, so that the Government
may evaluate Client's information and responses in making prosecutive decisions. By receiving
Client's proffer, the Government does not agree to make a motion on the Client's behalf or to enter
into a cooperation agreement, plea agreement, immunity or non-prosecution agreement. The
Government makes no representation about the likelihood that any such agreement will be reached
in connection with this proffer.
(2) In any prosecution brought against Client by this Office, except as provided below the
Government will not offer in evidence on its case-in-chief, or in connection with any sentencing
proceeding for the purpose of determining an appropriate sentence, any statements made by Client
at the meeting, except (a) in a prosecution for false statements, obstruction of justice or perjury
with respect to any acts committed or statements made during or after the meeting or testimony
given after the meeting; or (b) if, at any time following the meeting, Client becomes a fugitive
from justice.
(3) Notwithstanding item (2) above: (a) the Government may use information derived
directly or indirectly from the meeting for the purpose of obtaining leads to other evidence, which
evidence may be used in any prosecution of Client by the Government; (b) in any prosecution
brought against Client, the Government may use statements made by Client at the meeting and all
evidence obtained directly or indirectly therefrom for the purpose of cross-examination should
Client testify; and (c) the Government may also use statements made by Client at the meeting to
rebut any evidence or arguments offered by or on behalf of Client (including arguments made or
issues raised sua sponte by the District Court) at any stage of the criminal prosecution (including
bail, all phases of trial, and sentencing) in any prosecution brought against Client.
(4) The Client understands and agrees that in the event the Client seeks to qualify for a
reduction in sentence under Title 18, United States Code, Section 3553(f), United States
Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office may
offer or use at any stage of the criminal proceeding any statement made by Client during the
meeting, and all evidence obtained directly or indirectly therefrom, to the extent such use is
consistent with Section 402 of the First Step Act of 2018.
(5) To the extent that the Government is entitled under this Agreement to offer in evidence
any statements made by Client or leads obtained therefrom, Client shall assert no claim under the
United States Constitution, any statute, Rule 410 of the Federal Rules of Evidence, or any other
federal rule that such statements or any leads therefrom should be suppressed. It is the intent of
this Agreement to waive all rights in the foregoing respects.
01.14.2019
EFTA00028641

=== Page 2 ===
(6) If this Office receives a request from another prosecutor's office for access to
information obtained pursuant to this Proffer Agreement, this Office may furnish such information
but will do SO only on the condition that the requesting office honor the provisions of this
Agreement.
(7) It is further understood that this Agreement is limited to the statements made by Client
at the meeting and does not apply to any oral, written or recorded statements made by Client at
any other time. No understandings, promises, agreements and/or conditions have been entered
into with respect to the meeting other than those set forth in this Agreement and none will be
entered into unless in writing and signed by all parties.
(8) The understandings set forth in paragraphs 1 through 7 above extend to the continuation
of this meeting on the dates that appear below.
(9) Client and Attorney acknowledge that they have fully discussed and understand every
paragraph and clause in this Agreement and the consequences thereof.
Dated: West Palm Beach, Florida
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
by:
Client
Assistant United States Attorney
MA Attorney for Client
Witness
0
Dates of Continuation
Initials of counsel, Client, AUSA, witness
9/10/19
5/14/21
01.14.2019
EFTA00028642


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein MCC
Date: Mon, 12 Aug 2019 13:41:34 +0000
Per our discussion, FBI and DOJ-IG will do all of the interviews today without our involvement. We will also
not issue any subpoenas for now. If we could find a time to meet this morning to talk through next steps,
including looping in
,
I think that would be helpful.
EFTA00027094


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=== Page 1 ===
90A-NY-3151227 Serial 43
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title: (U) 08/10/2019 Evidence from MCC and
Date: 08/19/2019
Approved By: A/SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Reference: 90A-NY-3151227 Serial 29
Collected From: (U) MCC/
Receipt Given?: No
Holding Office: NEW YORK
Details:
On 08/10/2019, the following items were seized by SA
and are
being entered into evidence:
Item 1: (1) torn sheet
Item 2: Clothing released from New York Presbyterian Hospital
Item 3: Miscellaneous Papers, (1) MP-3 Player
(Agent Note: Reference 90A-NY-3151227, Serial 29).
Item Type
Description
1B General
(U) (1) torn sheet
Collected On: 08/10/2019 03:40 PM EDT
Receipt Number: 1
Seizing Individual:
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.
EFTA00027972

=== Page 2 ===
90A-NY-3151227 Serial 43
UNCLASSIFIED
Title: (U) 08/10/2019 Evidence from MCC and
Re: 90A-NY-3151227, 08/19/2019
Collected By:
Other Locator: SA
Location Area: L-Tier, Special Housing Unit, Cell #220
Specific Location: L-Tier, Special Housing Unit, Cell
#220
1B General
(U) Clothing released from New York Presbyterian
Hospital
Collected On: 08/10/2019 04:26 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Other Locator: SA
Location Area: New York Presbyterian Hospital
Specific Location: New York Presbyterian Hospital
1B General
(U) Miscellaneous Papers, (1) MP-3 Player
Collected On: 08/10/2019 03:40 PM EDT
Receipt Number: 3
Seizing Individual:
Collected By:
Other Locator: SA
Location Area: L-Tier, Special Housing Unit, Cell #220
Specific Location: L-Tier, Special Housing Unit, Cell
#220
UNCLASSIFIED
2
EFTA00027973


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=== Page 1 ===
Case 1:19-cv-08673-KPF Document 21 Filed 11/06/19 Page 1 of 2
KAPLAN HECKER & FINK LLP
350 FIFTH AVENUE I SUITE 7110
NEW YORK, NEW YORK 10118
TEL
I FAX
WWW.KAPLANHECKER.COM
DIRECT DIAL
DIRECT EMAIL
November 6, 2019
VIA ECF
The Honorable Katherine Polk Failla
United States District Court
Southern District of New York
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 10007
Re: Doe V. Indyke et al., No. 19-cv-08673 (S.D.N.Y.) (KPF)
Dear Judge Failla:
We represent Jane Doe in the above-captioned action. We write in response to Defendants'
two letters filed yesterday regarding: (1) related case status (ECF 19); and (2) document
preservation (ECF 20).
Since we do not see any conceivable basis under Rule 13 of the Rules for the Division of
Business Among District Judges in the Southern District to oppose designating these cases with
overlapping defendants, legal issues, and factual allegations as related, we oppose Defendants'
request for 30 days to respond. See Local Rule for the Division of Business Among District Judges
in the Southern District 13(a); see also Poindexter V. Cash Money Records, No. 13-cv-5882, 2014
WL 1383781, at *2 (S.D.N.Y. Apr. 8, 2014); Pace V. Quintanilla, No. 13-cv-91, 2013 WL
5405563, at *5 (S.D.N.Y. Sept. 23, 2013). Our client was understandably shocked by the suicide
of Jeffrey Epstein in federal custody, and is eager to obtain a modicum of justice as soon as
possible. All we have seen from Defendants, however, are efforts at delay. We very much want
to push this case forward to trial as soon as possible, and it is essential to have a judge assigned
who will preside over the entire progress of the case in order to do so.
I
Notably, contrary to the suggestion in Defendants' letter, Plaintiff is not seeking consolidation at this time.
We further note that the cases that Plaintiff has proposed as related have now all been reassigned to the same
magistrate judge, including: VE V. Nine East 71st Street et al., No. 19-cv-07625 (S.D.N.Y.) (Nathan, J.); Doe / et al.
EFTA00028472

