# docs_fts_content

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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015703.pdf
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=== Page 1 ===
From: "postmaster@voip.usa.doj.gov" <postmaster@voip.usa.doj.gov>
To:
Cc: USANYS-EpsteinVictims <USANYS.EpsteinVictims@usa.doj.gov>
Subject: Voice Message Attached from
Date: Wed, 07 Aug 2019 17:36:08 +0000
Attachments:
wav
Time: Aug 7, 2019 1:36:08 PM
Click attachment to listen to Voice Message
EFTA00015703


c1: EFTA00016616
c2: DataSet 8
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016616.pdf
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=== Page 1 ===
From
To
Subject: FW: US V Maxwell
Date: Tue, 23 Nov 2021 20:13:33 +0000
Attachments: LBNAMAXT.PDF
Transcript from today's conference is attached.
From:
Sent: Tuesday, November 23, 2021 3:03 PM
To:
Cc:
Subject: FW: US V Maxwell
EFTA00016616


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c2: DataSet 8
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014285.pdf
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=== Page 1 ===
Event: Accepted: Epstein Press Meeting
Start Date: 2019-07-01 20:00:00 +0000
End Date: 2019-07-01 21:00:00 +0000
Location: 8th Floor Library
Class: X-PERSONAL
Comment:
Date Created: 2019-06-28 15:26:59 +0000
Date Modified: 2019-06-28 15:26:59 +0000
Priority: 5
DTSTAMP: 2019-06-28 15:08:49 +0000
Attendee:
EFTA00014285


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c2: DataSet 8
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014522.pdf
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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS) 4"
Cc:
(USANYS)"
)"
N
,
)"
(USANYS)"
Subject: Re: CAFIs/Epstein
Date: Mon, 01 Jul 2019 14:46:58 +0000
Importance: Normal
I will be able to call in. Thanks!
Sent from my iPhone
On Jul 1, 2019, at 9:32 AM,
(USANYS) 4
wrote:
Thanks,
I won't be able to join today, but happy to help if any issues come up.
On Jun 30, 2019, at 4:49 PM,
(USANYS)
wrote:
For those interested, the call from Friday is being rescheduled for tomorrow (Monday) at 2. I don't have dial-in info
yet, but will circulate a calendar invite shortly.
EFTA00014522


c1: EFTA00016488
c2: DataSet 8
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016488.pdf
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
November 24, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing witness materials, government exhibits, and discovery
pertinent to Ghislaine Maxwell (02879-509) is
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
/s
Assistant United States Attorneys
EFTA00016488


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c2: DataSet 8
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016038.pdf
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=== Page 1 ===
Signature Page Summary
Ghislaine Maxwell
Account Number and Description
Signature Requirement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
de 0177 2386 4771 02/12/2014
Package ID: 0093830915
1
SDNY_GM_02742191
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Intentionally Left Blank
de 0177 2386 4772 02/12/2014
SDNY_GM_02742192
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Client Information
Client Information
Client Information
Ghislaine Maxwell
Personal Information
U.S. Federal law requires us
Name
Ghislaine Maxwell
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Female
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Single
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
We may also ask to see a
driver's license or other
Contact Information
documents that will allow
Residential Address
us to identify you.
City, State, Zip Code
New York, NY 10065-7007
Please review and verify all
Home Phone
of the information that you
provided to us when you
E-mail Address
opened your Account If
you have changes,
corrections or additions,
notify your Financial Advisor
Employment Information
as soon as possible.
Employment Status
Employed
If you share assets with
Occupation
Other
another person, the net
worth figure here shows
Occupation Industry
Other
your portion only, based
Employer Name
The TerraMar Project
upon instructions you
provided.
Business Address
Investment Information:
City, State, Zip Code
New York, NY 10065 7007
This section reflects answers
you provided related to
Net Worth Information
your investment experience,
market knowledge and
Annual Income
other assets and is used to
ensure our investment
Liquid Assets (cash and marketable securities)
recommendations are
Net Worth (excluding primary residence)
suitable for your situation.
Investment Information
Years you have held investment accounts
Equities
Bonds
Futures
Options-Buy
Options-Sell
Knowledge of investments
Percentage of total investable assets held at UBS
Other
Own Home or Rent?
Own
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
3
3
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Client Information
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
Client Information
4
4
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Account Information
Account Information
Account Information
Please review the information
about each of your accounts
and notify your Financial
Advisor immediately if you
have any changes or
corrections.
For more information, please
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Please note: the account risk
profile and investment
objective below are specific only
to this account: other accounts
may have different account risk
profiles and investment
objectives.
Your Account Risk Profile for
this particular account is defined
as:
Aggressive Willing to accept
high risk to principal and high
volatility to seek high returns over
time.
Different accounts may have
different risk profiles
Your Investment Objective
Produce a Combination of
Income and Capital
Appreciation Investments
seeking both the generation of
income and growth of principal.
A senior political official is
defined as a President or Vice
President, Cabinet Member,
Supreme Court Justice,
member of the Joint Chief's
Staff, Member of Congress or
a Parliament, Chairperson,
Head or Senior Leader of a
major religious organization,
or the like.
5
5
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=== Page 1 ===
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 GHISLAINE MAXWELL
IN SUPPORT OF HER RENEWED MOTION FOR BAIL
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
EFTA00015977

=== Page 2 ===
TABLE OF CONTENTS
Page
PRELIMINARY STATEMENT
1
ARGUMENT
2
I.
The Government Concedes that Its Case Relies Almost Exclusively on the
Testimony of Three Witnesses
2
II.
The Government Has Not Carried Its Burden
4
A.
The Government Asks the Court to Ignore Ms. Maxwell's Substantial
Ties to the United States, Including Her Spouse
4
B.
Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All
of Her and Her Spouse's Assets in Support of Her Bond
5
C.
The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and
Therefore a Flight Risk Is Specious
7
D.
Refusal of Extradition from France or the United Kingdom Is Highly
Unlikely
8
E.
The Recent COVID Surge at MDC Further Justifies Bail
10
CONCLUSION
10
i
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TABLE OF AUTHORITIES
Page(s)
Cases
United States V. Chen,
820 F. Supp. 1205 (N.D. Cal. 1992)
10
United States V. Orta,
760 F.2d 887 (8th Cir. 1985)
1
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=== Page 4 ===
TABLE OF EXHIBITS
Exhibit A.
Julié Addendum Opinion (France)
Exhibit B.
Perry Addendum Opinion (U.K.)
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=== Page 5 ===
PRELIMINARY STATEMENT
The only issue before the Court is whether conditions exist that can reasonably assure
Ms. Maxwell's appearance during this case. On this renewed application, Ms. Maxwell has put
before the Court a significant bail package, supported by detailed submissions, which warrant
her release on strict conditions. She and her spouse have committed to signing a bond in the full
amount of their net worth, regardless of the ownership of the underlying assets. She has
proffered seven additional sureties, consisting of her family and close friends, many of whom are
U.S. citizens and long-time residents, who have come forward at great personal risk and have
pledged meaningful assets. The government does not challenge the good faith and bona fides of
these proposed sureties. She has provided a detailed report from a respected accounting firm,
which was further reviewed by a former IRS special agent, setting forth a statement of her
financial condition, supported by voluminous documentation. The government does not
challenge the report's findings, nor its underlying documentation. She has agreed, in writing, to
give up any right she has or could have to contest extradition and submit to all other standard
travel restrictions. And she has noted that a key representation made by the government at the
initial bail hearing as to the strength of its evidence is simply not accurate -
and there is no "significant contemporaneous documentary
evidence" that corroborates its case.
With regard to any other defendant, this record would readily support release on strict
bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute
for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the
significant additional evidence proffered to the Court and further argues that a defendant cannot
be eligible for bail (apparently on any conditions), unless she can provide an absolute guarantee
against all risks. But this is not the legal standard. United States V. Orta, 760 F.2d 887, 888 n.4,
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892-93 (8th Cir. 1985) ("The legal standard required by the [Bail Reform] Act is one of reasonable
assurances, not absolute guarantees."). Under, the Bail Reform Act, a defendant must be released
unless there are "no conditions" that would reasonably assure her presence. Here, the proposed
package satisfies the actual governing standard, and the Court should grant bail.
ARGUMENT
I.
The Government Concedes that Its Case Relies Almost Exclusively on the
Testimony of Three Witnesses
In evaluating the strength of the government's case in its prior ruling, the Court relied on
the government's proffer that the testimony of the three accusers would be corroborated by
"significant contemporaneous documentary evidence." (Tr. 82 (emphasis added)). The
government now expressly retreats from this position. It is abundantly clear from the
government's response that it has no "significant contemporaneous documentary evidence"-in
fact, it has virtually no documentary corroboration at all-and that its case against Ms. Maxwell
is based almost exclusively on the recollections of the three accusers, who remain unidentified,
concerning events that took place over 25 years ago. Moreover, the government offers no
specificity about when within the four-year period of the charged conspiracy the alleged
incidents of abuse took place. This, alone, is grounds for the Court to reconsider its prior ruling.
The few examples of documentary corroboration referenced by the government-which
are the same examples that the government touted at the initial bail hearing-pertain to Epstein,
not Ms. Maxwell. The government concedes that
(Gov. Mem. at 11 (emphasis added)). The
government further states that
(Id.
(emphasis added)). The strength of the government's case against Jeffrey Epstein is not at issue
2
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=== Page 7 ===
here. Whether or not the accusers' recollections as to Epstein are corroborated is irrelevant to
the strength of the evidence against Ms. Maxwell.
The only purported corroboration that pertains in any way to Ms. Maxwell is of marginal
value. The government references
(Id. at 11). But even the government concedes that, at best,
It is clear that the only evidence that Ms. Maxwell allegedly "groomed" the accusers or
knowingly facilitated or participated in Epstein's sexual abuse of minors will come solely from
the testimony of the three accusers. The government's case against Ms. Maxwell therefore rests
entirely on the credibility and reliability of these three witnesses.² Moreover, the substantive
counts (Counts Two and Four) are based on the testimony of only one witness, Minor Victim-1.
It is also telling that the government does not even attempt to rebut the defense's assertion that it
did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death
of Jeffrey Epstein. This confirms that the case against Ms. Maxwell was assembled after the fact
1 The government also proffers that they will have "additional witnesses." (Gov. Mem. at 11). But these are not
"outcry" witnesses who will corroborate a contemporaneous account of abuse from one or more of the accusers.
Instead, they will testify only that "both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims
when those victims were minors." (Id.). Again, the fact that Ms. Maxwell may have "met and interacted with"
someone when they were a minor proves absolutely nothing.
2 One of the witnesses has submitted a letter to the Court. While the CVRA permits the right to be heard, the letter
should be given no legal weight in the Court's bail analysis. See United States V. Turner, 367 F. Supp. 2d 319, 331-
32 (E.D.N.Y. 2005)
3
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=== Page 8 ===
as a substitute for its prosecution of Epstein. 3 The government's case is not what it represented
to the Court at the initial bail hearing, which should weigh heavily in favor of granting bail. 4
II.
The Government Has Not Carried Its Burden
A.
The Government Asks the Court to Ignore Ms. Maxwell's Substantial
Ties to the United States, Including Her Spouse
The government incorrectly argues that the renewed bail application offers no new
information and that the Court was "already aware of" the defendant's friends and family in
the United States. (Gov. Mem. at 13). The government ignores that, since the initial bail
hearing, Ms. Maxwell's spouse has come forward as a co-signor and has submitted a
detailed letter describing his committed relationship with Ms. Maxwell for over four years
and the important role she has played, and continues to play,
It also ignores that several of Ms. Maxwell's closest friends and family, many of
whom are U.S. citizens and residents, have also come forward, at considerable personal risk,
to support her bond with pledges of assets or letters of support. This information, which
was not available to the Court at the time of the initial hearing, demonstrates Ms. Maxwell's
strong ties to this country and weighs heavily in favor of bail.
Rather than address the merits, the government attempts to dismiss the significance
of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial
Services that she was in the process of getting a divorce and that her spouse did not step
forward as a co-signer at the initial bail hearing. (Id. at 13-14). The government is entirely
3 Moreover, the government failure to request
regardless of whether it was legally obligated to
do so, shows that the government has accepted the accusers' accounts without serious scrutiny. Given the
government's ongoing Brady obligations, it is unsettling that the government would simply accept
4 Contrary to the government's assertion, the defense has not abandoned our legal challenges to the indictment.
(Gov. Mem. at 10n.1). We believe we have strong arguments that have only gotten stronger with the production of
discovery. We will be making those arguments to the Court in our pretrial motions to be filed next month.
4
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=== Page 9 ===
mistaken. Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting
a divorce as an additional way to create distance between Ms. Maxwell and her spouse to
protect him
from the terrible consequences of being associated with her.
Nevertheless, in the weeks following the initial bail hearing,
She and her spouse therefore had no reason to continue
discussing divorce, which neither of them wanted in the first place. Nor was there any
reason for her spouse to refrain from stepping forward as a co-signer. In sum, the
government has offered nothing but unsupported innuendo to suggest that Ms. Maxwell's
relationship with her spouse
is not a powerful tie to this country.
The government's assertion that Ms. Maxwell must not have a close relationship
with
is particularly callous
and belied by the facts. (Gov. Mem. at 14). As her spouse explains,
(Ex. A 1 12).
B.
Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of
Her and Her Spouse's Assets in Support of Her Bond
The government's attempts to rebut the financial condition report are unavailing.
Significantly, the government does not contest the accuracy of the report, nor the
voluminous supporting documentation. In fact, the government has proffered nothing that
calls into question the report's detailed account of Ms. Maxwell and her spouse's assets for
the last five years, which addresses one of the Court's principal reasons for denying bail.
Rather than question the report itself, the government attempts to argue that Ms.
Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23).
5
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=== Page 10 ===
The report shows nothing of the sort. Ms. Maxwell, who was sitting in a jail cell at the time,
was asked by Pretrial Services to estimate her assets. Accordingly, she gave her best
estimate of the assets she held in her own name, which the government concedes she did
with remarkable accuracy considering that she had not reviewed her financial statements. 5
The government's arguments further confirm that it has lost all objectivity and will
view at any fact involving Ms. Maxwell in the worst possible light. For example, the
government asserts that Ms. Maxwell has demonstrated "sophistication in hiding her assets"
and characterizes her transfers to a trust as "funneling" assets to her spouse to "hide her true
wealth." (Id. at 24). There is nothing unusual, let alone nefarious or even particularly
sophisticated about transferring assets into a trust or a spouse. Indeed, Ms. Maxwell fully
disclosed these transactions on her joint tax returns. More importantly, all of the assets
disclosed in the financial report, whether they are owned by Ms. Maxwell or her spouse, are
included in the bond amount and are subject to forfeiture if she flees.
The government further argues that the financial condition report shows that Ms.
Maxwell has access to millions of dollars of "unrestrained funds" that she could use to flee
the country and reimburse any of her sureties for the loss of their security. (Id. at 23). That
characterization is simply untrue. First, as disclosed in the financial report, Ms. Maxwell
has procured significant loans on the basis of a negative pledge over her London property.
Second, the $4 million controlled by her spouse
could only be liquidated with considerable difficulty.
The government also faults Ms. Maxwell for not including a valuation of future
contingent assets and income that may never materialize. (Id. at 23-24). For example,
5 Moreover, for the reasons discussed in our initial memorandum, Ms. Maxwell was reluctant to discuss anything
about her spouse and clearly expressed her reluctance to Pretrial Services early on in the interview.
6
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Similarly, the financial report does not include
a future income stream for Ms. Maxwell or her spouse because it presents only historical
and current assets. Even so, Ms. Maxwell has no certain future income stream. Her spouse
and has had to liquidate his existing investments to help Ms. Maxwell. Finally, the
reference to
is gratuitous. Ms. Maxwell had no knowledge of
But the larger point is this: Ms. Maxwell has proposed a substantial bail package
with multiple co-signers and significant security. She and her spouse have pledged all of
their assets in support of the bond. Ms. Maxwell's wealth is not a reason to deny her bail. It
is a reason to set appropriately strict conditions that will result in significant financial
consequences to Ms. Maxwell and her friends and family if she leaves the country. The
proposed bail package does exactly that. 6
C.
The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and
Therefore a Flight Risk Is Specious
The government continues to assert the sinister narrative that Ms. Maxwell had "an
expertise at remaining hidden," and that it would therefore be easy for her to become a fugitive.
6 The government's argument that her spouse's moral suasion is diminished because Ms. Maxwell brought the
majority of assets to the relationship is nonsensical. (Id. at 24-25). Regardless of whose money it was to begin with,
all of the assets of Ms. Maxwell and her spouse will be forfeited if she flees and her spouse
will be
left with nothing. Furthermore, the government's assertion that they could not verify the spouse's financial
information because Ms. Maxwell did not provide his current banking information is false. (Id. at 24 n.9). The
defense provided the spouse's current banking records and only redacted the name of the bank.
7
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=== Page 12 ===
(Gov. Mem. at 20). The government suggests that purchasing a home using a trust and providing
a pseudonym to a real estate broker are indicative of her willingness and ability to live in hiding
and somehow forecast Ms. Maxwell's intention to flee. (Id.). These arguments are just further
evidence that the government will frame every fact about Ms. Maxwell in the worst possible
light. As the defense has already argued extensively in its initial brief, these steps were borne
out of necessity to protect Ms. Maxwell and her family from harassment and physical threats.
Moreover, they are not predictive of flight. There is simply no basis to conclude, based on the
measures that Ms. Maxwell was forced to take to protect herself and her family, that she would
then willingly abandon that family to become a fugitive from justice. To the contrary, she
remained in the country precisely to remain close to them and to defend her case.
D.
Refusal of Extradition from France or the United Kingdom Is Highly
Unlikely
The government dismisses Ms. Maxwell's willingness to waive her extradition rights as
to France and the United Kingdom as "meaningless" because Ms. Maxwell cannot guarantee
with absolute certainty that either country will enforce the waiver. (Gov. Mem. at 14). The
government misses the point: Ms. Maxwell's willingness to do everything she can to eliminate
her ability to refuse extradition to the fullest extent possible demonstrates her firm commitment
to remain in this country to face the charges against her and, as Ms. Maxwell's French and U.K.
experts confirm, there is every reason to believe that both authorities would consider the waiver
as part of any extradition request.
In an attempt to counter William Julié's expert report stating it is "highly unlikely" that
the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the
government attaches a letter from the French Ministry of Justice ("MOJ") that references neither
Mr. Julié's report nor Ms. Maxwell, but states generally that the French Code of Criminal
Procedure "absolutely prohibits" the extradition of a French national. (Gov. Mem., Ex. B). But
8
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=== Page 13 ===
as Mr. Julié's accompanying rebuttal report explains (see Ex. A), the MOJ letter ignores that the
extradition provisions in French Code of Criminal Procedure apply only in the absence of an
international agreement providing otherwise. (Id. at 1). This rule is necessitated by the French
Constitution, which requires that international agreements prevail over national legislation. (Id.).
Thus, extradition of a French national to the United States is legally permissible if the extradition
treaty between the United States and France provides for it-which it does. (Id. at 3).
The government's reliance on a 2006 case-in which France refused to extradite a
French national who was also a U.S. citizen-provides no precedent as to how a French court
would rule on an extradition request regarding Ms. Maxwell because, as Mr. Julié notes, the
United States did not challenge the refusal in the French courts. (Id. at 2-3). Nor does it
undermine Mr. Julié's opinion that, in the unusual circumstance where a citizen of both countries
has executed an extradition waiver and then fled to France in violation of bail conditions set by a
U.S. court, it is "highly unlikely" that an extradition decree would not be issued. (Id. at 3).
The government offers no rebuttal to the opinion of Ms. Maxwell's U.K. extradition
expert, David Perry. Nor does it dispute Mr. Perry's opinion that Ms. Maxwell would be "highly
unlikely" to successfully resist extradition from the United Kingdom, that her waiver would be
admissible in any extradition proceeding, and that-contrary to the government's representation
at the initial bail hearing (Tr. 27)-bail would be "extremely unlikely." (See Def. Mem. Ex. U at
1 39). Mr. Perry's addendum opinion (attached as Ex. B) reiterates these points, opining that the
waiver would be "a highly relevant factor" in the U.K. proceeding, both to the likelihood of
extradition and to the likelihood of bail while the proceeding is pending. (Id. 3).⁷
7 Nor, as the government suggests, does the Secretary of State have general "discretion to deny extradition" after a
court has entered a final extradition order. (See Gov. Mem. at 19). That discretion is limited to a handful of
exceptional circumstances that would likely be inapplicable to Ms. Maxwell's case. (Id. 11 4-5).
9
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Finally, the government's argument that Ms. Maxwell could always flee to some country
other than the United Kingdom and France holds her-and any defendant-to an impossible
standard, which is not the standard under the Bail Reform Act. (See Gov. Mem. at 19). By the
government's reasoning, no defendant with financial means to travel could be granted bail,
because there would always be a possibility that they could flee to another country (even if they
had no ties there), and there could never be an assurance that any extradition waiver would be
enforced. However, "Section 3142 does not seek ironclad guarantees." United States V. Chen,
820 F. Supp. 1205, 1208 (N.D. Cal. 1992). To the extent that Ms. Maxwell's ties to France and
the United Kingdom-where she has not lived for nearly 30 years-create a flight risk, her
extradition waivers along with the substantial bail package proposed reasonably cure it.⁸
E.
The Recent COVID Surge at MDC Further Justifies Bail
The government suggests that the Court ignore COVID concerns because Ms. Maxwell,
though quarantined because of contact with an officer who tested positive, did not become
infected. This ignores the daily (sometimes multiple) inspections of Ms. Maxwell's mouth,
which heightens her risk of contracting the deadly virus, which has now surged to 113 positive
cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that "[i]t
has not been determined whether legal calls and legal visits will continue." As the Court is well
aware, legal visits with Ms. Maxwell already have been suspended. Should legal calls also be
discontinued, her constitutional right to effective assistance of counsel will be further eroded.
CONCLUSION
For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her
release on bail pursuant to the strict conditions she has proposed.
8 Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France
of Jean-Luc Brunel, who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See, e.g.,
France Details Modeling Agent in Jeffrey Epstein Inquiry, https://www.theguardian.com/world/2020/dec/17/france-
detains-modelling-agent-jean-luc-brunel-in-jeffrey-epstein-inquiry.
10
EFTA00015990