=== Page 2 ===
Case 1:19-cv-08673-KPF Document 21 Filed 11/06/19 Page 2 of 2
KAPLAN HECKER & FINK LLP
2
As for preservation, the issues we have raised regarding preservation present yet another
compelling reason why these cases should be marked as related since the risks of spoliation face
plaintiffs in all cases. While we appreciate Defendants' explanation about Mr. Epstein's clothing
(which was not previously provided to us), that was not the point of our prior letters and emails to
Defendants. (See, e.g., ECF 14 Ex. A.) The point of our letters and emails was that we have asked
Defendants to identify which categories of documents and other information we have specified for
preservation they believe are "argumentative, assume facts that have not been proven and implicate
information protected by the attorney-client privilege and attorney work product doctrine," and are
therefore not being preserved. Defendants have failed to answer that simple question, which
understandably causes us great concern about spoliation given Mr. Epstein's multiple residences
across the globe, the fact that one of the two Defendant executors is a lawyer, and the fact that, as
a result of a will he signed just before his death, Mr. Epstein's estate is being probated in the Virgin
Islands.
We look forward to discussing these issues with Your Honor in Court tomorrow.
Respectfully submitted,
Rohlll
Roberta A. Kaplan
cc: Counsel of Record
V. Jeffrey Epstein et al., No. 19-cv-07675 (S.D.N.Y) (Daniels, J.); Doe V. Darren K. Indyke et al., No. 19-cv-07771
(S.D.N.Y.) (Castel, J.); Doe V. Darren K. Indyke et al., No. 19-cv-07772 (S.D.N.Y.) (Carter, J.); Doe V. Darren K.
Indyke et al., No. 19-cv-07773 (S.D.N.Y.) (Ramos, J.); and Doe 17 V. Indyke et al., No. 19-cv-9610 (S.D.N.Y.)
(Engelmayer, J.).
EFTA00028473


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From:
To:
Subject: RE:
Date: Thu, 07 Nov 2019 22:30:31 +0000
Attachments: 2019.11.07 - _Fact_Witness_Travel_Request
docx
Thanks very much,
Attached is the filled out form.
Would it be possible to book the following flights?
Outbound on Wednesday Nov 20 -Jet Blue - Flight 748: 12:17 pm from Las Vegas, arriving JFK 8:09 pm
Return on Thursday Nov 21 -Jet Blue - Flight 611: 7:36 pm from JFK, arriving Las Vegas 10:29 pm
Also, we will be meeting with her in midtown at Madison and 50th. Is it possible to put
in a hotel as close to that
intersection as possible, please?
Thanks again,
From:
Sent: Thursday, November 7, 2019 2:29 PM
To:
Subject:
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
Tel.
EFTA00028800


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From:
(USANYS)"
To:
(USANYS)"
Cc:
)"
)"
Subject: Travel for trial witness
Date: Tue, 31 Aug 2021 19:48:16 +0000
Attachments: Fact_Witness_Travel_Request
(
).docx
Hi
See attached. Please let me know if you need any other information. I confirmed with
counsel that it is fine for
you to contact her directly to discuss travel logistics.
Thanks so much!!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00029595


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)
Subject: Re: Maxwell Clip (Email 1 of 11)
Date: Wed, 27 May 2020 22:09:20 +0000
Ok good will try that
Sent from my iPhone
On May 27, 2020, at 5:44 PM,
(USANYS)
wrote:
I would recommend headphones. The speakers on our laptops are terrible. I can see if there's a way for me to
boost the volume though.
On May 27, 2020, at 5:41 PM,
(USANYS)
wrote:
Volume is very low even if I turn my volume to highest.
From:
(USANYS)
Sent: Wednesday, May 27, 2020 3:37 PM
To: Berman, Geoffrey (USANYS)
is
(USANYS)
is
(USANYS)
Subject: Maxwell Clip (Email 1 of 11)
Will attempt to send all of them via email. Sorry for the quality. Should be 11 emails. This is #1. Corresponds to the
following transcript passage in the pros memo (with some additional time before and after):
Q: Did you ever give a massage to anyone other than Mr. Epstein at any of Mr. Epstein's properties?
A: First of all, I never said I gave Mr. Epstein a massage.
Q: I will ask that question if you want, but I was focusing on people other than Mr. Epstein right now.
A: I don't give massages.
Q: Let's just tie that down. Is it your testimony that you've never given anybody a massage?
A: I have not given anyone a massage.
Q: You never gave Mr. Epstein a massage, is that your testimony?
A: That is my testimony.
Q: You never gave
a massage is your testimony?
A: I never gave
a massage.
EFTA00027458


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From:
)"
To:
)"
Subject: RE: epstein
Date: Mon, 08 Jul 2019 16:15:40 +0000
Importance: Normal
Attachments: 19_Cr._490_Epstein_Sealed_Indictment.pdf
U.S._v_Epstein,_19_Cr._490_(RMB)_Government_bail_memorandum.pdf
Of course - attached.
From:
Sent: Monday, July 08, 2019 12:13
To:
)
Subject: epstein
Pls send me the indictment and the Detention Memo. Tx.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00028989


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Date: Mon, 06 Jul 2020 21:58:01 +0000
Inline-Images: image001.jpg
Hey give me just like 10 mins to catch up on emails, and l'll give you both a call to check in on a couple things.
From:
Sent: Monday, July 06, 2020 17:55
To:
is
Subject: FW: Epstein investigation [FFW-DOCS.FID6003375]
Just checking that this is the last communication before I email her (unless you'd prefer to,
From:
Sent: Wednesday, March 11, 2020 9:46 PM
To: Jill Greenfield
Cc: Louise Scott
is
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
Following up on the below, given the development of the virus pandemic over the past week, any foreign travel for us is
completely shut down. We certainly will plan to come to the U.K. whenever we are permitted, but in the interim this
makes it even more valuable to get even a summary of what your client would expect to convey to us. Would it be
possible to set up a call for later this week or sometime next week? And profound apologies for the inconvenience in
changing plans, we certainly don't want to cause additional stress or anxiety to your client, the circumstances are just
completely beyond our control.
thank you,
From:
Sent: Thursday, March 05, 2020 13:13
To: Jill Greenfield
Cc: Louise Scott
is
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
Just to clarify, would it be possible for you to provide us even a very general or high-level summary of what she has told
you? We ordinarily don't go into interviews completely blind when witnesses have counsel - and the Weinstein
investigation had a great number of problems that we have been able to avoid. And separately, we'll of course keep you
updated on our approval process as well.
thanks again,
EFTA00028762

=== Page 2 ===
From: Jill Greenfield
Sent: Thursday, March 05, 2020 04:20
To:
Cc: Louise Scott
is
is
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Thanks
I am afraid that an attorney proffer will not be possible. I have been working with the DA in New York on the Weinstein
case and have simply offered up my clients to questions which has worked well.
I am of course happy to speak over the phone but it seems to me that you are better off getting the information first hand. If
you wish it may be sensible for you to initially have a call with my client?
My client has made a complaint to the Met police regarding a sexual assault by Jeffrey Epstein whilst in London and in the
employment of G Maxwell. Apart from the complaint itself, no further information has been provided to the police.
I appreciate the issue re coronavirus of course.
Kind regards,
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
From:
Sent: Wednesday, March 4, 2020 5:04 PM
To: Jill Greenfield
Cc: Louise Scott
is
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
That's great, thank you for letting us know, and we'll check on that right away and get back to you as soon as possible.
The only wrinkle, which unfortunately is completely beyond our control, is that there is now some talk of government
international travel being prevented due to the coronavirus situation, but we'll talk to the relevant people here
immediately.
One thing that would be extremely helpful for us in the near-term, including in terms of getting approvals here - and we
talked about this on the phone as well - would be to get an attorney proffer about your understanding of generally what
information you expect your client will convey on the subjects we've spoken about? We completely understand that it's
best to have her tell her story directly to us, but in terms of our preparation it's often very useful for both us and the
EFTA00028763

=== Page 3 ===
witness for us to have had a conversation with counsel in the first instance. Would it be possible to set up a call to have
that discussion? We could do as soon as tomorrow or Friday, or also next week.
Thanks very much,
From: Jill Greenfield
Sent: Wednesday, March 04, 2020 11:46
To:
Cc: Louise Scott
is
V.
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Hi
There is the possibility of a meeting on the 19th March if you are able to come to London. Could you let me know please?
Kind regards
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
From:
Sent: Tuesday, March 3, 2020 11:17 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
is
Subject: RE: Epstein investigation
Jill,
We wanted to quickly follow up since I think you and I last spoke a little over a week ago-understand if you are still
discussing with your client, just wanted to check in, and we're happy to provide any additional information that might be
useful, as always.
thank you,
From: Jill Greenfield
Sent: Saturday, February 22, 2020 17:09
To:
)
Cc: Kyle Phillips
>; Louise Scott
is
EFTA00028764

=== Page 4 ===
is
)
Subject: Re: Epstein investigation
Thanks
Understood
I will call tomorrow
Regards
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
Sent from my iPhone
On 22 Feb 2020, at 21:51,
)
wrote:
Jill,
No problem at all, we understand this takes time, and we appreciate you getting back to us, and we're very grateful that
your client is open to speaking with us.
On your questions, we are certainly fine with the first two questions / requests - we're happy to meet with you and your
client in an initial conversation, during which we can do the kind of introductions and explanations we've done with you
(and that we do with all victim witnesses we meet), including answering any questions to the best of our ability, and
then to take a break and have a more substantive discussion later on.
Regarding the friend, does that individual also represent her as counsel? We aren't normally able to include individuals
in addition to the witness and counsel in an interview-what does sometimes work is for someone who is providing
support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness wants to speak
with that person, which would of course be totally fine in this instance. Or if he represents her in his capacity as an
attorney then he of course could be in the interview in that role (with the only caveat that we would just want to
confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not able to pay for
third parties (including counsel) to travel in connection with witness interviews, though - if it's preferable, we certainly
could pay for your client's travel to the U.S. for the interview, including airfare and lodging, if that makes it easier for the
friend to be present? And we're happy to discuss any of this further by email or phone if that's useful - I'll be at my
desk for the next several hours and most of tomorrow, at
or we could also set a time to chat, whatever
would be helpful.
thank you,
From: Jill Greenfield
Sent: Saturday, February 22, 2020 13:55
EFTA00028765

=== Page 5 ===
To:
Cc: Kyle Phillips
>; Louise Scott
is
is
)
Subject: RE: Epstein investigation
Hello
Apologies for the slight delay. My client is willing to help but asks the following:
That there be a morning meeting at which introductions with a discussion as to the investigation and my clients
involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist.
In the afternoon and after a break, my client would be willing to answer questions, in so far as she can.
That a friend of hers be allowed to be present as well. However that friend is based in the US and would need to
be flown over to London. He is a US lawyer.
Perhaps you could let me know if this is possible?
Kind regards,
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
From:
Sent: Saturday, February 15, 2020 7:08 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
i
V.
Subject: RE: Epstein investigation
Understood - thanks very much.
From: Jill Greenfield
Sent: Saturday, February 15, 2020 07:22
To:
Cc: Kyle Phillips
>; Louise Scott
is
is
)
Subject: Re: Epstein investigation
Thanks
This is helpful. I've gone back to my client with this. I will be back in touch shortly.
Regards
EFTA00028766

=== Page 6 ===
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image003.jpg>
Sent from my iPhone
On 14 Feb 2020, at 21:43,
wrote:
Jill,
Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding some
of the additional follow-up questions you asked, and to describe in more detail for your client how we would expect to
approach any discussion with your client if she were comfortable meeting with us.
The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the
decision to meet with us but also as to any topic or question-your client would be absolutely free to determine what
topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything that
would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell her, as
we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is no
problem at all.
In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves,
explained the status of our investigation, talked about how a discussion would proceed if your client ended up being
comfortable with that, and answered in person any questions she. We have done that previously, where we do the
talking rather than asking questions in an initial meeting, and that would of course be without any requirement for
anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are able
to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in
approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client
were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or
victimization she experienced. We wrote in our first email that we would primarily be interested in talking about
topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as
always we would be guided by her comfort level.
In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and
that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet
the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a
discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment
and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in
particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell
you in advance if there came a time when we thought that might be important to address, and how we could facilitate
that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure you that
every one of us has now spoken with dozens of victims in this case, and every one of us has extensive experience more
generally working with victims and working on cases involving sex offenses. We are proud of how we have been able
to work with victims in this case especially, given all of the circumstances, and we absolutely would take the same
sensitive approach with your client as we have with the many other victims in this case who have spoken with us.
EFTA00028767

=== Page 7 ===
Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how our
process works, and answer any questions your client has in person, we would absolutely be happy to do that with no
obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could just address
the general subject of her employment, for example. But no obligation and no pressure. We continue to appreciate
your and her willingness to even broach the possibility of a discussion, and we hope this is helpful.
thank you very much,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Saturday, February 08, 2020 14:25
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
)
is
Subject: RE: Epstein investigation
Jill,
Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the
most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The
only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign
country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't
believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's
useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just
the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise we're
of course happy to travel to her.)
Regarding access to notes, it would principally be the investigative team-so again, the prosecutors and the FBI team
working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not
generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types up
those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but I
can also check on that to see if I can make a more specific representation with respect to your client.
With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our
investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other
witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't
change even for individuals who are in the position of your client, who have been widely publicly reported to have
been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of
course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any
follow-up via email.
thanks,
From: Jill Greenfield
Sent: Saturday, February 08, 2020 13:17
To:
EFTA00028768

=== Page 8 ===
Cc: Kyle Phillips
>; Louise Scott
is
is
Subject: Re: Epstein investigation
Hi
Thanks for this. I've been asked who would be in the room and thereafter who would have access to any
notes made. Would her permission be sought before disclosing to any other parties or officials?
As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to
provide any comfort on this?
Many thanks
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
On 6 Feb 2020, at 21:53,
)
wrote:
Ms. Greenfield,
Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection
with our investigation into the conduct of Jeffrey Epstein.
As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to
reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to her
trauma or causing re-victimization.
As we mentioned on the phone, your client is not a target of our investigation-it sounds like the analogue in the
U.K. may be the "suspect" category-and we currently do not have reason to believe that she has committed any
U.S. federal crime. As we discussed, our knowledge of your client specifically is somewhat limited, having never
spoken to her-and therefore knowing about her only through other witnesses and records-but it certainly has
been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey
Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble
believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we
hope to speak with her.
Separately, and as we also discussed, any discussion with our team would be entirely voluntary-and that extends
not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss
particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that would
be beneficial while we're meeting, etc.
In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein and
his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked
EFTA00028769

=== Page 9 ===
directly for. That would broadly include how she came to be in contact with them, the nature and scope of her
employment, any instructions she was given relating to other women or girls, and just generally her experiences and
observations in interacting with them. We ordinarily would also be interested in understanding the general nature of
the abuse she was subjected to, but I want to emphasize that we would not need to discuss with her the specifics if
she weren't comfortable with that, and in particular we often don't even broach that subject in a first meeting.
Please let us know if you have any additional questions, and in particular whether any other information from us
would be useful, and we look forward to speaking with you again soon.
Regards,
Assistant U.S. Attorney
Southern District of New York
Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your
contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the
sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any attachments
for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at
www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and regulated
by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, 2 Swan Lane, London
EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00028770