=== Page 15 ===
Dated: December 18, 2020
Respectfully submitted,
/s/ Mark S. Cohen
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
11
EFTA00015991


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c0:
=== Page 1 ===
From:
"
To:
]"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), letter motion for order of nolle prosequi
Date: Mon, 19 Aug 2019 20:02:33 +0000
Thanks,
From:
Sent: Monday, August 19, 2019 3:59 PM
To:
is
is
Subject: FW: U.S. V. Epstein, 19 Cr. 490 (RMB), letter motion for order of nolle prosequi
As discussed, docketed version of our letter (and proposed order) attached.
From:
)
Sent: Monday, August 19, 2019 15:57
To: "bermannysdchambers@nysd.uscourts.gov <bermannysdchambers@nysd.uscourts.gov>
Cc:
>; 'Martin Weinberg'
is
>; 'Michael Miller'
>;
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), letter motion for order of nolle prosequi
To the Chambers of Judge Berman:
Attached please find a courtesy copy of the Government's letter motion requesting that the Court approve the enclosed
proposed order of nolle prosequi, in connection with the above-captioned case, filed this afternoon. Defense counsel is
copied.
Thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00014345


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=== Page 1 ===
11/26/21, 7:11 PM
Mail - Meder, Kimberly R. (NY) (FBI) - Outlook
Accepted: GM Physical Evidence Review
>
Fri 4/9/2021 12:58 PM
To:
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/1
EFTA00014965


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c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
"
)"
Subject: RE: Epstein investigation -- request
Date: Mon, 24 Jun 2019 22:31:30 +0000
Importance: Normal
thanks
From:
Sent: Monday, June 24, 2019 6:20 PM
To:
(USANYS)
Cc:
is
)
Subject: RE: Epstein investigation -- request
Definitely - attached.
From:
USANYS)
Sent: Monday, June 24, 2019 18:06
To:
)
is
)
V.
)
Subject: Epstein investigation -- request
Team,
Would you pls send me the DPA?
Many thanks.
EFTA00014517


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c0:
=== Page 1 ===
From:
To: BOBBI C STERNHEIM
Cc: Christian Everdell
"Mark S. Cohen"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 17:49:44 +0000
Embedded: RE:_Ghislaine_Maxwell_02879-509.msg
Sender:
Subject: RE: Ghislaine Maxwell 02879-509
Message-Id:
>
To:
Cc:
Cc:
EFTA00015882


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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016997.pdf
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c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE:
- Following up re proffers
Date: Wed, 15 Jan 2020 22:10:38 +0000
,
I'm sorry, I'm just seeing your email now. We're available to talk immediately if that would still be useful -- I'm at
my desk,
and can conference in
as well.
,
thanks,
Original Message
From:
Sent: Wednesday, January 15, 2020 16:09
To:
Cc:
i
Subject: RE:
- Following up re proffers
Are you available for a call at 4:45 pm today? Please let us know.
Thank you,
Original Message
From:
Sent: Wednesday, January 15, 2020 12:54 PM
To:
Cc:
i
Subject: RE:
- Following up re proffers
Great -- received, thank you.
Original Message
From:
EFTA00016997

=== Page 2 ===
Sent: Wednesday, January 15, 2020 09:01
To:
Cc:
Subject: Re:
- Following up re proffers
Thanks,
Confirmed for Friday, January 24, at 3:30.
We will also be in touch about scheduling another call with you later this week.
On Jan 14, 2020, at 7:28 PM,
wrote:
I apologize, but we've been advised that due to a scheduling issue the office leadership is able to do Friday,
January 24, at 3:30 p.m. (rather than Thursday). We've also asked to convey that the leadership will block out at
least a full hour, should you want that much time, with the potential for a short amount of additional time if
necessary for questions, follow-up, etc. But they wanted to make sure to provide at least that amount of time,
which is possible on Friday (but not Thursday).
Could you please confirm, and we'll finalize it on the various calendars?
Thanks very much,
EFTA00016998

=== Page 3 ===
Original Message
From:
)
Sent: Tuesday, January 14, 2020 12:32
To:
Cc:
Subject: RE:
- Following up re proffers
,
Thanks very much. We've confirmed with our office leadership that they are able to do Thursday, January 23 at
4:00 p.m.
You should also feel very free, though not obligated, to submit in advance any written materials you believe
would be useful. We will pass up the chain anything you convey, written or oral, in between now and the meeting
-- and as we mentioned previously, we would be happy to (and hope to) speak with you again in advance of the
meeting, particularly about the topics I mentioned in my email from yesterday (the incident described in the
complaint, as well as Ms.
recollection, if any, of other instances in which she observed Epstein engaged
in any sexual activity, or observed other women or girls in sexually-suggestive circumstances), but also about
anything else you think could be helpful.
thank you,
Original Message
From:
Sent: Tuesday, January 14, 2020 08:15
To:
Cc:
Subject: Re:
- Following up re proffers
EFTA00016999

=== Page 4 ===
We will be able to make the changes needed to do the meeting on the dates referenced below. Please let us know
if either of those dates. Thanks.
On Jan 13, 2020, at 1:59 PM,
wrote:
The following is conceivably possible for next week, if we can make certain changes to international travel that
was booked earlier with respect to a firm-related matter:
January 23 - any time after 2 pm
EFTA00017000

=== Page 5 ===
January 24 - any time after 10 am
Original Message
From:
Sent: Monday, January 13, 2020 12:18 PM
To:
Cc:
Subject: RE:
- Following up re proffers
,
Please let us know what days and time ranges would be even conceivably possible next week, and also if your
schedule changes at for later this week. On our end, we need to coordinate at least 10 people's schedules so we'll
need some ranges to make sure everyone who you will want to hear your presentation can attend.
EFTA00017001

=== Page 6 ===
As we mentioned on the phone, there is a strong view that there are offenses that can be charged now, so it is also
possible to have this discussion post-charge, but we certainly would prefer to have the conversation before that,
and while the issues are very fresh in everyone's minds here. Our supervisor's view is that the 30th/3 1st is a long
way off.
thanks,
Original Message
From:
Sent: Monday, January 13, 2020 12:10
To:
Cc:
Subject: RE:
- Following up re proffers
Understood. This week doesn't work at all. The 21st and 22nd also don't work, but if the 30th and 31st don't
work on your end, I will see if I can move some things around in order to make next week work.
EFTA00017002

=== Page 7 ===
Original Message
From:
Sent: Monday, January 13, 2020 12:05 PM
To:
Cc:
Subject: RE:
- Following up re proffers
,
We were asked to inquire regarding your availability later this week (15th to 17th) and early next (21st and
22nd), and I know the brass feels that the issues are teed up and they want to provide an opportunity to hear from
you as soon as possible. Are you available on any of those days, of it not, some other time next week?
thanks,
Original Message
From:
Sent: Monday, January 13, 2020 11:59
To:
Cc:
EFTA00017003

=== Page 8 ===
Subject: RE:
- Following up re proffers
All - Thank you for your time on the phone last week. We are following up with regard to scheduling the meeting
referenced in your earlier email. Would January 30th or 31st work (with a preference for the 31st)?
Original Message
From:
Sent: Thursday, January 9, 2020 11:00 PM
To:
Cc:
Subject: RE:
- Following up re proffers
Understood, thanks. We'll be reachable in the interim via email.
EFTA00017004

=== Page 9 ===
Original Message
From:
Sent: Thursday, January 09, 2020 22:57
To:
Cc:
Subject: Re:
- Following up re proffers
I'm trying to rearrange some things in order to call you at 11 am. Thanks.
EFTA00017005

=== Page 10 ===
On Jan 9, 2020, at 10:03 PM,
wrote:
We are all available just slightly later, at 11:00 a.m. - we'll be reachable a
,
or we can call you at
any number that would be convenient for you then. We'll plan to speak with you then, and no hard stop.
thanks,
From:
Sent: Thursday, January 09, 2020 19:45
To:
Cc:
Subject: RE:
- Following up re proffers
We can also do any time after 9 am, if that is better for you. Please let us know. Thanks.
EFTA00017006

=== Page 11 ===
From:
Sent: Thursday, January 9, 2020 7:25 PM
To:
Subject: RE:
- Following up re proffers
Thank you for the update. Are you available to speak tomorrow at 10 am?
EFTA00017007

=== Page 12 ===
I
From:
Sent: Thursday, January 9, 2020 6:09 PM
To:
Cc:
Subject: RE:
- Following up re proffers
EFTA00017008

=== Page 13 ===
As we flagged for you a week ago, and as expected, we had a meeting with the office leadership today to discuss
the status of the case in general and Ms.
in particular. We continue to believe that it would be helpful to
receive any clarifications, as well as any response to the complaint originally sent on December 4, as soon as
possible; we are available tomorrow or over the weekend if there is a time that works for you. If it remains
impossible to talk before Tuesday, we have 2:30 in our calendar for then, but with a hard stop at 3:30 so please
let us know if you'd like to start the discussion earlier if you expect it might be useful to have additional time.
More generally, you had requested the opportunity to present to the ultimate decision-makers in the case if it
appeared that charges were likely, and based on our meeting today, the Office would like to provide you that
opportunity. If you could please let us know what dates and times you are available in the ranges of January 15-
17 and 21-22, we will figure out a time when all the relevant supervisors here are available. I expect that meeting
will include at least the U.S. Attorney, the Deputy U.S. Attorney
(
), and the Chief of the Criminal
Division
), and some combination of the Chief Counsel
), the Counsel
),
the two Public Corruption Unit chiefs
t), the line assistants, and/or FBI
investigative and supervisory personnel. We will be prepared to discuss that meeting with you via phone when
we speak as well, which is one reason I note that we can begin our discussion earlier than 2:30 on Tuesday (or
block off significant time to talk before then) if that would be useful.
thank you,
EFTA00017009

=== Page 14 ===
Original Message
From:
)
Sent: Sunday, January 05, 2020 18:15
To:
Subject: RE:
- Following up re proffers
We'll block off that time in the calendar and plan to talk with you then.
EFTA00017010

=== Page 15 ===
thanks,
Original Message
From:
Sent: Saturday, January 04, 2020 22:30
To:
Cc:
Subject: Re:
- Following up re proffers
EFTA00017011

=== Page 16 ===
Sorry for the delay in my response. Unfortunately, I won't be able to address this until my return to the office.
Apologies. Of course, I will consult with
and try to get back to you as quickly as possible following my
return. In anticipation of being able to do that, do you want to "pencil in" a call for Tuesday, January 14 at 2:30?
X
EFTA00017012

=== Page 17 ===
On Jan 2, 2020, at 3:07 PM,
wrote:
Thanks very much for being in touch. We had actually planned to be in touch today-we expect that next week
we'll be having meaningful conversations internally with supervisors about the possible / likely paths forward
for aspects of the case including Ms.
In connection with that expectation, we wanted to ask if you were
prepared (and willing) to convey to convey your client's recollection regarding the incident described in the
complaint
ent on December 4 (re-attaching here, specifically at page seven). To the extent you have
additional information that would be helpful to convey, even minor, we would be available anytime in the
coming days to do a call. If that isn't possible until you come back, obviously we understand the challenges of
scheduling, but we had anticipated trying to see if we could schedule a call in the coming days. Please let us
know?
EFTA00017013

=== Page 18 ===
thanks,
Original Message
From:
Sent: Wednesday, January 01, 2020 21:50
To:
Cc:
EFTA00017014

=== Page 19 ===
Subject:
- Following up re proffers
All - Happy new year. Wishing you and your families a happy, healthy, and peaceful 2020. We wanted to let you
know that there are a few minor clarifications/corrections we want to share with respect to
proffers. I will
be out of the country and not returning to the office until January 10<x-apple-data-detectors://0> (or possibly
January 13<x-apple-data-detectors:/1>). We will contact you then about scheduling a call to discuss. Many
thanks.
Best,
EFTA00017015

=== Page 20 ===

=== Page 21 ===

=== Page 22 ===
The contents of this message may be privileged and confidential. If this message has been received in error,
please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege.
Please do not disseminate this message without the permission of the author. Any tax advice contained in this
email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under
applicable tax laws and regulations.
EFTA00017018


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=== Page 1 ===
From:
To:
(NY) (FBI)"
Cc:
)"
Subject: Epstein Search Warrant Materials
Date: Tue, 12 Nov 2019 22:07:11 +0000
Hi
I've put the drive for the search warrant materials downstairs at our office under your name for pick up. If you let me
know when it is ready I can come by and pick it up from you.
Thanks,
Paralegal Specialist
United States Attorney's Office
Southern District of New York
Office:
Cell:
EFTA00017063