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From:
)"
To:
(USANYS)"
(USANYS)"
Subject: RE: US V Epstein
Date: Wed, 14 Aug 2019 22:07:53 +0000
Got it - just sent them your names and email addresses.
From:
(USANYS)
Sent: Wednesday, August 14, 2019 15:17
To:
>;
(USANYS)
Subject: RE: US V Epstein
You can provide them with our contact information. Thanks.
From:
Sent: Wednesday, August 14, 2019 1:45 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: US V Epstein
FYI, among several other recent requests and communications, Epstein's defense counsel says below that they would
"welcome a call" with whoever is conducting the investigation into his death and have asked us to provide you with their
contact information. Obviously leave it entirely to you whether you believe it would be appropriate or useful for your
investigation to be in touch with them in any capacity.
Separately, they have asked us to advise the individuals working on the investigation into Epstein's death that his brother,
Mark Epstein, is represented by Stacey Richman, from the Law Offices of Murray Richman. Should you find it appropriate
or useful for the investigation to be in touch with her (or him through her), it appears that the number of her and her
father's firm is
From: Martin G. Weinberg
Sent: Tuesday, August 13, 2019 09:30
To:
>;
)
V.
>; Reid Weingarten
'Miller, Michael'
'Martin G. Weinberg'
Subject: US V Epstein
in light of yesterday's seizures of computers in the Virgin Islands from Mr Epstein's residence or residences, and in
light of the fact that emails and documents contained on some or all of these computers contain attorney-client and work
product privileged communications, I request that you provide us assurance that they will not be accessed by the "case
team" until a taint team is selected and until the procedures for a protection of those privileged communications is
established. You have agreed to that protocol for the phones seized from Mr. Epstein on July 6 and the computers etc
seized from his NYC residence shortly thereafter. I have a list of attorneys that I am prepared to send to a taint prosecutor
once one is identified to me.
Second, there remains the timing of the dismissal of the charge against Mr. Epstein. Are you awaiting a motion to dismiss
from us? Will the Indictment be nolle prossed today? Is there a reason for any delay beyond today?
EFTA00027975

=== Page 2 ===
Third, we would welcome a call with you or whoever is conducting the investigation into Mr. Epstein's death. Let us know.
Marty
Martin G. Weinberg, Esq.
Boston, MA 02116
- Office
- Cell
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.
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From:
To:
Subject: Call w/ SDNY re: discovery, Epstein investigation
Date: Thu, 22 Oct 2020 17:01:48 +0000
Importance: Normal
Attachments: unnamed
EFTA00028475


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=== Page 1 ===
Event: Accepted: call with USA of NDGA re: Epstein
Start Date: 2019-03-07 18:00:00 +0000
End Date: 2019-03-07 18:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-03-05 21:53:36 +0000
Date Modified: 2019-03-05 21:53:36 +0000
Priority: 5
DTSTAMP: 2019-03-05 21:28:44 +0000
Attendee:
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: motions
Date: Thu, 20 May 2021 00:05:11 +0000
Attachments: Government_Opposition_to_Defense_Supplemental_Pretrial_Motions_v2.docx
Full doc attached, thanks! I added three sentences into the intro paragraph to summarize my sections.
From:
Sent: Wednesday, May 19, 2021 7:56 PM
To:
Cc:
is
Subject: Re: motions
Does anyone want to review the full doc once
circulates? I can fill out the into paragraph, add in the docket cite to my
section, and then send to the chiefs.
On May 19, 2021, at 7:40 PM,
wrote:
Sorry, just realized you already sent me the master doc. Will incorporate now and send the full version around shortly.
From:
Sent: Wednesday, May 19, 2021 7:39 PM
To:
is
is
Subject: RE: motions
Attached are my sections. Thanks very much for your patience with me on this, team. Between the move and getting
sick, I've had trouble keeping on top of things over the past week. Happy to incorporate this into the master doc if you
want to send it to me.
From:
Sent: Wednesday, May 19, 2021 5:28 PM
To:
is
is
Subject: RE: motions
Yes, good idea - I will add that in when I get the doc back from
Thanks, all!
From:
Sent: Wednesday, May 19, 2021 5:22 PM
To:
;
Subject: RE: motions
EFTA00028697

=== Page 2 ===
Updated version attached - I've accepted all edits and added no new edits (nice work, team). Just one question for
,
this goes to you next. If you can add your points when you edit, that would be great.Thanks.
From:
Sent: Wednesday, May 19, 2021 3:45 PM
To:
is
is
Subject: RE: motions
Here is a current draft of the opposition. I wanted to circulate this so others could start editing/reviewing the other
sections. My suggestions/nits are in track changes.
From:
Sent: Wednesday, May 19, 2021 11:49 AM
To:
is
is
Subject: motions
Team,
Checking in on the status for the motions. I'm attaching the NPA point draft, which can be folded in. Can folks let me
know the status of pending motion points, for planning purposes? I think our deadline to get this to the chiefs is EOD
today, so ideally we'd combine this by this afternoon and circulate quickly around the team for edits.
Thanks all-
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
"
To:
Subject: short form update
Date: Fri, 04 Dec 2020 16:53:40 +0000
Attachments: PC_Unit__Short_Form_Update.12.4.20.docx
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
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=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: Re: USVI AG
Date: Wed, 02 Dec 2020 14:54:34 +0000
Embedded: Re:_USVI_AG.msg
Sender:
Subject: Re: USVIAG
Message-Id: <5737973D-8D63-4EA2-8778-57E700DB26C1@usa.doj.gov>
To:
EFTA00027384


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein -- Release of USMS information
Date: Fri, 13 Sep 2019 18:12:39 +0000
Not. At. All.
From:
(USANYS)
Sent: Friday, September 13, 2019 2:08 PM
To:
(USANYS)
Subject: FW: Epstein -- Release of USMS information
Do you know what she's talking about?
From:
(USANYS)
>
Sent: Friday, September 13, 2019 2:01 PM
To:
(USANYS)
>;
(USANYS)
V.
(USANYS)
Cc:
(USANYS)
i
(USANYS)
Subject: Epstein -- Release of USMS information
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
EFTA00029311


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=== Page 1 ===
From:
Subject: RE: Epstein Guards/ OIG Report
Date: Fri, 21 May 2021 20:28:59 +0000
Attachments: 2021.05.21_Letter_re_DP_Agreements_v3.DRAFT_TO_OIG.pdf
Hi
Per our conversation just now, attached is a draft of the letter we intend to submit shortly. As you'll see in the first bullet
point, we reference the DOJ-OIG review. We do not plan to make mention of a report, although if asked at a court
conference whether there will be a report, we plan to say that we don't know, and that OIG's normal process is to prepare
a report but we don't know whether it will be made public or not.
Please let us know if you have any objections to the language in the letter. Thanks again for the speedy response, we very
much appreciate it.
From:
(USANYS)
Sent: Friday, May 21, 2021 2:10 PM
To:
Subject: RE: Epstein Guards/ OIG Report
Thank you,
From:
Sent: Friday, May 21, 2021 2:09 PM
To:
Cc:
(USANYS)
Subject: RE: Epstein Guards/ OIG Report
I'm following up internally and will get back to you, or have someone from OIG get back to you. Thanks.
From:
(USANYS)
Sent: Friday, May 21, 2021 1:46 PM
To:
Subject: Epstein Guards/ OIG Report
Hi
EFTA00028580

=== Page 2 ===
We were hoping you could assist us with getting in touch with the OIG lawyer who is responsible for preparing the report
on Epstein's suicide. We have been trying to get in touch with
who was previously handling the
investigation, but understand he may have left the office. The time sensitivity is that we plan to file a public letter by close
of business today regarding reaching a deferred prosecution agreement with the two guards on duty that night who have
been charged with falsifying records. The guards have agreed to sit for an interview with our office and DOJ-OIG, and
we'd like to state in the letter that the interviews would occur as part of an ongoing OIG investigation that we expect
would lead to a public report. However, we don't want to make this representation unless DOJ-OIG is comfortable with it.
I'm happy to discuss by phone if convenient.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
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=== Page 1 ===
Event: Epstein Oral Argument-- Second Circuit
Start Date: 2019-03-06 15:00:00 +0000
End Date: 2019-03-06 17:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-02-05 17:16:21 +0000
Date Modified: 2019-02-05 17:16:21 +0000
Priority: 5
DTSTAMP: 2019-02-05 16:57:00 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
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=== Page 1 ===
From:
Subject: Hammad memo
Date: Thu, 05 Dec 2019 00:35:04 +0000
Embedded: Hammad_Memo - Keith_Outlaw.msg; Hammad_Memo_-_Steven_Lopez.msg;
Hammad_Memo - Epstein_Death_Investigation.msg
Hi
Attached are a few samples.
EFTA00027880


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=== Page 1 ===
From:
To:
Subject: US V. Epstein
Date: Thu, 01 Apr 2021 13:11:02 +0000
Hello
PAE talked with their technical team and they have indicated that all of the 109,853 records in the below saved search are
empty attachments of EMLX files that were provided and were extracted with an image placeholder indicating that the
attachment could not be exported.
US V. Epstein (SW Returns) - Image for this documents is not exported - https://d1pe.nss.pae.com/Relativity/go?
id=2370462-4350982
The majority of the parent documents have "partial" in the file name. The 109,853 records with the image slip sheet
stating that the image for this documents is not exported appear to be data where there were certain attachments that
were not captured by the data custodian.
Please let me know if there are any questions.
Thank you.
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=== Page 1 ===
From: Christian Everdell
To:
)"
i
Laura Menninger
,
(USANYS)"
Cc: Jeff Pagliuca
^
"Bobbi Sternheim
(
)"
(USANYS) [Contractor]"
(USANYS) [Contractor]"
(USANYS) [Contractor]"
)"
"Thomas J. Powers"
Subject: RE: Discovery Issues
Date: Mon, 24 May 2021 18:50:00 +0000
Inline-Images: image001.jpg; image002.jpg
Great. Thanks,
From:
)
[mailto:
Sent: Monday, May 24, 2021 2:49 PM
To: Christian Everdell; Laura Menninger;
);
(USANYS)
Cc: Jeff Pagliuca; Bobbi Sternheim
(
);
(USANYS) [Contractor];
(USANYS) [Contractor];
(USANYS) [Contractor];
); Thomas J. Powers
Subject: RE: Discovery Issues
Chris,
I will connect Tom on a separate email chain with our paralegals, who can help set him up with a USAfx account.
Best,
From: Christian Everdell
Sent: Monday, May 24, 2021 1:53 PM
To:
)
>; Laura Menninger
is
)
is
;
(USANYS)
Cc: Jeff Pagliuca
>; Bobbi Sternheim
(
is
(USANYS) [Contractor]
is
(USANYS) [Contractor]
is
(USANYS) [Contractor]
is
>; Thomas J. Powers
Subject: RE: Discovery Issues
I don't think C&G has a USAfx account. Can you set us up with one so that we can receive the new discovery? I have cc'd
Tom Powers from my office. Please include him on the response.
Thanks,
Chris
From:
)
[mailto:
Sent: Thursday, May 20, 2021 10:46 PM
EFTA00028646

=== Page 2 ===
To: Laura Menninger; Christian Everdell;
);
(USANYS)
Cc: Jeff Pagliuca; Bobbi Sternheim
(
);
(USANYS) [Contractor];
(USANYS) [Contractor];
(USANYS) [Contractor];
)
Subject: RE: Discovery Issues
Counsel,
Today we have an additional discovery production ready to send to you. This production is small enough to produce via
USAfx. Please let us know if you do not already have a USAfx account, in which case our paralegals (cc'd) can assist you in
creating an account. We are also sending a CD containing this production to the MDC via FedEx.
Attached please find a cover letter accompanying this production. As you will see in the letter, the majority of this
production consists of materials we are providing in response to your requests for additional information regarding the
SUPP production (referenced in the below email exchange). I am also attaching the excel spreadsheet referenced in the
cover letter to assist in your review of the materials from the SUPP production.
Please let us know if you have any further questions regarding the SUPP production or if you have any difficulty accessing
the materials.
Best,
From:
Sent: Tuesday, May 11, 2021 10:42 PM
To: Laura Menninger
>; Christian Everdell
is
)
is
(USANYS)
Cc: Jeff Pagliuca
>; Bobbi Sternheim
(
Subject: RE: Discovery Issues
Laura,
I am working with our paralegals to look into your requests below. Our paralegals are also still working on the list of files
that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as we are able to provide an update
on these issues, I will reach back out.
Best,
Assistant United States Attorney
Southern District of New York
From: Laura Menninger
Sent: Friday, May 7, 2021 4:53 PM
To:
>; Christian Everdell
is
(USANYS)
EFTA00028647

=== Page 3 ===
Cc: Jeff Pagliuca
>; Bobbi Sternheim
Subject: RE: Discovery Issues
-
Also following up on your response to Chris. We have had a chance to take a look at these files again.
For the SUPP production, many of the files were produced as PDFs, which seems as though they were converted prior to
production. As I understand it (which is admittedly limited), carved or deleted files can still contain application metadata.
We request that as to the SUPP production, you:
a. Provide a list of all files that were carved or deleted;
b. Confirm if all those files were produced in native format or if any were converted to PDF;
C. If any were converted, provide additional information including the MIME type (for all), and if available from
application metadata original file name, file dates, etc. This would amount to the equivalent of the index you provided for
SDNY011.
d. In the absence of (b), confirm that no application metadata was recovered from those files which might indicate file
creation/modified dates
Please let me know if you have any questions.
Thanks,
Laura
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
(Office)
From:
Sent: Friday, April 23, 2021 10:30 AM
To: Christian Everdell
is
is
(USANYS)
Cc: Jeff Pagliuca
>; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Chris,
Following up on these issues:
For #3, the attachments were not recovered from the searched devices. We do not have them, which is why they
were not produced.
For #4, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was
available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none
is viewable, except for data showing when a particular file was saved to a drive by the investigative team or
prepared for production. I am not aware of any additional metadata in our possession that you do not have for
these files.
For #5, those photographs were not processed by CART, which is why they do not have a CART number. They came
from the CDs that your team reviewed last week. The available metadata for those photographs was produced in
two excel spreadsheets with the same production - one with metadata for nude images (which were contained on
one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were
produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am
EFTA00028648

=== Page 4 ===
working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows
in the spreadsheet.
For #6:
The SDNY_GM_SUPP contain electronic files recovered from Epstein's devices. As noted above, those files
have the same metadata on the hard drive that was available when the FBI seized each file. For files that
were carved or deleted, no metadata was recovered, so none is viewable.
The videos from SDNY005 (October 20, 2020 production) were converted by a vendor from VHS and cassette
tapes, so there is no metadata to provide. The Sept-Octo 2020 dates reflect when these recordings were
converted by our vendor.
The SDNY011 (November 9, 2020 production) consists of images from the CDs seized from Epstein's
residences, which you reviewed last week. As referenced above, those photographs were not processed by
CART, which is why they do not have a CART number. As referenced above, the available metadata for those
photographs was produced in two excel spreadsheets with the same production - one with metadata for
nude images (which were contained on one of the hard drives you reviewed last week), and one with
metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I
mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey
to you which Bates numbers correspond with which rows in the spreadsheet.
Best,
Assistant United States Attorney
Southern District of New York
From:
Sent: Tuesday, March 30, 2021 11:10 PM
To: Christian Everdell
i
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; ; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Chris,
That all makes sense, thanks very much. I will reach back out once I have conferred with our vendor and have answers for
you on #3-#6.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00028649

=== Page 5 ===
From: Christian Everdell
Sent: Tuesday, March 30, 2021 10:58 PM
To:
is
V.
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Apologies for the late response on this. It seems like it would be better to confer after you have heard back from your
vendor, since the answers to #3-#6 will depend on what the vendor says. And I believe we have now resolved #7.
As for #1 and #2, I will call
at MDC and represent to her that we have your concurrence to send the
drive directly to Ms. Maxwell. If she agrees, we can add the additional productions to our drive before we send it. If she
refuses, we will take it up with Judge Nathan.
Thanks,
Chris
From:
)
[mailto:
Sent: Monday, March 29, 2021 3:36 PM
To: Christian Everdell;
);
(USANYS)
Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim
(
)
Subject: RE: Discovery Issues
Chris,
We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please
let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial
responses:
1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to
the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking
the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to
Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC
legal counsel the opportunity to note their objections to Judge Nathan.
2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a
new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive
if you would like to provide one for us.
3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them.
4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said,
similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files
EFTA00028650