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=== Page 1 ===
From: Gloria Allred
To:
)"
Subject: RE: August 19th
Date: Wed, 14 Aug 2019 21:21:50 +0000
Inline-Images: image001.png; image002.jpg
Thank you.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
Martindale-Hubbell"
PREEMINENT®
AV
Peer Rated for Highest Level
of Professional Excellence
2017
ALLRED, MAROKO & GOLDBERG
2018
Best Lawyers
From:
Sent: Wednesday, August 14, 2019 2:04 PM
To: Gloria Allred
Cc:
is
;
Subject: Re: August 19th
Thanks- I'll be available on my cell and can talk to you then. Thanks.
Sent from my iPhone
On Aug 14, 2019, at 4:47 PM, Gloria Allred
wrote:
I have the answers to your questions. May I call you in one hour at 5:45 P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
EFTA00014339

=== Page 2 ===
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
From:
Sent: Wednesday, August 14, 2019 9:58 AM
To: Gloria Allred
Cc:
is
Subject: RE: August 19th
Gloria,
I meant to ask: is
currently living in the Los Angeles area?
Thanks,
From: Gloria Allred
Sent: Tuesday, August 13, 2019 10:56 PM
To:
Subject: RE: August 19th
Perfect. I will call you then. Should I reach you at the
number?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
From:
Sent: Tuesday, August 13, 2019 7:37 PM
To: Gloria Allred
Cc:
is
^
Subject: Re: August 19th
Thanks- - I'm free tomorrow at 12:30 EST/ 9:30 am PST if that works.
Sent from my iPhone
On Aug 13, 2019, at 7:11 PM, Gloria Allred
wrote:
Tomorrow morning pacific is fine. What is best for you and which number should I call?
EFTA00014340

=== Page 3 ===
Get Outlook for Android
On Tue, Aug 13, 2019 at 11:32 AM -0700,
)"
> wrote:
Hi Gloria,
Thanks for reaching out. Do you have time to discuss briefly either today or tomorrow?
Thanks,
From: Gloria Allred
Sent: Monday, August 12, 2019 10:36 PM
To:
>; Diane Aldrich
Cc:
is
Subject: RE: August 19th
Good news. Another one of my clients who is an Epstein victim has agreed to fly to New York to meet with you on
August 19 in the afternoon. Is that time period still available? If so what time would work for you? I do have her
driver's license and I know she would like to fly with me on the Delta flight that I am taking on Sunday from L.A. to
New York. If you will have time to meet with her your federal agent who handles travel may contact my assistant,
Diane, tomorrow to arrange the details of my client's trip.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
From:
)
Sent: Friday, August 9, 2019 8:22 AM
To: Gloria Allred
Cc:
is
Subject: RE: August 19th
Thanks for letting us know. We understand that coming forward is a difficult decision, and we respect that.
From: Gloria Allred
Sent: Friday, August 9, 2019 11:17 AM
To:
Cc:
is
Subject: RE: August 19th
EFTA00014341

=== Page 4 ===
Unfortunately, at this point, she has decided that she does not wish to meet with you. I will let you know if she
changes her mind. Thank you for having followed up on this matter.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image005.png>
<image006.jpg>
From:
Sent: Friday, August 9, 2019 8:10 AM
To: Gloria Allred
Cc:
is
Subject: August 19th
Hi Gloria,
Hop you're doing well. I wanted to follow up on scheduling to see if August 19th at 2 p.m. still works to meet with
you and your client at our office. We're happy to be flexible on timing if you need to make other arrangements.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not
the addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU
RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING
THE SENDER NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not
the addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU
RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING
THE SENDER NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
EFTA00014342

=== Page 5 ===
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00014343


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=== Page 1 ===
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
U.S. ATTORNEY GEOFFREY S. BERMAN
FOR IMMEDIATE RELEASE
CONTACT: U.S. ATTORNEY'S OFFICE
Monday, July 8, 2019
http://www.justice.gov/usao/nys
NYPD
FBI
JEFFREY EPSTEIN CHARGED IN MANHATTAN FEDERAL COURT
WITH SEX TRAFFICKING OF MINORS
Alleged Conduct Occurred in both New York and Florida over Multiple Years,
Involving Dozens of Victims
Geoffrey S. Berman, the United States Attorney for the Southern District of New York,
, the Assistant Director in Charge of the New York Field Office of the
Federal Bureau of Investigation ("FBI"), and James P. O'Neill, Commissioner of the New York
City Police Department ("NYPD"), announced that JEFFREY EPSTEIN was arrested Saturday
and charged with sex trafficking of minors and conspiracy to commit sex trafficking of minors.
The indictment unsealed today alleges that, between 2002 through 2005, EPSTEIN sexually
exploited and abused dozens of underage girls by enticing them to engage in sex acts with him in
exchange for money. Epstein allegedly worked with several employees and associates to ensure
that he had a steady supply of minor victims to abuse, and paid several of those victims
themselves to recruit other underage girls to engage in similar sex acts for money. He committed
these offenses in locations including New York, New York, and Palm Beach, Florida. EPSTEIN
is expected to be presented in Manhattan federal court this afternoon before U.S. Magistrate
Judge Henry B. Pitman. The case is assigned to U.S. District Judge Richard M. Berman.
U.S. Attorney Geoffrey S. Berman said: "As alleged, Jeffrey Epstein abused underage
girls for years, operating a scheme in which girls he victimized would recruit others for Epstein
to exploit and abuse. Epstein exploited girls who were vulnerable to abuse, enticed them with
cash payments, and escalated his conduct to include sex acts, often occurring at his residence on
the Upper East Side of Manhattan. While the charged conduct is from a number of years ago,
the victims - then children and now young women - are no less entitled to their day in court.
My Office is proud to stand up for these victims by bringing this indictment."
EFTA00015350

=== Page 2 ===
FBI Assistant Director
said: "We are asking anyone who may
have been victimized by Jeffrey Epstein, or anyone who may have information about his alleged
criminal behavior, to please call us. The number is 1-800-CALL-FBI. We want to hear from
you, regardless of the age you are now, or whatever age you were then, no matter where the
incident took place. The bravery it takes to call us might empower others to speak out about the
crimes committed against them. It is important to remember there was never, nor will there ever
be an excuse for this type of behavior. In the eyes of the FBI, the victims will always come
first."
NYPD Commissioner James P. O'Neill said: "Today's charges serve as a warning to
individuals who continue to prey upon some of our society's most vulnerable population: we are
coming for you. I thank and commend the U.S. Attorney's Office for the Southern District and
the FBI for their tireless efforts to ensure child predators are taken off our streets. The NYPD
will continue to work with our law enforcement partners to eradicate the trafficking of children
in our city and nation and work to bring justice to victims of these heinous crimes."
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 2002 through at least 2005, JEFFREY EPSTEIN enticed and recruited, and
caused to be enticed and recruited, dozens of minor girls to visit his mansion in New York, New
York (the "New York Residence"), and his estate in Palm Beach, Florida (the "Palm Beach
Residence"), to engage in sex acts with him, after which he would give the victims hundreds of
dollars in cash. In order to maintain and increase his supply of victims, EPSTEIN also paid
certain victims to recruit additional underage girls whom he could similarly abuse. In this way,
EPSTEIN created a vast network of underage victims for him to sexually exploit, often on a
daily basis, in locations including New York and Palm Beach.
EPSTEIN's victims were as young as 14 at the time he abused them, and were, for
various reasons, often particularly vulnerable to exploitation. Moreover, EPSTEIN knew that
many of his victims were under 18, including because, in some instances, victims expressly told
him they were underage.
In creating and maintaining this network of minor victims in multiple states to abuse and
exploit sexually, EPSTEIN worked with others, including employees and associates who
facilitated his conduct by, among other things, contacting victims and scheduling their sexual
encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence.
In both New York and Florida, EPSTEIN perpetuated this abuse in similar ways.
Victims were initially recruited to provide "massages" to EPSTEIN, which became increasingly
sexual in nature and would typically include one or more sex acts. EPSTEIN paid his victims
hundreds of dollars in cash for each encounter.
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.
EFTA00015351

=== Page 3 ===
In particular, during encounters at the New York Residence, victims would be taken to a
room where they would perform a massage on EPSTEIN, during which EPSTEIN would
frequently escalate the nature and scope of physical contact with his victims to include, among
other things, sex acts such as groping and direct and indirect contact with the victims' genitals.
In connection with the encounters, EPSTEIN, or one of his employees or associates, typically
paid each victim hundreds of dollars in cash. Once minor victims were recruited, EPSTEIN or
his employees or associates would contact victims to schedule appointments for "massages." As
a result, many victims were abused by EPSTEIN on multiple subsequent occasions.
To further enable him to abuse underage girls, EPSTEIN asked and enticed certain of his
victims to recruit additional minor girls to perform "massages" and similarly engage in sex acts
with EPSTEIN. When a victim would recruit another underage girl for EPSTEIN, he paid both
the victim-recruiter and the new victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN maintained a steady supply of new victims to exploit, and gained access to
dozens of additional underage girls to abuse.
JEFFREY EPSTEIN, 66, is charged with one count of sex trafficking of minors, which
carries a maximum sentence of 40 years in prison, and one count of conspiracy to engage in sex
trafficking of minors, which carries a maximum sentence of five years in prison.
The statutory maximum and mandatory 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.
Mr. Berman praised the outstanding investigative work of the FBI and the NYPD. He
also thanked the U.S. Customs and Border Protection for their assistance.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S.
Attorneys
are in charge of the prosecution,
with assistance from the Office's Human Trafficking Co-Coordinator,
The charges contained in the Indictment are merely accusations. The defendant is
presumed innocent unless and until proven guilty.
19-211
###
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11/26/21, 6:56 PM
Mail Meder,
R. (NY) (FBI) - Outlook
Update
Wed 10/14/2020 4:16 PM
To:
>
Hey just tried calling you. Give me a call when you have a sec
On Oct 14, 2020 7:53 PM,
wrote:
Hey Mandy-
Just spoke to
and he was wondering if you spoke to
and if not if you could set up a
call to get an update (You, me,
and
).
The biggest thing he was asking about is what are the devices we will be reviewing (once it's split
between us and SDNY), and once we know which devices to review if we can start on it right away.
I'll be at work for a few hours still if you want call me!
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/1
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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE:
memo
Date: Tue, 07 Apr 2020 19:56:07 +0000
Sure, l'll cut that and see if
wants to add it back in. Will send now, cc'ing you guys. Thanks!
From:
Sent: Tuesday, April 7, 2020 3:55 PM
To:
Cc:
Subject: RE:
memo
Thank you for having that discussion, and for drafting (hilarious - though ultimately probably helpful - that she wanted
you to draft their views rather than just sending us a paragraph). My only thought is that given the change in our views of
obstructive conduct (particularly with respect to destruction of materials) since they reviewed the Update Memo,
would it be more straightforward to highlight just the large number of underage victims (and not the more outdated
obstruction elements, as presumably many trafficking victims in other cases also conceal the schemes from police, and we
don't ordinarily charge them)? Other than that, no additional thoughts, and thanks again.
From:
Sent: Tuesday, April 07, 2020 15:48
To:
Cc:
Subject: RE:
memo
I spoke with
Bottom line, she thinks it's a close call between making
take a felony plea and declining to
prosecute, but she ultimately comes down in favor of a felony plea. She does not think we should charge
with sex
trafficking.
asked me to send her and
a draft of the summary of their views that we plan to send up to the brass. Below is
what I'd propose:
Our Office's Human Trafficking Coordinators have reviewed the prosecution team's Update Memo as well as
submission, and are aware of the details of the Epstein investigation. In the Coordinators' experience, our Office
ordinarily would decline to prosecute a victim-participant like
absent certain aggravating factors, such as the use of
violence by the victim-participant on others, or the victim-perpetrator continuing to run a sex trafficking operation in the
absence of her abuser. Because those aggravating factors are not present here, the Coordinators believe it is a very close
call between declining to prosecute
and requiring
to enter a felony plea. Ultimately, though, the
Coordinators support a felony plea disposition along the lines set forth in
submission given the unique
circumstances of her case. In particular, the Coordinators believe that the large number of underage victims, together
with
obstructive conduct, warrant a felony plea. The Coordinators support such a disposition, in part, because a
plea will allow victims to gain a sense of closure and to have their voices heard at sentencing if they choose. Given the
mitigating factors presented in
submission-most notably the sexual abuse she suffered at Epstein's hands-the
Coordinators do not believe that our Office should charge
with sex trafficking.
What do you think?
EFTA00016245

=== Page 2 ===
From:
Sent: Monday, April 6, 2020 11:59 PM
To:
Cc:
Subject: RE:
memo
Great thanks
From:
Sent: Monday, April 06, 2020 23:11
To:
Cc:
Subject: Re:
memo
I have a call tentatively scheduled with
tomorrow afternoon.
has not confirmed whether she's joining.
On Apr 6, 2020, at 10:42 PM,
wrote:
Have we heard anything from
and/or
? Russell's comments ask about that specifically so wanted to check.
Assistant U.S. Attorney
Southern District of New York
212.637.2415
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=== Page 1 ===
From:
To:
Subject: WPB Grand Jury Extension
Date: Mon, 14 Jul 2008 15:36:22 +0000
Importance: Normal
Hi all - The grand jury that has heard the Epstein case is set to expire in two weeks. Should we extend them in
case the recent developments result in the unraveling of the agreement?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
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=== Page 1 ===
From: "Moyne, Parvin"
To:
Cc: "Moyer, Thomas"
,
"DiPiero, Joseph"
Subject: RE:
Date: Tue, 12 Nov 2019 22:27:23 +0000
Thanks
- and we will definitely keep you posted.
Best,
Parvin
Original Message
From:
Sent: Tuesday, November 12, 2019 1:23 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
DiPiero, Joseph
Subject: RE:
**EXTERNAL Email*
Parvin,
Thanks for letting us know, and we have no concerns or questions about that. Please let us know if anything
arises that you think would be useful to convey, and thanks again for the heads up.
Original Message
From: Moyne, Parvin
Sent: Tuesday, November 12, 2019 11:00
To:
Cc: Moyer, Thomas
DiPiero, Joseph
Subject:
Hi all - Hope you are well. As part of the bank's internal investigation, we are planning to reach out to several
former DB employees, including Paul Morris, to see if they would be willing to speak with us about Epstein's
accounts. Please let us know if you would like to discuss this.
Best,
Parvin
The information contained in this e-mail message is intended only for the personal and confidential use of the
EFTA00017064

=== Page 2 ===
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
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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=== Page 1 ===
From: BOBBI C STERNHEIM
To: Nathan NYSD Chambers
Cc:
Christian Everdell
, Laura Menninger
Jeff Pagliuca
Subject: U.S. V. Ghislaine Maxwell 20 Cr. 330 (AJN)
Date: Tue, 23 Mar 2021 20:14:57 +0000
Good afternoon-
Per the court's order (Dkt. 169), the parties have conferred and agreed that
redactions to the Bail Reply Memorandum are unnecessary.
The original document has been publicly filed (Dkt. 171).
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
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=== Page 1 ===
From: Martin Weinberg
To:
Cc:
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB)
Date: Wed, 17 Jul 2019 23:19:16 +0000
Hi
Will the original be available tomorrow for us to see?
Thanks
Marty
Sent from my iPhone
On Jul 17, 2019, at 7:02 PM,
wrote:
Mike,
The photographs you requested are attached. My understanding is that pages 6 and 7 were blank, and were not
photographed.
Best,
Assistant United States Attorney
Southern District of New York
<Passport Photographs.pdf>
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=== Page 1 ===
From:
To:
)"
Cc:
Subject: RE: Maxwell
account
Date: Tue, 31 Dec 2019 18:57:51 +0000
No problem -- just sent an application off to court. It should come back by the end of the week.
Original Message
From:
Sent: Tuesday, December 31, 2019 12:56 PM
To:
Cc:
Subject: Maxwell
account
Hey all,
We received statements from USAA and Maxwell has an
account. Can we get a subpoena and NDO for
? Looks like she has made quite a few transactions from there and we'd like to see where her packages
are going right now. The credit card she was using for purchases is under the name Ghislaine Borgerson.
Identifiers:
Ghislaine Maxwell and/or Ghislaine Borgerson
Thanks,
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=== Page 1 ===
From:
Subject: Re: Contact from MCC NY Warden
Date: Fri, 11 Oct 2019 22:28:43 +0000
SDNY is fine with allowing the cell to go back into normal use. Thank you.
On Oct 11, 2019, at 6:26 PM, Modano, Guido (OIG) <gmodano@oig.usdoj.gov> wrote:
Good evening everyone,
I was contacted by BOP MCC NY Warden
this afternoon and he asked whether it was ok for the
MCC to return to the normal usage of the cell in the Special Housing Unit where Jeffrey Epstein was housed
and the incident occurred. He mentioned that he recalled being told by someone at some point it was ok to
begin using the cell again to house inmates but wants to confirm it is ok to do so before reopening the cell for
normal use. I told Warden
that I would check with the Investigative Team and get back to him next
week. Please let me know if he should continue to keep the cell secured and unoccupied or if he can begin
using the cell to house inmates. Thank you all and have a nice weekend.
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=== Page 1 ===
From:
"
To:
Subject: FW: Confidentiality Order -
V. Maxwell (Judge Sweet)
Date: Thu, 03 Jan 2019 19:14:52 +0000
Attachments: 2017-11-14_Sealed_Opinion.pdf; 2016-03-18 [DE 62] Protective_Order.pdf; 2017-07-
18_[DE_56]_New_Case_Manager_Assigned
Inline-Images: image001.png
These documents are public.
ГП
EDWARDS
LI
POTTINGER LLC
Stan Pottinger
Partner
1930 Broadway
Suite 12B
New York, New York 10023
Fort Lauderdale, FL 33301
www.epllc.com
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=== Page 1 ===
Page 1 of 1
Print View
Executed:6/28/2019 15:49
Executed
by:NYPDFINESTIHARKINS904113
New York City Police Department
SOMU
SOMU Event ID: 11472
Next Appointment Date:
Parole Officer:
SOMU Offender ID: 33216
Interviewer Tax ID:
Phone Number
Offender FBI ID: 787075K8
No Show at Last Visit:
Probation Officer:
SOMU Registration Date: 4/15/2010
Risk Level 3
Phone Number:
Previous Visit Date:
Status OPEN
Borough:
Person
NYSID#: 04614879Q
Hair Color GRAY
Name: JEFFREY EPSTEIN
Hair Dyed
Alias
Hair Style: CLOSE CUT
Date Of Birth: 1/20/1953
Height: 6' 0"
No Image
Sex: MALE
Weight: 180
Race: WHITE
Eye Color: BLUE
Available
Driver License #:
Skin Tone LIGHT
State
Skin Complexion FLUSHED/RUDOY
Offender Phone Number: C:2125333739
Address History:
Full Address
City
State Code Zip Code
Move-In Date Move-Out Date Address Type
6100 RED HOOK QUARTER B3ZZ
NY
4/28/2017
P
Charges:
Arrest Precinct:
Victim Sex:
Arresting Officer:
Victim Age:
Arrest ID:
Victim Race:
Arrest Date:
Victim Relation:
Convicted Date:
Crime Description:
Precinct of Occurence:
Vehicle History:
Vehicle
Vehicle Make Vehicle Model
Vehicle Style
Vehicle
VIN Number
Vehicle
Vehicle
License Plate
Plate State
Year
Code
Color Code
Start Date
End Date
Number
Code
Page 1 of 1
https://dashboardsvc/EventDetailReport/(S(3too1yhrvscc4aghbusr3fpi))/DASReportView... 6/28/2019
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=== Page 1 ===
From
To
Subject: FW: Preservation request
Date: Tue, 17 Dec 2019 21:40:42 +0000
Dear
and
I am surprised that the video was not retained, as I specifically requested its preservation, and
had
confirmed with me that he had made the preservation request. See below. Thank you.
Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
Please note that my emailed has changed to:
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments.
From:
Sent: Tuesday, December 17, 2019 4:30 PM
To:
Subject: FW: Preservation request
Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
Ste 700
Please note that my emailed has changed to:
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=== Page 2 ===
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments.
From:
Sent: Thursday
25
To:
Subject: Re: Preservation request
Hello
It was great seeing you as well.
I have asked the appropriate staff to preserve the requested video footage. Please be advised MCC staff do not have body
cameras.
Thank you,
>>>
7/25/2019 11:54 AM>>>
Hello
It was good to see you yesterday. Thank you for accommodating my visit with
and giving him extra time to
review his discovery. We very much appreciate that.
I am writing to request the preservation of all video surveillance that captures the hallway outside of
cell on
the date and time of the Epstein incident that is currently being investigated. I believe that the date and time is July 23
during the early morning hours. Accordingly, I would ask that all video surveillance from July 22 at 11 pm to July 23 at 4 am
is preserved. If it is your understanding that the incident occurred at a different time, please let me know and preserve the
relevant footage, including an hour before the incident and an hour afterwards. If the responding officers were wearing
body cameras that captured the inside of the cell in the aftermath of the incident, I am requesting that such footage also
be preserved.
We will be officially requesting this material through the appropriate means, but please consider this email a formal
preservation request.
Thank you.
, Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
Please note that my emailed has changed to:
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
EFTA00016418