=== Page 6 ===
recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized
each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data
showing when a particular file was saved to a drive by the investigative team or prepared for production.
5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY_GM_00467566 though
SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the
CDs that were recovered during those searches, so they did not come from any of the electronic devices that were
the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I
have asked our vendor to look into this issue and will get back to you when I have spoken with them.
6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I
note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive that
was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so
none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the
SDNY011 load file (Bates range SDNY_GM_00467566 though SDNY_GM_00514100) were seized during the 2019
searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so
they did not come from any of the electronic devices that were the subject of extractions by CART. As a result,
these images would not have CART numbers.
7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to
them.
Best,
Assistant United States Attorney
Southern District of New York
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; ; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
EFTA00028651

=== Page 7 ===
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY_GM_SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
EFTA00028652

=== Page 8 ===
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From:
"
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: Fwd: Sasse letter
Date: Mon, 12 Aug 2019 12:40:12 +0000
Here is the letter that
was referencing. Doesn't mention our office or an investigation into our office.
Begin forwarded message:
From:
"
(USANYS)"
Date: August 12, 2019 at 8:38:51 AM EDT
To:
"
(USANYS)"
Cc:
"
(USANYS)"
Subject: Sasse letter
https://www.sasse.senate.gov/public/_cache/files/c4aa769e-3f2d-43a4-a550-e0e4c15390ad/08-10-2019--sasse-
letter-to-ag-barr-re-epstein-suicide.pdf
EFTA00027093


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=== Page 1 ===
From: "
To:
Subject: RE: emails
Date: Sat, 17 Aug 2019 :17:05 +0000
Attachments: MCC_Timeline.xlsx; 8.9 - 8.10_Timeline.pdf
As discussed, please feel free to have
call me to discuss what briefing materials he needs.
It is our preference that you guys, where possible, not draft briefing materials yourselves.
Attached is the latest draft of the timeline we put together, which gives an overview of the relevant events.
I am also attaching a timeline we put together of the video review and internet search history.
it would be very
helpful to fill in as much detail as possible on the video review including what direction they are walking (using the maps).
If you want to write the notes out we can add them into the spreadsheet.
will be in all weekend so feel free to
give us a call with any questions.
From:
Sent: Saturday, August 17, 2019 12:20 PM
To:
Subject: RE: emails
There's a lot of information in this case and I think we are all getting swamped. I know we are trying to review and retain
all the info while also doing the enforcement and investigative steps. Our boss said you guys did a pretty comprehensive
power point? Would you guys mind providing that or anything you guys prepared to keep track of the case, I know it
would help me out a little, I feel like I'm drowning in information. Apologies.
-
On Aug 17, 2019 11:59 AM,
wrote:
From:
Sent: Saturday, August 17, 2019 11:56 AM
To:
Subject: emails
EFTA00027177

=== Page 2 ===
I am requesting emails for the following people, please let me know if there are any additions.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
New York, NY 10004
(Office)
(Cell Phone)
EFTA00027178


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=== Page 1 ===
From:
To:
Cc:
Subject: Hard drive for GM
Date: Tue, 05 Oct 2021 21:41:10 +0000
Attachments: 2021.10.05 MDC - Maxwell_PASSWORD.docx; 2021.10.05_MDC_- -
Maxwell_MAIN.docx
Hi all,
We received the thumb drive from defense counsel to load the latest discovery production onto it for Maxwell, and the
production has been loaded onto it. Could you please confirm the attached letters are good to go?
Thanks,
Paralegal Specialist
U.S. Attorney's Office I
SDNY
1 Saint Andrew's Plaza
New York NY 10007
EFTA00029224


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Sun, 11 Aug 2019 00:18:38 +0000
Just FYI - NBC plans to report that he hanged himself with a bedsheet either by a bar on the window or the
bedpost.
Sent from my iPhone
EFTA00027260


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: RE: epstein
Date: Mon, 08 Jul 2019 17:00:05 +0000
Importance: Normal
These things are no longer sealed, of course
From:
Sent: Monday, July 8, 2019 12:16 PM
To:
Subject: RE: epstein
Of course - attached.
From:
Sent: Monday, July 08, 2019 12:13
To:
Subject: epstein
Pls send me the indictment and the Detention Memo. Tx.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00028312


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=== Page 1 ===
From:
(NY) (OGA)
To:
(USANYS)"
Subject: FW:
Date: Tue, 14 Jul 2020 20:22:54 +0000
Sure gimme a call at 5
-
On Jul 14, 2020 4:12 PM,
(USANYS)'
wrote:
Hi
Hope all is well. Are you available for a quick call regarding this 302? Trying to run down how Lt.
got the number
for
Thanks in advance!
Original Message
From:
(NY) (FBI)
Sent: Tuesday, July 14, 2020 2:51 PM
To:
(USANYS)
Subject:
Hey
When looking through my case file, this is where
documented the phone number and last call made by Epstein. Let
me know if you need anything else
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00028773


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=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
Subject: RE: Updated vic list
Date: Fri, 23 Aug 2019 00:25:50 +0000
did not answer. VM is full. Sent a text.
From:
) [mailto:
Sent: Thursday, August 22, 2019 8:15 PM
To:
(NY) (FBI)
Subject: RE: Updated vic list
Can you give me a call real quick? I just need to know what the deal is for
and
From:
(NY) (FBI)
Sent: Thursday, August 22, 2019 7:57 PM
To:
)
Subject: Updated vic list
EFTA00027344


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=== Page 1 ===
AO 93 (Rev. 11/13) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
District of New Hampshire
In the Matter of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
THE USE OF A CELL-SITE SIMULATOR TO LOCATE
)
THE CELLULAR DEVICE ASSIGNED CALL NUMBER
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
District of
New Hampshire
(identify the person or describe the property to be searched and give its location):
See Attachment A.
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):
See Attachment B.
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10:00 p.m.
at any time in the day or night because good cause has been established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to
(United States Magistrate Judge)
Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
$ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
for 30 days (not to exceed 30)
until, the facts justifying, the later specific date of
Date and time issued:
Judge's signature
City and state:
Concord, NH
Printed name and title
EFTA00029476

=== Page 2 ===
AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.
Date:
Executing officer's signature
Printed name and title
EFTA00029477

=== Page 3 ===
ATTACHMENT A
This warrant authorizes the use of the electronic investigative technique described in
Attachment B to identify the location of the cellular device assigned phone number
whose wireless provider is AT&T, and whose listed subscriber is "G Max."
4
EFTA00029478

=== Page 4 ===
ATTACHMENT B
Pursuant to an investigation of GHISLAINE MAXWELL for a violation of 18 U.S.C.
§§ 371, 2422, 2423(a), and 1623, this Warrant authorizes the officers to whom it is directed to
determine the location of the cellular device identified in Attachment A by collecting and
examining:
1. radio signals emitted by the target cellular device for the purpose of communicating with
cellular infrastructure, including towers that route and connect individual communications;
and
2. radio signals emitted by the target cellular device in response to radio signals sent to the
cellular device by the officers;
for a period of thirty days, during all times of day and night. This warrant does not authorize the
interception of any telephone calls, text messages, other electronic communications, and this
warrant prohibits the seizure of any tangible property. The Court finds reasonable necessity for
the use of the technique authorized above. See 18 U.S.C. § 3103a(b)(2).
5
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=== Page 1 ===
From:
"
(USANYS)"
To:
Cc: "
(USANYS)"
Subject: Epstein
Date: Mon, 15 Jul 2019 00:09:15 +0000
Importance: Normal
We have his bail argument before Judge Berman tomorrow at 10 AM. While I think we are feeling optimistic,
were we to lose, and were we to want to appeal, is that a decision we can make in house? Or does that need to be
approved by DC?
Sent from my iPhone
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=== Page 1 ===
From: Nathan NYSD Chambers
To:
Subject: 20cr330, U.S. V. Maxwell
Date: Thu, 14 Oct 2021 21:29:57 +0000
Attachments: 20cr330_Order_10.14.21.pdf
Counsel:
Attached please find an order issued by Judge Nathan in this case. It will be filed on the public docket tomorrow
morning. Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
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From:
)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Sat, 10 Aug 2019 19:06:47 +0000
Hey thank you, we really appreciate it -- it's obviously shocking even given all the circumstances, and extremely
disappointing for the victims (and, y'know, the cause of justice more generally). I think we're just working
through the many phone calls and updates today, but it's thoughtful of you to reach out so thanks very much
again.
Original Message
From:
(USANYS)
Sent: Saturday, August 10, 2019 11:11
To:
)
Subject: Epstein
All,
Sorry to see the sad news about Epstein. I'm sure you're shaken.
,
and I went through a similar
suicide three years ago with a securities fraud defendant. If you need anything, we're here for you. You were
doing you're job and obviously no one wishes harm to come to anyone.
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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: Checking in on Epstein FOIA Review
Date: Wed, 28 Apr 2021 20:49:23 +0000
Hi
Thank you for the update! I think we're going to try for a 2-day extension, but because we're a little behind and there is no
guarantee PAE will grant the extension, we are still going to need the review completed today.
Thank you again!
From:
)
Sent: Wednesday, April 28, 2021 2:05 PM
To:
(USANYS)
Subject: RE: Checking in on Epstein FOIA Review
Hi
I will do my absolute best to get these reviewed today, but you may not get them until very late tonight. If it is possible to
ask for an extension (you can blame me!), then that would probably make sense.
Thanks,
From:
(USANYS)
Sent: Wednesday, April 28, 2021 12:21 PM
To:
Subject: RE: Checking in on Epstein FOIA Review
Hi
Sorry again to bug on this but, in part because of a few other developments in the case, I think BOP might have real
trouble meeting the Friday deadline if we don't get the rest of the Tartaglione redactions to them today. I want to make
sure we're still on track for that. If not, then I think we could try to get some small extension into next week for some
portion of the documents, although I think this would annoy PAE. Unfortunately, under his rules, we'd have to make that
extension request today (and I'd need to get the Times's position on it). I can make that happen if we need to, but I need
to know soon if it's necessary. Please let me know if we're on track to have the Tartaglione review for the second half of
the docs complete today, or if we need to consider other options.
Also, if there is any portion finished and it can be easily sent my way, please do that so I can get BOP started on it.
Thanks!
From:
(USANYS)
Sent: Tuesday, April 27, 2021 6:24 PM
To:
)
Subject: RE: Checking in on Epstein FOIA Review
EFTA00027395

=== Page 2 ===
Ok, thanks,
From:
Sent: Tuesday, April 27, 2021 5:55 PM
To:
(USANYS)
Subject: RE: Checking in on Epstein FOIA Review
Hey
Very sorry, I've been swamped and haven't even gotten to start yet. Will do my best to make a dent tonight and get this
finished for you by EOD tomorrow.
Thanks,
From:
(USANYS)
Sent: Tuesday, April 27, 2021 3:36 PM
To:
Subject: Checking in on Epstein FOIA Review
Hi
Sorry to bug you on this, but for planning purposes I wanted to check in on the Tartaglione review of the second half of
the Epstein FOIA documents. Can you share any sense of when your review will be complete?
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
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=== Page 1 ===
From:
To:
Subject: Travel Authorization
approved by
, now awaiting further
approval
Date: Tue, 28 Jan 2020 17:12:15 +0000
Importance: Normal
Dear
Travel authorization
has been approved by
, now awaiting further approval.
Trip ID:
Traveler name:
Purpose: R20NYS13342 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-08
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
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
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.
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=== Page 1 ===
From:
)"
To:
(
)"
Subject: RE: Epstein
Date: Mon, 15 Jul 2019 21:38:10 +0000
Importance: Normal
Not really - ordinarily the defendant provides financial information to Pretrial Services when he's arrested; here, Epstein
declined to do so and told the court he would submit financial information directly to the court. So it's not something we
asked for in particular.
From:
Sent: Monday, July 15, 2019 17:37
To:
Subject: Re: Epstein
We had originally requested this document, correct?
Sent from my iPhone
On Jul 15, 2019, at 5:09 PM,
wrote:
Originally submitted by defense counsel under seal and then unsealed by the court.
Sent from my iPhone
On Jul 15, 2019, at 17:08,
(
wrote:
I'm unable to open PACER, but assume the document that was just posted about his finances was submitted by
defense counsel?
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I Mobile:
I
Press Office: (212) 637-1020
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=== Page 1 ===
From:
Cc:
Subject: Lead U.S. prosecutor in '08 Epstein case - who sources say wanted to charge him - resigns
Date: Fri, 09 Aug 2019 11:55:57 +0000
https://www.miamiherald.com/news/state/florida/article233668342.html
Sent from my iPhone
EFTA00027918


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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
July 11, 2019
VIA ECF
The Honorable Richard M. Berman
United States District Court
Southern District of New York
United States Courthouse
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter in response to the defendant's motion for
leave to file a supplemental financial disclosure under seal (the "Sealing Motion") in connection
with his motion for pretrial release (the "Bail Motion").
The Government takes no position on the defendant's application, but notes that as of this
filing the Government still has not yet received any financial disclosure or information from the
defense in connection with the defendant's application for bail. It is now more than three days
following the defendant's initial presentment, more than seven hours after the defendant's deadline
to file his Motion, and less than 24 hours before the Government's deadline to reply. There is no
reason that the defendant need have waited until this evening to submit his Sealing Motion, and
the Government cannot meaningfully respond to a Bail Motion that contains no material financial
information, either under seal or otherwise.
Accordingly, the Government respectfully requests that its deadline to respond to the
defendant's Bail Motion be extended to at least 24 hours following the defendant's disclosure of
any financial information upon which he intends to rely in connection with the Motion. Should
EFTA00028418

=== Page 2 ===
Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 2 of 2
Honorable Richard M. Berman
United States District Judge
July 11, 2019
Page 2
that require adjourning the bail hearing, the Government respectfully requests that the hearing be
moved to a date and time convenient for the Court and sufficient to permit the Court to review the
Government's reply.
Very truly yours,
GEOFFREY S. BERMAN
United A States Attorney
By:
/
/
Assistant United States Attorney
Southern District of New York
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
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=== Page 1 ===
From: Jack Scarola
To:
)"
Cc:
)"
)"
Subject: Re: Epstein
Date: Wed, 07 Aug 2019 22:39:41 +0000
I have forwarded your message to
On Aug 7, 2019, at 4:48 PM,
)
wrote:
Mr. Scarola,
We have had difficulty contacting Ms.
in connection with our investigation. Are you in touch with her and able to
set up a meeting with us? We would be interested in speaking with her and can travel to Florida to do so.
thank you,
From: Jack Scarola
Sent: Wednesday, August 07, 2019 08:54
To:
Cc: ROBERT C. JOSEFSBERG
; Brad Edwards
Subject: Re: Epstein
For whatever value it may have in connection with your pending prosecution of Jeffrey Epstein, one of his
victims,
,
who was repeatedly molested in Florida beginning at age 14, received multiple gifts
of lingerie from Epstein shipped to her in Florida from NY.
may be reached at
, and is
willing to speak to investigators.
|
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
communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at
and destroy all copies of the original message. Thank you.
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=== Page 1 ===
From:
To:
Subject: Epstein Case A Turning Point In Prosecutorial Accountability?
Date: Tue, 12 Feb 2019 11:29:40 +0000
Importance: Normal
Epstein Case A Turning Point In Prosecutorial Accountability?
By Jody Godoy
Share us on:
Law360 (February 11, 2019, 9:30 PM EST) --
The U.S. Department of Justice is reviewing a deal
that a Trump administration official cut as a federal
prosecutor, and the case has added fuel to a bid to
change how the DOJ handles prosecutorial
misconduct probes.
Last week it came to light that the DOJ's Office of
Professional Responsibility had opened an
investigation into how Labor Secretary Alexander
Acosta handled a 2008 investigation into an underage
sex trafficking ring when he was a U.S. attorney. The
Miami Herald reported in November that Acosta and
another prosecutor worked with lawyers for
billionaire Jeffrey Epstein to keep the public eye off
the case and have Epstein charged with state crimes
even though investigators had gathered evidence of
an international trafficking scheme.
The case has become part of a rallying cry for some
members of Congress who instead want to see such
investigations into potential prosecutorial misconduct
done by the DOJ's Inspector General, which is
independent from the agency.
The law currently gives the OIG power to investigate
alleged misconduct by DOJ employees, except when
the claims "relate to the exercise of the authority of
an attorney to investigate, litigate, or provide legal
EFTA00029471