=== Page 3 ===
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments.
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=== Page 1 ===
LAST WILL AND TESTAMENT
OF
JEFFREY E. EPSTEIN
I, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin Islands, do make,
publish and declare this to be my Will hereby revoking all prior Wills and Codicils made by me.
FIRST:
A.
I direct my Executor to pay from my estate my funeral and
burial expenses, the administration expenses of my estate and all of my debts duly proven and
allowed against my estate.
B.
I direct my Executor to pay from my estate the
federal and state transfer taxes described in Paragraph B(1) of Article SEVENTH.
C.
I direct my Executor to pay from my estate all
expenses of storing, insuring, packing, shipping and delivering my tangible personal property.
SECOND: I give all of my property, real and personal, wherever situated,
after the payments and distributions provided in Article FIRST, to the then acting Trustees of
The Jeffrey E. Epstein Trust One created under that certain Trust Agreement (the "Trust
Agreement") dated November 8, 2001, as amended from time to time, and as amended and
restated contemporaneously with the execution of this Will, and as the same may be amended
from time to time, to be held in accordance with the provisions comprising the Trust Agreement
at the time of my death.
THIRD:
A.
I appoint DARREN K. INDYKE, JOSEPH PAGANO and
LAWRENCE NEWMAN to be the Executors of this Will. If any one or more of my Executors
fails to qualify or ceases to act, I appoint JES STALEY and ANDREW FARKAS, singly and in
the order named, as successor Executors. I authorize the last acting Executor to designate his
successor as Executor.
B.
If my estate must be administered in whole or in
part in any jurisdiction other than the state of my domicile at the date of my death and if my
Executor is unable or unwilling to serve in such jurisdiction, then I appoint the first successor
Executor of my estate designated in Paragraph A of Article THIRD who is able and willing to
serve in such jurisdiction. If no Executor or successor Executor is able and willing to serve in
2657367.1
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such jurisdiction, my Executor shall designate a successor Executor to serve in such jurisdiction.
Such designation shall be made by written instrument delivered to such successor Executor.
C.
No bond or other security shall be required of any
Executor in any jurisdiction.
D.
Any Executor may resign by filing a written notice
of resignation with the Court having jurisdiction of the administration of my estate. All of my
Executor's fees and expenses (including attorneys' fees) attributable to the appointment of a
successor Executor shall be paid by my estate.
E.
My Executor shall not be accountable or
responsible to any person interested in my estate for the manner in which my Executor in good
faith exercises or declines to exercise any discretionary authority or power of my Executor. My
Executor shall not be liable for any loss or depreciation in value occasioned by reason of any
negligence, error or mistake of judgment in entering into any transaction, in making any sale or
investment, in continuing to hold any property or by reason of any action or omission, whether
by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence
of proof by affirmative evidence to the contrary, each Executor shall be deemed to have acted
within the scope of my Executor's authority, to have exercised reasonable care, diligence and
prudence and to have acted impartially as to all interested persons. An Executor shall not be
liable for the acts or defaults of another Executor.
FOURTH: The following provisions shall apply to my estate and to my
Executor, except as is otherwise specifically provided in this Will:
(1) My Executor has the entire care and
custody of all assets of my estate. My Executor has the power to do everything my Executor in
good faith deems advisable without necessity of any judicial authorization or approval, even
though but for this power it would not be authorized or appropriate for fiduciaries under any
statutory or other rule of law. My Executor shall exercise my Executor's best judgment and
discretion for what my Executor believes to be in the best interests of the beneficiaries
hereunder. If more than two Executors are empowered to participate in the decision to exercise
or not exercise any fiduciary power granted by this Will or by law, a majority of such Executors
shall be empowered to make such decision.
B.
Except as otherwise provided herein, my Executor
shall have the power:
(1) to enter upon and take possession of the
assets of my estate and collect the income and profits from such assets, and to invest and
reinvest such assets in real, personal or mixed assets (including the common trust funds of a
corporate fiduciary) or in undivided interests therein without being limited by any present or
future investment laws;
(2)
to retain all or any part of the assets of my
estate (without regard to the proportion that any one asset or class of assets may bear to the
whole) in the form in which such assets were received or acquired by my Executor;
2
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(3)
to sell or dispose of, exchange, transfer,
invest or loan all or any part of the assets of my estate which may, at any time, be held by my
Executor for such sums or upon such terms as to payment, security or otherwise as my Executor
determines, either by public or private transactions;
(4)
to buy and sell options, warrants, puts, calls
or other rights to purchase or sell (collectively "options") relating to any security or securities,
regardless of whether such security or securities are then held by my Executor, and whether
such options are purchased or sold on a national securities exchange, and to exercise with
respect to such options all powers which an individual owner thereof could exercise, including,
without limitation, the right to allow the same to expire;
(5) with respect to oil, natural gas, minerals,
and all other natural resources and rights to and interests therein (together with all equipment
pertaining thereto) including, without limiting the generality of the foregoing, oil and gas
royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee,
lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint
tenant, or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral
leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties,
taxes, assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or
otherwise hypothecate any or all of such rights and interests; (d) to surrender or abandon, with
or without consideration, any or all of such rights and interests; (e) to make farm-out, pooling,
and unitization agreements; (f) to make reservations or impose conditions on the transfer of
any such rights or interests; (g) to employ the most advantageous business form in which
properly to exploit such rights and interests, whether as corporations, partnerships, limited
partnerships, mining partnerships, joint ventures, co-tenancies, or otherwise exploit any and all
such rights and interests; (h) to produce, process, sell or exchange all products recovered
through the exploitation of such rights and interests, and to enter into contracts and agreements
for or in respect of the installation or operation of absorption, reprocessing or other processing
plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (j)
to delegate, to the extent permitted by law, any or all of the powers set forth herein to the
operator of such property; and (k) to employ personnel, rent office space, buy or lease office
equipment, contract and pay for geological surveys and studies, procure appraisals, and
generally to conduct and engage in any and all activities incident to the foregoing powers, with
full power to borrow and pledge in order to finance such activities; together with the power to
allocate between principal and income any net proceeds received as consideration, whether as
royalties or otherwise, for the permanent severance from lands of oil, natural gas, minerals, and
all other natural resources;
(6)
to hold all or any part of the assets of my
estate in cash or in bank accounts without the necessity of investing the same;
(7)
to improve, repair, partition, plat or
subdivide all or any part of the assets of my estate;
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(8) to litigate, defend, compromise, settle,
abandon or submit to arbitration on such terms and conditions as my Executor determines any
claims in favor of or against my estate or the assets of my estate;
(9) to loan or borrow money in such amounts
and upon such terms and conditions as my Executor determines, assume such obligations or give
such guarantees as my Executor determines, for the purpose of the acquisition, improvement,
protection, retention or preservation of the assets of my estate, or for the welfare of the
beneficiaries of my estate;
(10) to carry on for as long and in such manner
as my Executor determines any business enterprise in which I owned any interest at my death,
either individually, or as a partner, joint venture, stockholder or trust beneficiary; to sell such
business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate
or undertake any other extraordinary corporate transaction relating to such business enterprise;
(11) to vote in person or by proxy any and all
stock or securities and to become a party to any voting trusts, reorganization, consolidation or
other capital or debt readjustment of any corporation, association, partnership, limited liability
partnership, limited liability company or individual with respect to stocks, securities or debts
held by my estate;
(12) to enter into any good faith transactions
with my Executor individually or with any corporation, partnership or other entity in which my
Executor has an ownership interest;
(13) to lease, mortgage, pledge, grant a security
interest in or otherwise encumber all or any part of the assets of my estate for any term of years
whether or not beyond the duration of my estate (including, without limitation, any such action
for the benefit of any of the beneficiaries of my estate);
(14) to abandon any property, real or personal,
which my Executor may deem worthless or not of sufficient value to warrant keeping or
protecting; to abstain from the payment of taxes, water rents or assessments and to forego
making repairs, maintaining or keeping up any such property; and to permit such property to be
lost by tax sale or other proceedings or to convey any such property for a nominal consideration
or without consideration SO as to prevent the imposition of any liability by reason of the
continued ownership thereof;
(15) to elect the mode of distribution of the
proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit
plan, individual retirement plan, insurance contract or annuity contract pursuant to the terms of
such plan;
(16) to allocate, in my Executors discretion, any
adjustment to basis provided to my estate under the provisions of Federal and State law with
respect to property comprising my estate, without any obligation to make a compensatory
adjustment among the beneficiaries hereunder on account of such allocation;
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(17) to conduct any audit, assessment or
investigation with respect to any asset of my estate regarding compliance with any law or
regulation having as its object protection of public health, natural resources or the environment
("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply
with any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as
may be required in my Executor's judgment by any Environmental Law, to notify any
governmental authority of any past, present or future non-compliance with any Environmental
Law; and
(18) to sell to the Trustee under the Trust
Agreement any stocks, bonds, securities, real or personal property or other assets or borrow
from the Trustee under the Trust Agreement even though the same person or persons occupy the
office of the Executor of my estate and the Trustee under the Trust Agreement.
(19) No executor shall directly or indirectly buy
or sell any property for the estate from or to himself, or from or to his relative, employer,
employee, partner, or other business associate.
(20) No executor shall lend estate funds to
himself, or to his relative, employer, employee, partner, or other business associate.
C.
Except as otherwise provided herein, my Executor
shall have the power:
(1) to employ agents, attorneys-at-law,
consultants, investment advisers (to whom my Executor has discretion to delegate my
Executor's investment authority and responsibility), other executors and other fiduciaries in the
administration of my Executor's duties; to delegate to such persons, or to one or more of my
Executors, the custody, control or management of any part of my
estate as my Executor determines and to pay for such services from the assets of my estate,
without obtaining judicial authorization or approval;
(2)
to delegate, in whole or in part, to any
person or persons the authority and power to (a) sign checks, drafts or orders for the payment or
withdrawal of funds, securities and other assets from any bank, brokerage, custody or other
account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for
sale, transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and
all property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever,
(c) gain access to any safe deposit box or boxes in which my assets or assets of my estate may
be located or which may be in the name of my Executor and remove part or all of the contents of
any such safe deposit box or boxes and release and surrender the same, and (d) take any other
action that my Executor may have the power to take with respect to my estate and the property
thereof; no person or corporation acting in reliance on any such delegation shall be charged with
notice of any revocation or change of such delegation unless such person or corporation receives
actual notice thereof;
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=== Page 6 ===
(3) to pay any property distributable to a
beneficiary under a legal disability, without liability to my Executor, by paying such property
(a) to such beneficiary, (b) for the use of such beneficiary, (c) to a legal representative of such
beneficiary appointed by a court or if none, to a relative for the use of such beneficiary, or (d) to
a custodian for such beneficiary designated by my Executor;
(4) to distribute to any of the beneficiaries of
my estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds
or disproportionate shares of assets or undivided interests in assets among all of such
beneficiaries;
(5) to have evidence of ownership of any
security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book
Entry System; to deposit funds in any bank or trust company; to carry in the name of my
Executor or the nominee or nominees of my Executor and with or without designation of
fiduciary capacity, or to hold in bearer form, securities or other property requiring or permitting
of registration; and to cause any securities to be held by a depository corporation of which an
Executor is a member or by an agent under a safekeeping contract; provided, however, that the
books and records of my Executor shall at all times show that such investments are part of my
estate;
(6)
to renounce and disclaim, in whole or in
part, and in accordance with applicable law, any assets, interests, rights or powers (including
any power of appointment) which are payable to (or exercisable by) me or my estate, which are
includible in my estate or Gross Estate or over which I have any right, title, interest or power;
and
(7)
to make, execute and deliver any and all
such instruments in writing as shall be necessary or proper to carry out any power, right, duty or
obligation of my Executor or any disposition whatsoever of my estate or any asset of my estate
and to exercise any and all other powers incidental or necessary to carry out or to fulfill the
terms, provisions and purposes of my estate.
D.
In connection with any insurance policy or annuity
on the life of an Executor which is included in my estate, such Executor shall not participate in
the decision to exercise or not exercise any fiduciary power in connection with any incidents of
ownership for such policy or annuity, including, without limitation, any decision to continue,
assign, terminate or convert such policy or annuity or to name the beneficiary of such policy or
annuity.
E.
An Executor hereunder may by a written notice
delivered to the other Executor (or Executors) decline to participate in the decision to exercise or
not exercise any fiduciary power granted by this Will or by law.
F.
If an Executor is not empowered (because of a
conflict of interest, declination to act or otherwise) to participate in the decision to exercise or
not exercise any fiduciary power granted by this Will or by law, then the remaining Executor or
6
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=== Page 7 ===
Executors shall be empowered to make such decision. If no Executor is empowered to
participate in such decision, then the first successor Executor of my estate designated in
Paragraph A of Article THIRD and able and willing to act shall be empowered to make such
decision. If no Executor or successor Executor is empowered to participate in such decision, my
Executor may designate a successor Executor to serve as Executor of my estate who shall be
empowered to make such decision but shall have no other power or authority of my Executor.
Such designation shall be by written notice delivered to such successor Executor.
G.
(1)
Except as otherwise specifically provided
herein and except as provided in Paragraph G(2) of this Article, my Executor shall allocate
receipts and disbursements in accordance with sound trust accounting principles and shall have
discretion to allocate receipts and disbursements when the treatment is uncertain under
applicable laws or generally accepted accounting principles in the judgment of my Executor.
(2)
Except as otherwise specifically provided in
this Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of
any asset of my estate as income distributable to or for the benefit of any beneficiary entitled to
distributions of income; provided, however, that my Executor shall treat a portion of any
proceeds of sale of any financial instrument originally issued or acquired at a discount equal to
the amount which (a) has previously been characterized as ordinary income for income tax
purposes or (b) will be characterized as ordinary income for income tax purposes in the year of
such sale, as income for trust accounting purposes.
FIFTH:
Where a party to any proceeding with respect to my estate has the
same interest as a person under a disability, it shall not be necessary to serve legal process on the
person under a disability.
SIXTH:
If any beneficiary under The Jeffrey E. Epstein 2001 Trust One
("the trust") shall in any way directly or indirectly (a) contest or object to the probate of my Will
or to the validity of any disposition or provision of my Will or of the trust or (b) institute or
prosecute, or be in any way directly or indirectly instrumental in the institution or prosecution
of, any action, proceeding, contest, objection or claim for the purpose of setting aside or
invalidating my Will or the trust or any disposition therein or provision thereof, then I direct that
(a) any and all provisions in the trust for such beneficiary and his issue in any degree shall be
null and void and (b) my estate, whether passing under my Will or the trust or pursuant to the
laws of intestacy, shall be disposed of as if such beneficiary and his issue in any degree had all
failed to survive me.
SEVENTH:
A.
As used herein:
(1)
The term "Executor" of a person's estate
means all persons or entities who occupy the office of executor, administrator, personal
representative, or ancillary administrator while such persons or entities occupy such office,
whether one or more persons or entities occupy such office at the same time or times, and
includes any successor or successors to that office. The term "Trustee" means all persons or
entities who occupy the office of Trustee under the Trust Agreement while such persons or
entities occupy such office, whether one or more persons or entities occupy the office of Trustee
7
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=== Page 8 ===
at the same time or times, and includes any successor Trustee or Trustees. A reference to a
person's estate or probate estate means that person's estate which is subject to probate
administration. A reference to a person's Will means such person's Last Will and Testament and
any Codicil or Codicils thereto.
(2)
The term "IRC section" means a section of
the Internal Revenue Code of 1986, as amended, or the corresponding provision of any
successor Internal Revenue law, as in effect as of the date of my death.
(3)
A reference to any tax also includes any
interest or penalties thereon. A reference to a person's "Gross Estate" means such person's gross
estate as finally determined for purposes of computing such person's federal estate tax.
(4)
Whenever the singular number is used, the
same shall include the plural, and the masculine gender shall include the feminine and neuter
genders.
B.
(1)
The federal and state transfer taxes which
my Executor shall be obligated to pay pursuant to Paragraph B of Article FIRST shall consist of
all federal and state estate, inheritance, succession, and similar taxes (including any federal or
state generation-skipping transfer tax) imposed upon my probate estate or by reason of my death
in respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph
B(2) of this Article, all federal estate taxes with respect to assets not passing under this Will or
the Trust Agreement (such assets are referred to as the "Apportionment Assets") and any
applicable state estate taxes with respect to the Apportionment Assets shall be apportioned
among all persons interested in the Apportionment Assets. My Executor shall make reasonable
efforts to collect all federal estate taxes and state estate, inheritance, succession and similar taxes
allocable to the Apportionment Assets from the recipients of the Apportionment Assets. Without
changing the apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is
not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the
extent my Executor pays such taxes allocable to the Apportionment Assets, my Executor shall
seek reimbursement for such taxes from the recipients of the Apportionment Assets. My
Executor shall not be personally liable for any of such taxes if my Executor is unable, with
reasonable efforts, to collect payment (or reimbursement) from any recipient of any
Apportionment Assets for any or all of such taxes allocable to such assets.
(2)
My Executor has discretion to direct the
Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is
directed or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B
pursuant to a written direction delivered to the Trustee under the Trust Agreement. Any taxes
which my Executor directs the Trustee under the Trust
Agreement to pay shall be allocated and paid from the trusts under the Trust Agreement as
provided under the Trust Agreement.
C.
Except as otherwise specifically provided in this
Will, a bequest or devise to an individual who does not survive me shall lapse notwithstanding
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=== Page 9 ===
any law to the contrary.
D.
To the extent that the distribution to the Trustee
under the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the
rest of my property, real and personal, wherever situated, after the payments and distributions
provided in Article FIRST, to the person or persons named as Trustee or Trustees under the
Trust Agreement, be to held in trust under this Will in accordance with the provisions
comprising the Trust Agreement at the time of my death, which provisions are incorporated in
this Will by reference.
IN WITNESS WHEREOF, I have duly executed this Will the 27th day of
January , 2012.
JEFREY C E. EPSTEIN
The foregoing written instrument was on the date thereof, signed, published and
declared by the Testator therein named as the Testator's Will in the presence of us and of each
of us, who, at the Testator's request, in the Testator's presence and in the presence of each
other, have subscribed our names as witnesses thereto.
residing at
Richard BARNETT
Portwashrugton NY 11050
?Lawrence newman residing at
Sands Point, N.Y. 11050
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=== Page 10 ===
We, JEFFREY E. EPSTEIN, Richard Barnett and, Lawrence Newman the Testator
and the witnesses, respectively, whose names are signed to the foregoing instrument, having
been sworn, declared to the undersigned officer that the Testator, in the presence of the
witnesses, signed the instrument as his Will, that he signed, and that each of the witnesses, in the
presence of the Testator and in the presence of each other, signed the Will as a witness.
JEFFREY E. EPSTEIN
Unland Bannett
Lawrence newman
New YNK
STATE OF A )
New Y-K)SS:
COUNTY OF)
Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is personally
known to me or who has produced
as identification, and byRichard by Barnett amenta witness
who is personally known to me or who has produced
as identification, and
Laurence Neuman, a witness who is personally known to me or who has produced
as identification, on JANUARY 27, , 2012.
Sworn to before me this 27 day of
January,
Hung I Full
Notary Public
HARRY I.
York
Expires Feb. 17, 2014
County
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=== Page 11 ===
EFTA00016875
GJ_000137
LAST WILL AND TESTAMENT
OF
JEFFREY E. EPSTEIN
Dated
, 2012


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: RE: United States V. Ghislaine Maxwell --
Date: Sun, 28 Nov 2021 20:46:02 +0000
Good luck, guys!
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS<USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell --
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: 302s New York
Date: Wed, 26 Jun 2019 21:32:31 +0000
Attachments:
Special Agent
FBI New York
VCAC/Human Trafficking
EFTA00014434


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From:
To:
Subject: RE: Ghislaine Maxwell Siblings
Date: Wed, 01 Jul 2020 19:29:15 +0000
Thanks for putting this together!
From:
Sent: Wednesday, July 1, 2020 3:27 PM
Subject: FW: Ghislaine Maxwell Siblings
Good afternoon,
Below is information regarding Maxwell's siblings.
From:
(NY) (FBI)
Sent: Wednesday, July 01, 2020 2:55 PM
To:
(NY) (FBI)
is
Subject: Ghislaine Maxwell Siblings
1. Christine Maxwell
Address:
2. Isabel Maxwell
Address:
3. Karine Maxwell
DOB:
Deceased
4. Ann (Anne) Maxwell (Anne Holve)
DOB:
Married Lawrence Holve
No identified residence in US
i. OUTBOUND flight on 5/23/2015 to UK
5.
***Kevin Maxwell
DOB:
No identified residence in US
i. INBOUND flight on 2/29/2020 to Boston from London
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=== Page 2 ===
6.
Michael Maxwell
DOB:
Deceased
7. lan Maxwell
DOB:
No identified residence in US
i. OUTBOUND flight on 12/27/2017 to London from Boston
8. Philip Maxwell
DOB:
No travel history
No identified residence in US
Let me know if you need anything else!
EFTA00014394


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Civilian Caller About Epstein Case FW: Voice Message Attached from
-
Intake Line
Date: Thu, 18 Jul 2019 16:45:00 +0000
Attachments:
wav
,
Would you please forward this to whoever is currently handling the tipline?
Thanks,
Assistant United States Attorney
Southern District of New York
Original Message
From:
Sent: Thursday, July 18, 2019 12:43 PM
To:
Cc:
Subject: Civilian Caller About Epstein Case FW: Voice Message Attached from
- Intake Line
this caller got directed to call the 1-2500 intake line (wrongly, as that is just for law
enforcement and we are trying to stop whomever is doing that). He should have called the FBI number in your
press release. Could you please forward this to your FBI agents and let them deal with it? If they get back to you
and say they know him and he is a crazy, let me know that, and we will figure out his mailing address and send
him out the usual form letter from the Civilian Crime Reports Unit, with a form to fill out. And we will deal with
him if he continues to be a problem. But before we do that, just in case this is useful, let the FBI hear it and let us
know whether to process it in the CCR system. Thanks.
Original Message
From:
(USANYS)
Sent: Thursday, July 18, 2019 12:12 PM
To:
Subject: FW: Voice Message Attached from
- Intake Line
EFTA00014609

=== Page 2 ===
Original Message
From: postmaster@voip.usa.doj.gov <postmaster@voip.usa.doj.gov>
Sent: Thursday, July 18, 2019 12:11 PM
To:
Cc:
(USANYS)
Subject: Voice Message Attached from
- Intake Line
Time: Jul 18, 2019 12:11:02 PM
Click attachment to listen to Voice Message
EFTA00014610


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=== Page 1 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
V.
20-CV-00833 (PAE)
FEDERAL BUREAU OF PRISONS,
Defendant.
DECLARATION OF NICOLE MCFARLAND
I, Nicole McFarland, declare as follows:
1. I am employed by the United States Department of Justice, Federal Bureau of Prisons
("BOP"), as a Staff Attorney at the Metropolitan Correctional Center ("MCC"). I have served
in this role since December 2019. Prior to that time, I was the Senior Staff Attorney at MDC
Brooklyn from January 2009 until December 2019 and the Staff attorney at FCI Fort Dix from
September 2005 until January 2009. I have been employed by the BOP since September
2005.
2. As a Staff Attorney, my duties include coordinating searches at MCC when a Freedom of
Information Act ("FOIA") requires MCC staff to undertake a search for responsive
documents. In this capacity, I typically work with staff at BOP's Central Office. In this case,
I communicated with BOP Government Information Specialist Kara Christenson regarding
Plaintiff's FOIA requests.
3. I submit this declaration in support of the BOP's motion for summary judgment and to
1
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=== Page 2 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 2 of 10
describe BOP's search at MCC for records responsive to the FOIA requests submitted by
Plaintiff.
4. The statements made in this declaration are based upon my personal knowledge, conversations
and communications with other BOP staff, and information available to me in my official
capacity and about which I have become knowledgeable.
5. To conduct the search at MCC for records responsive to Plaintiff's FOIA request, I conferred
with staff at MCC and staff at Central Office to determine that the following individuals
would likely have documents responsive to Plaintiff's request: Lieutenant, MCC Associate
Warden; MCC Chief Psychologist; Executive Assistant to the MCC Warden; Case
Management Coordinator in the MCC Records Department; Special Investigave Agent at
the MCC; Deputy Regional Counsel for the Northeast Regional Office and former BOP
Staff Attorney at the MCC; former MCC Warden; and Unit Managers. Based on my
conversations with staff at MCC and Central Office and my own experience, no other
individuals at MCC, or who formerly worked at MCC, are reasonably likely to have records
responsive to Plaintiff's request.
6. I asked each of the individuals identified in Paragraph 5 to search their electronic and non-
electronic files for documents responsive to Plaintiff's FOIA requests. Each of them advised
me that he or she conducted a manual search of electronic and non-electronic files for
documents responsive to Plaintiff's FOIA requests. Their searches included a search of drives
on BOP's computer system where individual BOP employees can save documents. Separate
from these searches conducted by individuals, a search for email records and searches of other
BOP electronic systems, including SENTRY and TRULINKS, for records responsive to
2
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=== Page 3 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 3 of 10
Plaintiff's FOIA requests was conducted by Central Office and is detailed in the Declaration
of Kara Christenson (the "Christenson Declaration").
7. The results of the searches conducted by MCC in response to Plaintiffs' requests are described
in the following paragraphs.
8. SHU LOGS - With respect to Plaintiff's request for "[t]he signed log in the Special Housing
Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 1,"
MCC staff determined that the SHU log books in question were handed over to the Office of
the Inspector General ("OIG") on or about August 22, 2019. With the exception of the
scanned copies of certain log book pages described in the Christenson Declaration, the
searches at MCC did not return additional records responsive to this request.
9. SENTRY QUARTER'S HISTORY - With respect to Plaintiff's request for "[a]ll quarter
entries (showing which cells he was housed in) for Jeffrey Epstein at MCC[,]" Central Office
conducted a search of the SENTRY database, as described in the Christenson Declaration.
The searches at MCC did not return additional records responsive to this request, apart from
records relating to Epstein that indicated which cell or part of the facility he was housed in.
10. CIM CLEARANCE SHEET/SEPARATEE DATA - With respect to Plaintiff's request
for "CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC[,]" Central Office
conducted a search of the SENTRY database, as described in the Christenson Declaration.
The searches at MCC did not return additional records responsive to this request.
11. DISCIPLINARY RECORDS - With respect to Plaintiff's request for "chronological
disciplinary records for Jeffrey Epstein at MCC[,]" Central Office conducted a search of the
SENTRY database, as described in the Christenson Declaration. The searches at MCC did
3
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=== Page 4 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 4 of 10
not return additional records responsive to this request.
12. INTAKE SCREENING FORM - Based on my own experience and conversations with
BOP staff at MCC and Central Office, the DROP File for Epstein was the only likely place
where "the intake screening form for Jeffrey Epstein at MCC" would be located. To locate
the DROP File for Epstein, I requested that the Case Management Coordinator for the MCC
Records Department, obtain the file. The Case Management Coordinator obtained the file, which
did not contain records responsive to Plaintiff's request for intake screening forms. Based on
my own experience and conversations with MCC and Central Office staff, there are no other
locations likely to produce records responsive to this request.
13. SECURITY DESIGNATION - With respect to Plaintiff's request for "the security
designation records for Jeffrey Epstein at MCC[,]" Central Office conducted a search of the
SENTRY database, as described in the Christenson Declaration. The searches at MCC did
not return additional records responsive to this request.
14. INMATE PROFILE - With respect to Plaintiff's request for "the inmate profile for Jeffrey
Epstein at MCC[,]" Central Office conducted a search of the SENTRY database, as described
in the Christenson Declaration. The searches at MCC did not return additional records
responsive to this request.
15. INCIDENT REPORTS - With respect to Plaintiff's request for "[a]ll incident reports
related to Jeffrey Epstein at MCC[,]" Central Office conducted a search of the SENTRY
database, as described in the Christenson Declaration. The searches at MCC did not return
additional records responsive to this request
16. MEDICAL REPORTS - With respect to Plaintiff's request for "all medical reports related
4
EFTA00015431

=== Page 5 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 5 of 10
to Jeffrey Epstein at MCC [,]" Central Office conducted a search of the Bureau Electronic
Medical Record ("BEMR") database, as described in the Christenson Declaration. The
searches at MCC did not return additional records responsive to this request.
17. VISITOR LOG - With respect to Plaintiff's request for visitor "[t]he signed visitor log for
Jeffrey Epstein at MCC[,]" MCC staff searched for responsive log books and located one log
book showing a visitor for Jeffrey Epstein on July 30, 2020. MCC staff determined that any
other responsive log books were handed over to OIG on or about August 22, 2019. With the
exception of the scanned copies of certain log book pages described in the Christenson
Declaration, the searches at MCC did not return additional records responsive to this request.
18. MEETING DOCUMENTS - With respect to Plaintiff's request for "[d]ocuments showing
when MCC staff held meetings regarding Jeffrey Epstein, and who attended[,]" Central Office
conducted a search for responsive emails and meeting invites within the GROUPWISE
system, as described in the Christenson Declaration. In addition, MCC staff searched for
responsive records. The individuals identified in Paragraph 5 who searched for responsive
records include all MCC staff likely to have attended any staff meetings regarding Epstein
and therefore the only MCC staff reasonably likely to have responsive records. The searches
at MCC did not locate documents responsive to Plaintiff's request.
19. SUICIDE WATCH REMOVAL MEETING DOCUMENTS - With respect to Plaintiff's
request for "[a]ll records generated from the meeting at MCC during which it was decided
that Jeffrey Epstein would be taken off suicide watch[,]" Central Office conducted a search
for responsive emails and meeting invites within the GROUPWISE system, as described in
the Christenson Declaration. In addition, MCC staff searched for responsive records. The
5
EFTA00015432

=== Page 6 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 6 of 10
individuals identified in Paragraph 5 who searched for responsive records include all MCC
staff likely to have attended any meetings regarding the removal of Epstein from suicide
watch and therefore the only MCC staff reasonably likely to have responsive records. The
searches at MCC did not locate documents responsive to Plaintiff's request relating to any
meeting regarding the removal of Epstein from suicide watch.
20. POST- WATCH REPORT - With respect to Plaintiff's request for "the Post-Watch report
compiled in order to take Jeffrey Epstein off suicide watch[,]" Central Office conducted a
search of the BEMR, as described in the Christenson Declaration. The searches at MCC did
not return additional records responsive to this request.
21. OVERTIME SIGN-UP SHEETS - With respect to Plaintiff's request for "[t]he overtime
sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and on July
22 and 23[,]" Central Office conducted a search of the Roster/Overtime Program, as described
in the Christenson Declaration. The searches at MCC did not return additional records
responsive to this request.
22. STAFF AUGMENTING RECORDS - With respect to Plaintiff's request for "[d]ocuments
showing which staff were augmented at MCC and what positions they worked in on Aug. 9
and 10, and on July 22 and 23[,]" Central Office conducted a search of the Roster/Overtime
Program, as described in the Christenson Declaration. The searches at MCC did not return
additional records responsive to this request.
23. VIDEO CAMERA FOOTAGE - With respect to Plaintiff's request for "[a]ll video camera
footage at MCC pertinent to the Jeffrey Epstein suicide and the first suicide attempt[,]" MCC
staff determined that all responsive video footage had been handed over to the Federal Bureau
6
EFTA00015433