=== Page 2 ===
advice."
In January, the U.S. House of
Representativesunanimously passed a bill called the
Inspector General Access Act that would delete that
exception.
At the hearing, Rep. Debbie Wasserman Schultz, D-
Fla., said that while lawmakers on both sides of the
aisle have long supported the concept, the situation
has become "urgent."
"The American people and the victims of these
horrific crimes deserve to know why justice was not
served in this disturbing case, and the lack of
transparency still cloaking it is deeply disturbing,"
Wasserman Schultz said at the hearing, referring to
the Epstein case.
Since 1975, the OPR has been in charge of fielding
and investigating complaints against the DOJ's
attorneys. The office opens full-blown investigations
into a fraction of those complaints, ultimately
determining how the incident occurred, be it a
mistake or willful misconduct.
In the past, prosecutors have been suspended or
reprimanded. In some cases where the OPR has
found that the conduct didn't rise to misconduct,
findings get reported back to the attorney's
supervisor.
"If you work in the Justice Department, it is really
scary to be reviewed by OPR," said Jennifer Rodgers,
a former federal prosecutor who now serves on the
advisory board at the Center for the Advancement of
Public Integrity at Columbia Law School.
But sometimes the attorneys the OPR investigates are
long gone by that point. According to the most recent
EFTA00029472

=== Page 3 ===
OPR report from 2017, six of the 13 attorneys who
were found to have committed professional
misconduct in that year had already left the DOJ by
the time the investigation concluded. The office
authorized reporting most of them to their state bar
associations.
While the OPR focuses on individuals, Rodgers said
the OIG's mandate is broader and involves putting
out public recommendations for systemic change
within the DOJ. The OIG already gets to review and
issue advice on issues that involve other DOJ staff,
such as FBI agents. The bill before Congress would
put attorneys on the same footing.
"This may be the case that pushes that over the line.
And I am OK with that," Rodgers said of the Epstein
matter.
The OPR has also changed over the years. In 2015,
the office started documenting whether its findings
actually resulted in discipline after a recommendation
from the Government Accountability Office. The
office also expanded the number of DOJ attorneys
who could be reported to bar associations.
Still, some members of Congress believe the
Inspector General is better suited to the job, pointing
to the fact that the OPR is not independent from the
DOJ and has fewer reporting requirements.
The Inspector General Access Act is pending before
the Senate Judiciary Committee. Similar bills have
been proposed before, including one last year by a
group of Republican senators including then-
Judiciary Committee head Chuck Grassley of Iowa.
Grassley supports the 2019 bill, his staff confirmed.
DOJ Inspector General Michael Horowitz wrote to
Congress in support of the bill in November, saying
EFTA00029473

=== Page 4 ===
as a statutorily independent agency the OIG is better
situated to investigate misconduct claims than the
OPR, which reports to the deputy attorney general.
"The credibility of the department's disciplinary
process is inevitably reduced when the responsible
component operates under the direction of the
department's senior leadership and is not subject to
public scrutiny because of limited transparency,"
Horowitz wrote.
The OPR does issue an annual report breaking down
the number of complaints received and how many
resulted in action. The vast majority of complaints
pass through the office without further action. In
2017, 72 of the 636 complaints the OPR received
resulted in a formal inquiry or investigation. The
OPR report also gives the outlines of what happened
in a sample of the cases.
Bruce Green, a Fordham University law professor
who writes on prosecutorial misconduct, said the
OPR's summaries aren't enough to reassure the
public, particularly given that the office is overseen
from within the DOJ.
"Do they go too easy? Are they too willing to credit
what prosecutors told them? It's hard to know,"
Green said.
The biggest issue is the lack of independence, Green
said. He pointed to the example of John Yoo, the DOJ
attorney in the Bush administration who famously
authored memos offering a legal justification for
tactics such as waterboarding that the CIA used after
the 9/11 terrorist attacks.
The OPR issued a report in 2009 finding that Yoo and
Jay Bybee, another DOJ attorney, had committed
professional misconduct and recommending they be
EFTA00029474

=== Page 5 ===
referred to the state bar for discipline. A DOJ official
vetoed the move, saying the pair had not violated a
clear standard.
Green has written that the advent of digital media
seems to have initiated a shift towards prosecutorial
accountability, particularly in the states. However,
changing the game for federal prosecutors has proven
more difficult.
He pointed to laws that were proposed but never
passed in the wake of the disastrous prosecution of
former U.S. Senator Ted Stevens, R-Alaska, on
federal corruption charges. In that case, the OPR had
concluded that two prosecutors had "engaged in
reckless professional misconduct" for not handing
over certain evidence to the defense.
"For a moment in time, there was a push to reform
discovery law. But then it died down," Green said.
--Editing by Kelly Duncan and Alanna Weissman.
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=== Page 1 ===
From:
To:
Subject: Re: Misc Correspondence re Jeffrey Epstein
Date: Tue, 15 Oct 2019 17:48:18 +0000
Received and will do, thanks.
On Oct 15, 2019, at 12:08,
wrote:
Please file this, which includes my response, in some appropriate place. Thanks.
From:
Sent: Wednesday, October 9, 2019 2:06 PM
To:
Subject: FW: Arlan Ettinger
What is the right way to handle this? It seems to be an offer by Guernsey's Auctioneers & Brokers to be retained to
handle the disposition of Epstein's property. I was assigned to respond to this. Please advise.
Thanks
From:
Sent: Wednesday, October 9, 2019 1:57 PM
To:
Subject: Arlan Ettinger
Good afternoon!
I have been advised to forward you the attached correspondence from Arlan Ettinger, President of Guernsey's
Auctioneers & Brokers. The letter is regarding the property of the late Jeffrey Epstein. As advised by Nathaniel Gamble II
from ODAG (see email attached), this has been assigned to USAO-SDNY for handling. Please let me know if you have any
questions or concerns.
Thank you very much in advance.
Best,
U.S. Department of Justice
Executive Office for U.S. Attorneys
0:
Pronouns: she/ her/ hers
EFTA00028126

=== Page 2 ===
<4319870-Email Message-RE Ettinger.pdf>
<Arlan Ettinger.pdf>
<4319870-ES Control Sheet-Ettinger.pdf>
<2019.10.15 Letter to Guernsey's.docx>
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=== Page 1 ===
From: Mariann Wang
To:
)"
, Gloria Allred
Bcc:
Subject: Re: Follow up
Date: Mon, 23 Nov 2020 02:09:48 +0000
Embedded: Re:_Follow_up.msg
Sender:
Subject: Re: Follow up
Message-Id:
Recipient:
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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
(USANYS)"
i
(USANYS)"
Subject: RE: Scan of Epstein Note
Date: Tue, 10 Sep 2019 19:49:07 +0000
is one of the guards. I think it says Noel gave him food that had been burned. Epstein kept a running list of
grievances, mostly about the conditions. That's what this appears to be.
From:
(USANYS)
Sent: Tuesday, September 10, 2019 3:43 PM
To:
(USANYS)
is
(USANYS)
Cc:
Subject: RE: Scan of Epstein Note
Who is
?
What does that say about Noel?
From:
(USANYS)
Sent: Tuesday, September 10, 2019 3:41 PM
To:
(USANYS)
is
(USANYS)
Cc:
Subject: Scan of Epstein Note
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00029307


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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 18:10:10 +0000
Inline-Images: image001.png
Thank you!!
Fron
Sent: Thursday, July 02, 2020 13:58
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations!
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
UNITED QUI PRO DOMINA JUSTITIA OF SESTION
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,
EFTA00027847

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
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=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
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AT (212) 637-2600.
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[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.
EFTA00027849