=== Page 7 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 7 of 10
of Investigation on or about August 10, 2019. Nonetheless, MCC searched the Special
Investigator Administrator's office, the place where video camera footage responsive to the
request would ordinarily be located. No responsive video footage was located.
24. SUICIDE ATTEMPT AND SUICIDE RECORDS - With respect to plaintiff's request for
"[a]ll BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt[,]" in
addition to the searches by Central Office described in the Christenson Declaration, MCC
staff located responsive records through their searches of their files.
25. SUICIDE WATCH REMOVAL DOCUMENTS With respect to Plaintiff's request for
"[a]ll BOP documents, including email correspondence and meeting minutes, pertaining to
the decision to remove Jeffrey Epstein from suicide watch[,]" Central Office conducted a
search for responsive emails and meeting invites within the GROUPWISE system and a
search for psychological records in the BEMR database, as described in the Christenson
Declaration. In addition, MCC staff searched for responsive records. The individuals
identified in Paragraph 5 who searched for responsive records include all MCC staff
reasonably likely have records responsive to plaintiff's request, including meeting minutes or
email correspondence. In particular, the individuals identified in Paragraph 5 who searched
for responsive records include all MCC staff likely to have attended any meetings regarding
the removal of Epstein from suicide watch. The searches at MCC located responsive records,
including saved email correspondence but no meeting minutes. The results of the MCC staff's
search largely overlapped with the results of Central Office's search of the GROUPWISE and
BEMR systems, but also located the Form 583 for Epstein's apparent suicide attempt, and
memoranda and reports of Epstein's apparent suicide attempt. After these searches were
7
EFTA00015434

=== Page 8 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 8 of 10
conducted, I double-checked with the Executive Assistant to the MCC Warden and the
MCC's chief psychologist and confirmed that they did not have any meeting minutes or any
record of a meeting held to determine that Epstein would be removed from suicide watch. The
Executive Assistant to the MCC Warden and MCC's chief psychologist are the only individuals
likely to have attended or to have been aware of such a meeting, and thus the only MCC
staff reasonably likely to have responsive records.
26. SPECIAL INVESTIGATIVE REPORTS - With respect to Plaintiff's request for "[a]ll
BOP special investigation reports mentioning Jeffrey Epstein[,]" Central Office conducted a
search of the BOP Special Investigative Section, as described in the Christenson Declaration.
The searches at MCC did not return additional records responsive to this request.
27. CORRESPONDENCE - With respect to Plaintiff's request for "[a]ll BOP correspondence
with the U.S. Attorney's Office regarding Jeffrey Epstein[,]" Central Office conducted a
search of the BOP GROUPWISE system, as described in the Christenson Declaration. The
searches at MCC did not return additional records responsive to this request.
28. PHONE LOGS - With respect to Plaintiff's request for a "full log of Mr. Epstein's phone
calls to and from the MCC[,]" Central Office searched the TRUVIEW system, as discussed
in the Christenson Declaration. In addition, MCC staff searched for responsive records and
located memoranda regarding calls that Epstein had made on legal lines at the MCC. Several
of his calls on the MCC legal line were described in memoranda saved on MCC computer
systems and located by MCC staff. Other than these memoranda, no systematic record or log
was located of Epstein's calls while he was incarcerated.
29. EMAIL COMMUNICATIONS - With respect to Plaintiff's request for "[a]ll email
correspondence to and from Mr. Epstein while he was at the MCC (including any
8
EFTA00015435

=== Page 9 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 9 of 10
correspondence through the Corrlinks system or any other email system he had access to[,]"
Central Office conducted a search of the TRULINCS system. The searches at MCC did not
return additional records responsive to this request.
30. VISITOR LOGS - With respect to Plaintiff's request for "[t]he full log of people who
visited Mr. Epstein while he was at the MCC and when they visited[,]" MCC staff searched
for responsive log books and located one log book showing a visitor for Jeffrey Epstein on
July 30, 2020. MCC staff determined that any remaining responsive log books were handed
over to OIG on or about August 22, 2019. With the exception of the scanned copies of certain
log book pages described in the Christenson Declaration, the searches at MCC did not return
additional records responsive to this request.
31. VISITOR LISTS - With respect to Plaintiff's request for "[t]he full list of people that Mr.
Epstein had requested to be on his approved visitor list[,]" Central Office conducted a search
of the TRUVIEW system, as described in the Christenson Declaration. The searches at MCC
did not return additional records responsive to this request.
32. EMAIL LIST - With respect to Plaintiff's request for "[t]he full list of people that Mr.
Epstein had requested to be on his approved email correspondence list[,]" Central Office
conducted a search of the TRUVIEW system, as described in the Christenson Declaration.
The searches at MCC did not return additional records responsive to this request.
33. APPROVED CALL LIST - With respect to Plaintiff's request for "[t]he full list of people
that Mr. Epstein had requested to be on his approved call list[,]" Central Office conducted a
search of the TRUVIEW system, as described in the Christenson Declaration. The searches
at MCC did not return additional records responsive to this request.
9
EFTA00015436

=== Page 10 ===
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 10 of 10
34. RECORDINGS OF TELEPHONE CALLS - With respect to Plaintiff's request for a
"recordings of the last three phone conversations that Mr. Epstein had[,]" Central Office
searched the TRUVIEW system, as discussed in the Christenson Declaration. In addition,
MCC staff searched for responsive records, and did not locate any recording of any calls by
Epstein. BOP has determined that no recording was made of Epstein's calls on any legal or
non-legal line.
Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury that the foregoing is
true and correct.
Executed this 5th day of August 2020.
Nicole McFarland
Staff Attorney
Metropolitan Correctional Center
Bureau of Prisons
10
EFTA00015427


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=== Page 1 ===
JANE DOE #2
(
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 95
2/6/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 96
2/6/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 97
2/6/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 122
3/31/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 123
4/1/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
Ct 6
2/5/05 -
EPSTEIN
Enticement of a minor to engage in
2/6/05
prostitution
Ct. 43
3/31/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct 60
3/30/05 -
EPSTEIN
Attempted enticement of a minor to
4/1/05
engage in prostitution
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 1
JANE DOE #2
EFTA00016004


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell Bail Application Exhibits
Date: Wed, 09 Dec 2020 15:10:22 +0000
Attachments: 2020-12-08_defense_renewed_motion_for_bail_(1of2).zip
Hi
Please find attached a zip folder containing the Part 1 of the exhibits pertaining to Maxwell's renewed bail application. I
apologize, my previous email was not delivered to you because the single file size was too large. A second email
containing Part 2 of the exhibits is forthcoming momentarily. Thank you very much, and please let me know if you
encounter any issues.
All the best,
From
[Contractor]
Sent: Wednesday, December 9, 2020 9:54 AM
To:
Subject: Maxwell Bail Application Exhibits
Hi
I hope you're both well! Please find attached a zip folder containing the exhibits pertaining to Maxwell's renewed bail
application. Thank you, and please let me know if you have any questions or encounter any issues.
Take care,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016465


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 19:16:44 +0000
Yes!
From:
(USANYS)
Sent: Thursday, December 31, 2020 2:16 PM
To:
(USANYS)
Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Did it go through now?
On Dec 31, 2020, at 2:12 PM,
(USANYS)
wrote:
You never have to explain the frustrations of Government issued IT to me!
From:
(USANYS)
Sent: Thursday, December 31, 2020 2:11 PM
To:
(USANYS)
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Really sorry - I swear I looked at this immediately, but outlook has been very temperamental today, and I can't always
tell when it freezes.
From:
(USANYS)
Sent: Thursday, December 31, 2020 2:06 PM
To:
(USANYS)
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Oh no! Thanks!
From:
(USANYS)
Sent: Thursday, December 31, 2020 2:05 PM
To:
(USANYS)
Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
I sent a response hours ago! Let me see where it is.
On Dec 31, 2020, at 2:03 PM,
(USANYS)
wrote:
I am sure you are swamped with pre-holiday craziness, so just wanted to flag that re: the below, our BOP contacts are
eager to head out (and we have asked them to stay until this is filed in case there are any changes). So if there is any
EFTA00015902

=== Page 2 ===
way to bump this up the list a bit it would help keep the peace.
Thanks!
From:
(USANYS)
Sent: Thursday, December 31, 2020 12:19 PM
To:
(USANYS)
i
(USANYS)
>;
(USANYS)
is
(USANYS)
is
)
in
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Hi
: Please see our proposed letter, which I understand you would like to review, as well as
declarations from associate wardens at the MDC and MCC. The GC and PC chiefs have signed off
on these drafts.
With apologies for the time sensitivity, our contacts at MCC/MDC have asked to leave early today
(before 1/1:30), and have asked us to finalize the declarations as soon as possible.
Best,
From:
(USANYS)
Sent: Wednesday, December 30, 2020 24 PM
To:
(USANYS)
V.
(USANYS)
V.
(USANYS)
is
(USANYS)
is
)
is
)
>;
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
,
who is the Associate Warden at the MCC. There's a possibility that there will be a very
short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I
am working through that with
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:45 PM
To:
(USANYS)
in
(USANYS)
i
(USANYS)
is
(USANYS)
is
is
)
i
(USANYS)
Cc:
(USANYS)
is
(USANYS)
i
(USANYS)
is
(USANYS)
EFTA00015903

=== Page 3 ===
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks. Who is signing the declaration for BOP?
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:40 PM
To:
(USANYS)
>;
(USANYS)
>;
(USANYS)
>;
(USANYS)
>;
)
is
)
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS) 1
>
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
: We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to
explain that the discovery and counsel access accommodations that have been provided to Maxwell
and Rivera, respectively, result from the specific circumstances of their cases, the specific requests
of their lawyers, and their individual housing circumstances. On all of these factors, there are
several important differences, including:
-
The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need
for such expanded discovery access is greater in the Maxwell case.
-
At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside
the general population. She therefore has sole access to a room to use a computer and phone
for approximately 13 hours a day. Rivera, by contrast, is housed in the general population.
-
There are approximately 80 other inmates at the MCC in Rivera's unit that use the same
VTC room for court appearances, probation interviews, and attorney meetings. By contrast,
Maxwell shares access to the MDC VTC room with substantially fewer inmates. The MDC
can therefore provide 15 hours of VTC meetings with her attorneys without compromising
access for other MDC inmates. The same is not true for Rivera at the MCC.
Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera
receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day
long, and only takes it back at night to charge it. Therefore, the MCC is now providing the same
amount of electronic discovery access to Rivera that Maxwell receives at the MDC.
As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will
compromise access for other inmates. If defense counsel expresses a need for additional time, the
MCC will continue to find ways to accommodate those requests as best as they can.
Please let me know if you have any questions or would like to discuss this further.
Best,
From:
(USANYS)
>
Sent: Monday, December 21, 2020 :42 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
i
(USANYS)
is
is
)
i
(USANYS)
EFTA00015904

=== Page 4 ===
Cc:
(USANYS)
is
(USANYS)
i
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks,
Can you keep me posted on what we think will be the substance of the draft declaration when you
know (that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences
between MCC and MDC, as well as specific differences in their housing situations?
From:
(USANYS)
Sent: Monday, December 21, 2020 :35 PM
To:
(USANYS)
i
(USANYS)
>;
(USANYS)
is
(USANYS)
>;
)
is
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
All:
I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a
sex trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
general population) cannot be extended to Justin Rivera (detained at the MCC in the general
population).
Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at
the MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was
originally scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had
new counsel appointed, citing an irreconcilable breakdown with his former counsel.
Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal
health concerns. We have two court orders in place to address these issues: (1) a laptop order,
which requires the MCC to provide Rivera access to a laptop for three hours per day; and (2) a
videoconference order, which requires the MCC to make available four hours of videoconferencing
each week, in addition to any telephone or videoconference calls obtained through the Federal
Defenders.
At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time
Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation,
although defense counsel has stated that they may request more time in the future. However, in a
letter last night and during a court conference this morning (transcript attached), defense counsel
cited the accommodations that the MDC has provided to Maxwell, describing them as "strikingly
different and far superior" to those afforded to Rivera. Defense counsel further suggested that
Rivera was being treated differently on account of his race, gender and class. Judge Engelmayer
stated that the disparity in access "jumped off the page" and that the optics were "terrible," and
asked us to explain the rationale for the differing treatment. After conferring with
and
EFTA00015905

=== Page 5 ===
before our conference, we explained our understanding that the disparity comes
down to the fact that Maxwell and Rivera have very different housing situations, with Maxwell's
situation being more amenable to greater access to electronic discovery review and legal visits.
Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
explaining in more detail why the accommodations provided to Maxwell cannot be extended to
Rivera. Based on the recent bail opposition in the Maxwell case, I believe the differences in
counsel/discovery access are as follows:
Accommodation
Maxwell
Rivera
Review of electronic
13 hours per day/7 days per
3 hours per day/7 days per
discovery (NB: each
week (91 hours total)
week (21 hours total)
defendant has laptop access)
Counsel visits (by video)
3 hours per day/5 days per
Four hours per week (plus an
week (15 hours total)
additional two hours
scheduled through the
Federal Defenders) (6 hours
total)
Weekend legal calls
As needed
Not available
The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two
criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure
that you were all aware of this issue. We are also happy to set up a call to discuss this further. In
the meantime, we are working with
to identify the appropriate declarant and
draft an explanation for the Court.
Best,
Assistant United States Attorney
United States Attorney's Office for the Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
<2020.12.31 Thompson Decl re Maxwell (v.2).docx>
<2020.12.31 Letter on Rivera and Maxwell discovery and counsel access (v.3).docx>
<2020.12.31 Best Decl Re Rivera (v.2).docx>
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From:
To:
Subject: Epstein cars current registrations
Date: Thu, 04 Jul 2019 01:34:21 +0000
Importance: Normal
Yukon 2015
Suburban 2019
Suburban 2016
Suburban 2018
Express 2017
Bentley 2017
Suburban 2016
Escalade 2012
2010 Suburban
2015 Suburban
2013 Expedition
2008 Range Rover
2007 Hummer II
2002 Benz 500
2010 Suburban
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To: "Weingarten, Reid"
Cc:
)"
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Date: Sun, 14 Jul 2019 22:39:02 +0000
Importance: Normal
Reid,
No problem. Don't hesitate to be in touch prior to the hearing if that would be useful, otherwise we'll plan to see you at
10:00 and go from there.
thanks,
From: Weingarten, Reid
Sent: Sunday, July 14, 2019 18:35
To:
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
So just leaving the jail tomorrow morn has gotten really jammed give me a second after the hearing and we
can talk about whether or not a visit makes sense
Sent from my BlackBerry 10 smartphone.
From:
)
Sent: Saturday, July 13, 2019 2:30 PM
To: Weingarten, Reid
Cc:
);
)
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
No problem - didn't take it as a slight, we all just have various travel and other case obligations in the near-term and want
to make sure somebody can be responsive at all times. And that also sounds helpful re: an agenda, we'll look out for that
tomorrow evening and be ready to chat on Monday at 8:00.
thanks,
From: Weingarten, Reid
Sent: Saturday, July 13, 2019 14:17
To:
Cc:
is
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Apologies to
and
was not meant as a slight assumed you would forward hopeless on a
computer. worse on a blackberry which I am using now. (will make best efforts to CC them on this
message) probably best I send a proposed informal agenda after I meet with the client tomorrow evening so I
don't get out over my skies reid
EFTA00014330

=== Page 2 ===
Sent from my BlackBerry 10 smartphone.
From:
)
Sent: Saturday, July 13, 2019 2:01 PM
To: Weingarten, Reid
Cc:
);
)
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Reid,
In our experience it's rarely a waste of time to talk, and we would be available on Monday morning. And we'll be in the
best position to be able to talk productively if you could give us a general sense of what you'd like to address?
Also, if you could please include
and
on any communications- know it's often convenient to just hit
reply but we want to make sure we're all in the loop since parts of the team will be more and less available at various
times if and when you reach out.
thanks,
From: Weingarten, Reid
Sent: Saturday, July 13, 2019 12:05
To:
)
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Will be with the client tomorrow evening till about 7 if you will be in your office then don't think it would be a
waste of time to talk about the state of play. if not I could stop by Monday morning around 8 reid
Sent from my BlackBerry 10 smartphone.
From:
)
Sent: Friday, July 12, 2019 5:40 PM
To:
Cc:
'Martin Weinberg'; Weingarten, Reid;
);
)
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
To the Chambers of Judge Berman:
With apologies for the delay, attached please find a courtesy copy of the Government's reply in support of its detention
memo and in opposition to the defendant's motion for bail, including exhibits, filed this afternoon in the above-captioned
case. Defense counsel is copied.
I hope everyone has a good weekend.
Thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00014331


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=== Page 1 ===
From:
To:
)"
Cc:
)"
Subject: [EXTERNAL EMAIL] - Epstein image & video files
Date: Fri, 16 Oct 2020 02:17:45 +0000
I'll check in the morning and let you know.
On Oct 15, 2020 9:48 PM,
)"
wrote:
Hi
Thank you so much for dropping off the image and video files from the Epstein devices earlier today. I've looked through
all the drives, and it appears that the folders for device number NYC024342 are empty. Is it right that there were no
images or videos extracted from that device?
And I believe we are still waiting on images and videos from the below devices (but please let me know if I'm wrong):
NYC024328
NYC024329
NYC024329
NYC024353
NYC024365
NYC024366
NYC024371
NYC024383
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
(NY) (FBI)"
Cc:
)"
Subject: follow-up call
Date: Fri, 12 Jun 2020 17:12:14 +0000
Attachments: 2019-09-25
and
Are you available for a call at 10 a.m. on Monday morning? We wanted to follow up on some of the information we've
been emailing about. Below are the topics we'd like to discuss-if you're able to address these topics on the call, we'd
very much appreciate it.
What current/active financial accounts are we are of for Maxwell, including credit card accounts?
What is the connection between Maxwell and UMB bank, and what did we expect to find when we issued the
subpoena?
We issued a subpoena to
on 9/25/19 (attached). SDNY does not have returns - have you received them?
When was the last time we ran a SAR/CTR check on Maxwell? Have there been any filings in the past year for her
accounts?
Thanks,
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: RE: Ghislaine Maxwell custody
Date: Fri, 03 Jul 2020 14:23:41 +0000
Thanks very much for passing this along. The permitted attorney contact on the list below only includes Vogelman
without reference to her New York counsel. Would it be possible to add her two New York attorneys-Chris Everdell and
Mark Cohen-to the list of people Maxwell can speak with on the phone, please?
Ideally, we would like to get them added today so that they can speak with their client over the weekend to facilitate our
discussions with them about next steps in the case.
Thanks,
From:
Sent: Thursday, July 2, 2020 3:47 PM
To:
Subject: Fwd: Ghislaine Maxwell custody
FYI
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 3:43:43 PM EDT
To: "NHD-SUPERVISORS (USMS)" <USMS-NHD-SUPERVISORS@usms.doj.gov>
Cc:
Subject: Ghislaine Maxwell custody
To all:
Below are the restrictions we have put in place regarding Ms. Maxwell during her stay at Merrimack DOC. I. If you have
any questions please feel free to call or email me.
Due to the high profile status of this case Inmate Maxwell will be closely monitored. The following directives
apply and shall not be deviated from without express permission from
myself or
1.
Inmate Maxwell will be housed in M1
2.
SRT personnel will be posted in medical and will only be relieved only by SRT personnel
EFTA00014910

=== Page 2 ===
3.
Staff will not converse with the inmate outside of the standard communication required related to the
inmate's health and safety
4.
Inmate Maxwell will remain on a 15 minute observation watch
5.
All rounds, and touch probe rounds will be conducted and documented in XJail
6.
Third Shift Supervisors will download the touch probe rounds and camera footage from the previous day
at 0000 hours each day. The video from the medical cell DVR will be downloaded onto a USB drive and will
be tracked via the designated tracking form provided. Supervisors are directed to deliver this documentation
and video to
Monday July 6th
7.
Inmate Maxwell will be authorized to communicate with her legal counsel, Lawrence Vogelman. This
contact is only authorized after Atty Vogelman provides the appropriate PIN
8.
Any and all requests from Inmate Maxwell are to be directed to
only
At no time are staff authorized to make statements to the press regarding this matter or our SOP regarding this
inmate.
Supervisory Deputy United States Marshal
District of New Hampshire
Concord, New Hampshire
office
This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is addressed and
may contain information that is privileged, confidential, or otherwise protected from disclosure. Distribution or copying
of this e-mail or the information contained herein by anyone other than the intended recipient is prohibited. If you have
received this e-mail in error, please notify me immediately and destroy all electronic and paper copies of this e-mail.
EFTA00014911


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=== Page 1 ===
From: Gloria Allred
To:
)"
Cc:
)"
)"
Subject: RE: Call this week
Date: Wed, 01 Apr 2020 19:43:22 +0000
Inline-Images: image001.png; image002.png
I finally heard from
She had ordered a new phone and it had not yet arrived. I explained options and she
will give me a decision tomorrow
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best
Lawyers RECOGNIZED BY
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 11:08 AM
To: Gloria Allred
Cc:
)
is
Subject: RE: Call this week
Please call my cell at
(If we end up needing a conference line l'll send that before 3:00 EST as well.)
thanks,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:54
To:
)
Cc:
is
Subject: RE: Call this week
That works. Please advise as to which number I should call.
Gloria Allred
EFTA00016237

=== Page 2 ===
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIA ALLRED
2020
Best
Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:51 AM
To: Gloria Allred
Cc:
)
is
Subject: RE: Call this week
Yes, if that works for you - so in a little more than an hour. Or let us know if there's a different preferable time.
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:50
To:
Cc:
is
)
Subject: RE: Call this week
3P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
EFTA00016238

=== Page 3 ===
From:
Sent: Tuesday, March 31, 2020 10:46 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Gloria,
That would be great, thanks. Would 3:00 work for you? Or please let us know if there's a more convenient time, we can
be flexible.
thanks again,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:31
To:
Cc:
is
Subject: RE: Call this week
May I call you with an update? What time today are you available for a call?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:03 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Gloria,
We were wondering if you or your colleagues have been able to reach any of the clients we discussed last week? It would
be very helpful to know their views and reactions shortly - and we're of course happy to speak with them directly as well
if that would be helpful.
EFTA00016239

=== Page 4 ===
thanks,
From:
Sent: Thursday, March 26, 2020 15:45
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Gloria,
Thanks for speaking with us just now. The individuals we mentioned are
Thanks,
Sent from my iPhone
On Mar 26, 2020, at 10:16 AM, Gloria Allred
wrote:
Thank you.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Thursday, March 26, 2020 7:12 AM
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
We can use the below conference line:
Dial-in:
Code: 933571
Thank you,
On Mar 25, 2020, at 8:55 PM, Gloria Allred
wrote:
EFTA00016240

=== Page 5 ===
I would be happy to send a Zoom number to you or feel free to send me a conference number to call.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 5:53 PM
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Thanks very much. 3pm EST works for us. What number should we call?
Best,
On Mar 25, 2020, at 8:21 PM, Gloria Allred
wrote:
Yes. What time tomorrow is better for you, 3 P.M. e.s.t. or 4P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 1:55 PM
To: Gloria Allred
Cc:
is
Subject: Call this week
Gloria,
EFTA00016241

=== Page 6 ===
Would you have time for a call with the SDNY Epstein team tomorrow or Friday? We would like to provide you with a
bit of an update and discuss some of your clients in particular.
Hope you are staying safe and healthy.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
EFTA00016242

=== Page 7 ===
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
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=== Page 1 ===
November 30, 2021
prep notes
AUSAs
SA
recalls an address book at the PB residence that he observed during his employment
for JE:
This book was different from
Roladex. The book was either dark blue or
black. It was a bit bigger than a big iPhone, very thick, and contained a lot of
names.
estimates it was between 200 and 300 pages. The book's cover was
blank, and the pages were black ink printed on white paper.
first saw the book years before
left, in the 1990s around 1994, 1995, or
1996.
thinks either
(both assistants) told
that he had to
put the blue/black book on the desk.
was told to put book on JE's desk in
living room, JE's desk in the master bedroom, JE's night table in the master
bedroom, JE's desk in the cabana, GM's desk next to the pantry room, and by the
phone in the kitchen. These books were replaced every year and updated with
more friends and contacts.
recollection is that those updates were adding
entries, not removing entries.
recalls that Mr. Epstein used the books the most.
has also seen GM use the
books.
doesn't know who added to the books or updated them.
looked inside the books at the time of his employment, and they contained all
of Mr. Epstein and Ms. Maxwell's friends and employees, Mr. Epstein's family
members were there,
name was there, Prince Andrew's name was there,
Donald Trump's name was there. Each page had a name, address, company,
phone numbers for different homes.
looked through multiple versions of this
book from mid-1990s until 2002 when left. It included contact information for
massage therapists, chefs, pilots, houses from ranch and employees who worked
at different locations at ranch were.
When copies of the book were replaced with updated versions, the staff threw out
the old versions. All versions every year looked the same. No writing on the
cover.
showed the following Government Exhibits:
GX-298
recognizes to be a diagram of first floor of JE PB house. During
employment, GM's desk was in Garden Room, JE's desk was in Lake
Room,
desk was in staff room
GX-297
recognizes to be a diagram of second floor of JE PB house. Pink or
green sofa was in JE's bathroom attached to master bedroom, which is where JE
got his massages. GM bathroom attached to master bedroom was where basket
was with sex toys kept in it.
GX-299 - shows pool house at JE PB property
GX-606
recognizes to be document given to
and his wife around the late
1990s by GM. It is a copy of pages that
recalls receiving in the form of a
1
EFTA00016590

=== Page 2 ===
booklet. The document contained all of the tasks that were demanded of him.
remembers seeing this manual for the first time when a duchess from England
came. She was a woman who was supposed to be royalty and supposed to teach
the staff how to properly maintain a house. This document was a booklet
provided to
by this lady who was hired by JE and GM.
There was a different page that was a laminated page with information for the
guest with
contact information, which was not in the booklet and is not in
this exhibit.
When first received this booklet,
told GM, I've been working for this for
years, I'm not going to do this. GM told
many times that this is the way it
goes and must be.
fought with JE once when JE didn't have a pen by his night table with a light,
and guest didn't have a toothbrush, which was required by the booklet.
yelled
at JE about it.
fought more with GM about the handbook. GM complained about food trays
and other details that
did not follow from the handbook.
reviewed each page of this exhibit.
specifically remembers pages 1- 6 and
8 being in the version of the booklet he received. Re page 7,
remembers he
was supposed to answer Mr. Epstein residence, never Ms. Maxwell residence, so
doesn't recall that portion of page 7, but otherwise recognizes it.
doesn't
remember page 9.
remembers page 10 as a checklist that
had to follow.
remembers all the checklists in the manual as tasks he had to complete.
never filled out the checklists. GM asked
to fill out the checklists, but
never did, and GM was pissed.
Lady from England, GM, and JE all called
even though that was not
his name.
was supposed to fill out all of these checklists before JE arrived at PB
residence. Food had to be thrown out each time JE left, even if it had not gone
bad.
was no longer working for JE when this exhibit is dated in 2005,
was gone
by then, but everything in this exhibit except page 9, a portion of page 7, and a
portion of page 31 re alcoholic beverages is what
remembers from the booklet.
read the entire booklet when first given to him in the late 1990s
GM told
that he was supposed to do all of this work while being "invisible"
only remembers receiving one copy of this booklet, which he read but never
used. This copy is dated later, but it contains the same rules and checklists he had
to follow.
had a uniform he had to wear: black pants, white shirt usually, for parties a
tuxedo, GM told him what to wear
was not supposed to talk to anyone about anything of JE, GM, and the guests;
applied to all guests; applied to everyone
did not discuss personal problems with guests, per the rule
2
EFTA00016591

=== Page 3 ===
remembers the rule that a copy of Mr. Epstein and Ms. Maxwell's telephone
directories must be placed to the right of each telephone (same one talking about)
Page 8,
followed the rule not to disclose JE and GM behavior
References to JE directory versus GM directory:
recalls them being the same
size and same length with same entrances and blank covers, but believes first page
had JE or GM.
Ms. Maxwell's Bathroom referenced in checklists was on the right-hand side of
JE bedroom as you enter; can't recall what photographs were required to be
placed there.
was supposed to complete checklists every time JE arrived
Ms. Maxwell's desk was in the garden room
Page 24 references special papers made for JE and GM specifically printed
stationary and supposed to leave it by the desk
Page 28 references "Max," was GM's tiny Yorkie terrier.
recalled that GM
traveled with the dog on JE's plane.
Page 31,
remembered having to throw out everything even if wouldn't go bad
(but doesn't remember the Beverages list)
Page 36
recalls that he would weekly wipe and sanitize massage tables
had to clean bathroom and replace sheets every day
Page 55,
recalls that JE and GM had the preferences for breakfast listed here
JE told
how to use the message books and to use them to take messages from the
beginning of
employment.
wrote down messages during each phone call. When
a message book was full, he put it in the storage area next to his desk in the staff room.
3
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=== Page 1 ===
From:
To:
Subject: Epstein meeting at 3
Date: Wed, 14 Aug 2019 13:41:42 +0000
Hi all,
has scheduled a brief meeting regarding the Epstein case today at 3pm in the 8th floor library with the PC chiefs,
and the Epstein team. I've put it on all of your calendars.
Thanks,
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=== Page 1 ===
From: "Kathleen E. Cassidy"
To:
Susan Necheles
Cc:
Bec: "USAHUB-USAJournal111"
Subject: RE: following up
Date: Mon, 14 Dec 2020 21:57:56 +0000
Embedded: RE:_following_up.msg
Sender:
Subject: RE: following up
Message-Id:
<MN2PR14MB2512749E6797A7ED0850FCCFDFC70@MN2PR14MB2512.namprd14.prod.outlook.com>
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=== Page 1 ===
From
To
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 01:55:06 +0000
Thanks,
From:
Sent: Sunday, November 28, 2021 10:15 AM
To:
Subject: FW: United States V. Ghislaine Maxwell --
opens
A really incredible prosecution team - good luck tomorrow!
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell
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
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=== Page 1 ===
From:
To:
(
Subject: Update
Date: Tue, 27 Aug 2019 14:24:18 +0000
Attachments: JeffreyEpstein_update_8.26.19.docx
This went up this morning
Best Regards,
Special Agent in Charge
Criminal Division
FBI New York Office
(0
(0
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=== Page 1 ===
From: "
To:
Cc:
Subject: MCC Pros Memo
Date: Fri, 27 Sep 2019 14:42:34 +0000
Attachments: MCC_Pros_Memo_v10.doc
All,
Please see attached for your review.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
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=== Page 1 ===
ROY BLACK
BLACK
JESSICA FONSECA-NADER
HOWARD M. SREBNICK
SREBNICK
KATHLEEN P. PHILLIPS
SCOTT A. KORNSPAN
LARRY A. STUMPF
KORNSPAN
AARON ANTHON
MARCOS BEATON, JR.
MARIA NEYRA
& STUMPF
MATTHEW P. O'BRIEN
JACKIE PERCZEK
JENIFER J. SOULIKIAS
MARK A.J. SHAPIRO
P.A.
NOAH Fox
JARED LOPEZ
E-Mail:
December 9, 2009
Assistant United States Attorney
United States Attorney's Office
Southern District of Florida
500 South Australian Avenue
Suite 400
West Palm Beach, Florida 33401
RE: Jeffrey Epstein
Dear
You emailed me a letter on November 2, asking whether Jeffrey Epstein's
place of employment remained constant. It has. I reviewed a Google map to
confirm that the distance between that place of employment and the location
where he was stopped by Palm Beach Police is less than 3 miles (and that the
location where he was walking was on a direct route to his place of work).
It has taken us a while to respond to your letter because other matters have
consumed our time and effort. Over the past five weeks, the massive billion-dollar
conspiracy created and run by Scott Rothstein has been exposed. On Monday,
Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad
Edwards, and others with tortuous and fraudulent abuses of process that resulted
in serious injury to Mr. Epstein. A copy of the Complaint is enclosed with this
letter.
As you know, Rothstein's firm represents
and
,
three of the plaintiffs who have brought civil actions against Mr.
Epstein. The Rothstein firm was a criminal enterprise that used the litigation
against Mr. Epstein to lure investors into its billion-dollar ponzi scheme. We
believe that Rothstein and his co-conspirators used the government's criminal
investigation as a means to perpetrate and further their fraud. For example:
201 S. Biscayne Boulevard, Suite 1300
Miami, Florida 33131
Phone: 305-371-6421
Fax: 305-358-2006
www.RoyBlack.com
EFTA00014178

=== Page 2 ===
December 9, 2009
Page 2
1. The Rothstein lawyers sought disclosure of the NPA to prove who the
victims were, and used the NPA to "corroborate" their false claims.
2. Rothstein and his co-conspirators abused the legal process in other
cases. They forged the signature of judges, and even forged an Eleventh Circuit
opinion.
3. Rothstein lawyers demanded phony protective orders.
4. In our case, they sought discovery of Epstein's plane logs to fish for
celebrities to extort and convince investors that huge amounts of settlement
money was available from them.
5. Rothstein lawyers litigated claims using Jane Doe names to make the
phony settlements appear plausible to investors, and also to prevent any
investigation into the claims by the investors.
6. Rothstein and others told investors that your office directed the women
to the Rothstein firm.
7. Rothstein and his co-conspirators gathered information illegally, and
shared it with the other plaintiffs' attorneys in this case.
8. Rothstein deceived investors into believing that he had the confidential
victim list you prepared, and that he had a copy of the NPA.
9. Rothstein told investors that his investigators had sophisticated
electronic bugging equipment to gather evidence against Epstein.
10. Rothstein told investors that Epstein had offered to settle the cases for
$200 million, when there have been no such discussions about any settlement at
any price.
And it does not stop there. Rothstein, his partners, and his employees
investigated and litigated the
, and
cases with funds derived
,
from their criminal enterprise and their fraud and misrepresentations to investors.
But we have been stymied from debunking fraudulent claims brought by the
Rothstein criminal enterprise because you have threatened that such action on
Black, Srebnick, Kornspan & Stumpf, P.A.
EFTA00014179

=== Page 3 ===
December 9, 2009
Page 3
our part would constitute a breach of the NPA. So the Rothstein lawyers, once
again, are using the power of the federal government to perpetrate and further
their fraud. And the expense of litigating these cases has been extreme. For
example,
who I do not believe was aware of the Rothstein crimes,
is now demanding over $2 million in legal fees.
As a lawsuit brought by some of the investors' claims, Rothstein and his
partner Edwards used Jeffrey Epstein as bait. The litigation strategy, media
pronouncements, and investigatory initiatives of Rothstein and Edwards were
calculated to support Rothstein's deceptions rather than to advance the position
of his clients. I bring these facts to your attention so that if you had contact with
Edwards or those associated with him in the past concerning Mr. Epstein, you
consider not continuing communications with any of them in the future.
I would like a short conference with you in person to talk about Mr.
Epstein's progress through the state criminal justice system, to discuss several
outstanding issues that I want to make sure you have accurate information about,
and, from my perspective, most importantly, so that I can provide Mr. Epstein
with proper counsel going forward. If you email me some dates when you are
available this month, we can schedule a short meeting in your office hopefully
before the year ends.
Sincerely,
Roy Roy Black
RB/wg
Enclosure
Black, Srebnick, Kornspan & Stumpf, P.A.
EFTA00014180


c1: EFTA00015738
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015738.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Wed, 07 Apr 2021 16:05:44 +0000
Attachments: New_York_Evidence_List_-_Annotated_by_AUSA.xlsx; Florida_Evidence_List_-
_Annotated_by_AUSA.xlsx;Florida_Evidence_Sub-Item_List_-_Annotated_by_AUSA.xlsx
Inline-Images: image001.jpg
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)'
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of
the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at 347-344-8771.
EFTA00015738

=== Page 2 ===
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated
spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item
about which we plan to provide you with a letter later this week.
These spreadsheets also indicate where each item will be made available for the defense to review. As you will see,
we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be
available for review next week. Please let me know if you believe you need to review that item, and I will inquire as
to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as
opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute
the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data,
and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness
statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item
to produce for you to review.
Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence
at the Bronx warehouse.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, April 5, 2021 10:48 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your
modifications and clarifications are acceptable to us. Below I address each specifically:
The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the
Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for
that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early
next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will
have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
EFTA00015739

=== Page 3 ===
Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to
500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items
will be designated "Confidential," in which case they may be photographed, but the photographs should be treated
as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential evidence items include both nude and non-nude
portions, in which case we would permit photography of the non-nude portions.
In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer
segregating any electronic media that contain witness statements during this review. This is because all of the
witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does
not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the
contents of the electronic media with these non-testifying witness statements, but you are of course welcome to
review the original recordings themselves.
In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and
will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at
500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a
private meeting space for the defense team.
Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the
2,100 that were not previously reviewed and the electronic images that were previously provided for review at the
MDC.
Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April
13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals
produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The
Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not
yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me
whether they can accommodate these specific dates.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Friday, April 2, 2021 5:36 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
:
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
EFTA00015740

=== Page 4 ===
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
EFTA00015741

=== Page 5 ===
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
Highly Confidential Electronic Images
EFTA00015742

=== Page 6 ===
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
EFTA00015743

=== Page 7 ===
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 16, 2021 4:40 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
EFTA00015744

=== Page 8 ===
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
EFTA00015745

=== Page 9 ===
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
)
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00015746

=== Page 10 ===
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
EFTA00015747

=== Page 11 ===
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00015748

=== Page 12 ===
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007 It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
EFTA00015749

=== Page 13 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
)
is
)
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
)
is
)
is
(USANYS)
EFTA00015750

=== Page 14 ===
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00015751


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=== Page 1 ===
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: January 28, 2020 at 5:50:44 PM EST
To: daniel bates
Subject: Re: Andrew claims he hasn't been approached
Thank you, we'll decline.
Note: you have Geoffrey Berman listed as the State Attorney for New York. He's the United States Attorney for
the Southern District of New York.
Sent from my iPhone
On Jan 28, 2020, at 5:15 PM, daniel bates
wrote:
Hello
This story is going in the Daily Mail in the UK tomorrow and will be up on MailOnline shortly.
Do you have any comment?
He is claiming he hasn't been approached which contradicts what Mr Berman said.
Can you tell us how you reached out to Andrew?
Thanks
Daniel
Forwarded message
From: Lewis Pennock
Date: Tue, Jan 28, 2020 at 5:11 PM
Subject: pdf
To: daniel bates
Disclaimer
EFTA00016810

=== Page 2 ===
This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential
and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the
addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender
immediately and then delete it from your system. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St,
Kensington, London, W8 5TT. Registered No 84121 England.
Daniel Bates
Journalist in New York
www.danielgbates.com
<andrew spread.pdf>
EFTA00016811


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=== Page 1 ===
From:
To:
Cc:
Bec:
Subject: MM Digital Evidence
Date: Tue, 08 Dec 2020 17:36:47 +0000
Embedded: MM_Digital_Evidence.msg
Sender:
Subject: MM Digital Evidence
Message-Id:
<BN3P110MB050048327927A004F27FA1FB90CD0@BN3P110MB0500.NAMP110.PROD.OUTLOOK.COM
>
Recipient:
EFTA00016462


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=== Page 1 ===
From: Martin Weinberg
To:
)"
Subject: Re: US V Epstein
Date: Wed, 14 Aug 2019 20:55:50 +0000
Yes, will do
Thanks
Sent from my iPhone
On Aug 14, 2019, at 4:41 PM,
)
wrote:
Marty,
That time works for us, thanks. Could you please circulate a dial-in?
Thanks.
Sent from my iPhone
On Aug 14, 2019, at 11:23 AM, Martin G. Weinberg
wrote:
Alex, Mike and I are authorized to continue the discussion of potential civil forfeiture issues with you. Are you
available at 930 tomorrow morning? Thanks
Martin G. Weinberg, Esq.
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.
EFTA00014337


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c0:
=== Page 1 ===
From:
To:
Subject: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Date: Mon, 14 Sep 2020 19:23:06 +0000
Attachments: FINAL_LETTER.PDF
The attached document is in regard to the above referenced case, to which you are a party of or have an interest
in. If you have any questions, please contact our office at
EFTA00016314


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=== Page 1 ===
From:
To:
,
Subject: FW: Protective Order
Date: Fri, 17 Jul 2020 18:59:49 +0000
Attachments: 2020.07.16_GM_protective_order_for_discovery_(AJN)_-_Def_edits.docx;
2020.07.16_GM_protective_order_for_discovery_(AJN)_-_Def_edits.pdf
Inline-Images: image001.jpg; image002.png; image005.jpg
Happy to discuss a response to this if it would be useful.
From: Christian Everdell
Sent: Friday, July 17, 2020 12:11 AM
To:
is
>;
Cc: Mark S. Cohen
>; Jeff Pagliuca
>; 'Laura Menninger'
Subject: Protective Order
and
-
Laura Menninger tried sending the below message to you earlier this evening on behalf of defense counsel, but it seems
that it has not been delivered yet due to technical problems. I am forwarding it on to you myself. Please confirm receipt.
Thanks,
Chris
Counsel:
Attached please find our proposed Protective Order, with a redline and a clean copy.
As a prefatory note, it is equally in our client's interest as much as in yours to have this matter tried before a jury of
impartial peers. We have no desire to try this case in the press. Unfortunately, however, some of your prospective
witnesses and their counsel have repeatedly and persistently violated Local Rule 23.1 and ethics standards pertaining to
pretrial publicity. Defense witnesses should be afforded the same protections from harassment and intimidation as are
government witnesses. Government witnesses should be on the same footing as both the Defendant and defense
witnesses in terms of access to and use of discovery.
Regarding public filings, because each document filed in this case redacted or under seal will be subject to a press request
to unseal it, we need to ensure at the outset that we only mark things as confidential that the Court (and Second Circuit)
will view as such when making an unsealing determination, so we included a definition of "Confidential" consistent with
the case law. See, e.g., Brown V. Maxwell.
A few notes to explain specific changes.
1. We have clarified treatment of non-confidential discovery materials from confidential discovery materials. We
have modified the access restrictions for non-confidential materials because we did not believe them necessary or
appropriate.
EFTA00015968

=== Page 2 ===
2. We have fine-tuned the definition of what constitutes "Confidential" consistent with prior decisions in the Second
Circuit and common law privacy rights of individuals. This language has been adopted by magistrates in this Circuit
for civil cases.
3. We have removed the category of "Highly Confidential." If there is a category of documents that think warrants
separate treatment, we should discuss what types of evidence you believe should fall into such category or and
why they merit separate treatment from "confidential information." We cannot imagine, for example, that
discovery contains child pornography, which counsel will not possess in any event.
4. With respect to our client's access to the Discovery and Confidential information, your proposal would not allow
any means for her to review any Confidential information because you required she review it in the presence of
counsel and we are not allowed in-person visits with her. We propose that, consistent with numerous other federal
pretrial detainees, the Government shall make available a laptop containing all of the Discovery (including any
Confidential Information) for her to review while in custody. She would have regular access to the laptop
consistent with MDC regulations.
5. We deleted language regarding designation of Confidential documents simply by virtue of their contents or a cover
letter. For tracking and clarity, each document or item you believe should be designated Confidential should be
marked as such, because cover letters or other indexes may be separated from their contents.
6. We allow for the party's designation to be controlling but we believe (consistent with the law) that a party who
disputes the designation can seek relief from the Court.
Please let us know if our proposal is agreeable to you and we can file it with the Court as unopposed.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
Christian Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
view bio
www.cohengresser.com
EFTA00015969

=== Page 3 ===
New York
Seoul
Paris
Washington DC
London
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.
EFTA00015970


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
Subject: Epstein 6(e) Order Signed and Ready to Pick Up
Date: Fri, 31 Jan 2020 22:23:06 +0000
I just got a call from Judge Nathan's clerk that she signed the order and it's ready to be picked up from her
chambers, if one of you want to engineer that right now.
EFTA00015023


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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, 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:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney.
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
May 12, 2021
/s
AUDREY STRAUSS
United States Attorney for the
STATE UNITED COURT
Southern District of New York
FOR
THE
RICT
YORK
NEW
Assistant United States Attorney
One St. Andrew's Plaza
New York, New York 10007
Telephone:
rev. 02.01.12
EFTA00014663


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=== Page 1 ===
Michael C. Miller
Steptoe
STEPTOE & JOHNSON IIP
New York, NY 10036
main
www.steptoe.com
August 1, 2019
By Electronic Mail
Assistant United States Attorneys
U.S. Attorney's Office for the
Southern District of New York
New York, New York 10007
Re:
United States V. Jeffrey Epstein, No. 19-cr-00490
Defendant's Request for Particulars, Discovery and Brady Material
Dear
:
We are writing on behalf of Jeffrey Epstein regarding discovery in this case. In order to
preserve Mr. Epstein's rights, and to request additional information, we respectfully submit this
formal request for discovery in this case pursuant to the Fourth, Fifth and Sixth Amendments to
the United States Constitution, Rules 12, 16, and 26.2 of the Federal Rules of Criminal
Procedure, and the additional authority set forth below.
This request encompasses not only documents and information in your possession,
custody, or control, but also documents that the government has the legal right or practical ability
to obtain. Such information includes but is not limited to information in the possession, custody,
or control of any agency of the United States involved in any way in regulating or investigating
the activities alleged in the Indictment or related transactions, including but not limited to the
Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI")
and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"),
and the Department of Homeland Security. In addition, such information includes information in
EFTA00016136

=== Page 2 ===
Steptoe
August 1, 2019
SIPPIOR & JOHNSON LLP
Page 2
the possession, custody, and control of any local, state, or foreign law enforcement entities
involved in any way in regulating or investigating the activities alleged in the Indictment or
related transactions.¹ Finally, such information includes information gathered and/or produced
from private entities aiding in the government's investigation.²
The defendant, through counsel, requests that the government comply with all of its
discovery obligations under federal law, including but not limited to the following:3
I.
Statements of the Defendant
A.
Pursuant to Rule 16(a)(1)(B)(i) of the Federal Rules of Criminal Procedure, Mr.
Epstein requests any written or recorded statements made by Mr. Epstein, the
existence of which is known, or by the exercise of due diligence may become
known, to the government. This request includes, without limitation:
1.
All interview memoranda summarizing any interview of Mr. Epstein by
the government, including all drafts of such interview memoranda;
2.
All transcripts and/or recordings of conversations in which Mr. Epstein
participated;
3.
All wire and oral communications made by Mr. Epstein that were
transmitted to or intercepted by, for or on behalf of any government agent
or employee or any agency or entity of the government;
4.
All written or recorded statements of witnesses that reflect, relate, or
incorporate any statements made by Mr. Epstein; and
5.
All other documents that purport to reflect, relate, or incorporate any
statements made by Mr. Epstein.
1 Such entities include but are not limited to the New York Police Department, Manhattan District
Attorney's Office, State Attorney's Office for the 15th Judicial District in and for Palm Beach County, the Palm
Beach County Sheriff's Office, and New Mexico Attorney General's Office, which recently confirmed that it would
be sharing evidence with "New York prosecutors." See Patrick Hayes & Chris Ramirez, Balderas Believes Previous
Investigations Failed Epstein's Alleged NM Victims (July 16, 2019), https://www.kob.com/new-mexico-
news/balderas-believes-previous-investigations-failed-epsteins-aleged-nm-victinms/5425345/
2 See Curt Devine, Private Investigator Has Spent 1 Decade on Jeffrey Epstein's Trail, CNN.com (July 20,
2019), https://www.cnn.com/2019/07/19/us/private-investigator-fisten-epstein-scx-case-invs/index.html.
3 All of these requests are continuing in nature, requiring supplementation in accordance with, inter alia,
Rule 16(c) of the Federal Rules of Criminal Procedure.
EFTA00016137

=== Page 3 ===
Steptoe
August 1, 2019
STEPTOE & JOHNSON LLP
Page 3
6.
The portion of any written record containing the substance of any oral
statement made by Mr. Epstein, whether before or after arrest, in response
to interrogation by any person then known to Mr. Epstcin to be a
government agent. See Fed. R. Crim. P. 16(a)(1)(B)(ii). This request
includes, without limitation, all documents, including notes, prepared by
any FBI employee or agent that contain the substance of any relevant
statement made by Mr. Epstein.
7.
The substance of any other oral statement made by Mr. Epstein, whether
before or after arrest, in response to interrogation by any person then
known by Mr. Epstein to be a government agent, if the prosecution intends
to use that statement at trial. See Fed. R. Crim. P. 16(a)(1)(A).
II.
Documents and Tangible Objects
A.
Pursuant to Rule 16(a)(1)(E) of the Federal Rules of Criminal Procedure, Mr.
Epstcin requests all documents, tangible objects, or copies or portions thereof:
1.
Obtained from or belonging to Mr. Epstein, or that belonged to Mr.
Epstein at the time of the alleged offenses, or that belong or belonged to
any agent or employee of Mr. Epstein or any entity allegedly associated
with Mr. Epstein. See Fed. R. Crim. P. 16(a)(1)(E)(iii).
2.
The government intends to use at trial in its casc-in-chief. See Fed. R.
Crim. P. 16(a)(1)(E)(ii). Mr. Epstein requests that any materials in this
category be specifically identified from among the materials produced
pursuant to Mr. Epstein's other Rule 16 and Brady requests, both to enable
counsel to prepare effectively for trial and to afford Mr. Epstein
opportunity to move to suppress any evidence the prosecution intends to
use in its case-in-chief. See Fed. R. Crim. P. 12(b)(3) and 12(d)(2).
3.
Material to the preparation of Mr. Epstein's defense, see Fcd. R. Crim. P.
16(a)(l)(E)(i), including but not limited to those items set forth in
paragraphs II.A.4 to II.A.27 below.
4.
That are alleged as the basis for Counts 1 and 2's assertion that the alleged
crimes were committed "in or affecting interstate commerce."
5.
Relating to Mr. Epstein or the conduct alleged in the Indictment that were
introduced as exhibits before the grand jury. Mr. Epstein requests that any
materials in this category be specifically identified from among the
materials produced pursuant to Mr. Epstein's other Rule 16 and Brady
requests.
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6.
Relating to Mr. Epstein or the conduct alleged in the Indictment that were
obtained by or for the grand jury or pursuant to any grand jury, pretrial, or
trial subpoena.
7.
Relating to Mr. Epstein or the conduct alleged in the Indictment obtained
from any witness who testified before the grand jury, or their counsel, or
who was interviewed or consulted during the course of the grand jury
investigation.
8.
Relating to Mr. Epstein or the conduct alleged in the Indictment that were
obtained by any search or seizure pursuant to a search warrant or
otherwise.
9.
Relating to Mr. Epstein or the conduct alleged in the Indictment obtained
from any federal, state, or local governmental, regulatory, or legislative
body or agency.
10.
Relating to press releases or press conferences concerning Mr. Epstein or
the investigation of him or others named in the Indictment, and all other
documents relating to any contacts between the government and
representatives of the media concerning Mr. Epstein or others named in
the Indictment, or the investigation of Mr. Epstein or others named in the
Indictment.
11.
Relating to the reputation of Mr. Epstein including without limitation, any
documents relating, positively or negatively, to Mr. Epstein's reputation
for honesty, integrity, or competence.
12.
Relating to any investigations, interviews, reports, analyses, or other
documents provided by, or to, the U.S. Attorney's Office for the Southern
District of New York, the Department of Justice, the FBI, or any state or
local government or regulatory body or agency, in connection with the
investigation and prosecution of Mr. Epstein.
13.
Referenced, directly or indirectly, in the Indictment.
14.
Relating to communications between Mr. Epstein and any alleged co-
conspirator, indicted or unindicted, concerning any of the matters alleged
in the Indictment.
15.
Relating to, or concerning or referring to, communications between Mr.
Epstein and any other person not named in the Indictment concerning any
of the matters alleged in the Indictment.
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16.
Relating to the "payments" alleged in the Indictment, including but not
limited to any financial records reflecting such payments.
17.
Relating to the finances of Mr. Epstein or entities owned or controlled by
Mr. Epstein.
18.
Relating to the alleged victims, "dozens of minor girls," and/or
"recruiters" in the Indictment.
19.
Obtained from or belonging to agents of Mr. Epstein or entities owned
and/or controlled by Mr. Epstein, including documents obtained from his
employees.
20.
Relating to the scheduling of any massages for or by Mr. Epstein.
21.
Relating to Mr. Epstein's travel or whereabouts during the period alleged
in the Indictment.
22.
Relating to the use of Mr. Epstein's planes.
23.
Relating to access to Mr. Epstein's homes or businesses, including visitor
logs and security camera footage.
24.
Relating to any civil or criminal proceedings concerning the alleged
victims, including but not limited to pleadings, motions, and discovery
materials.
25.
Relating to the negotiation and execution of the: (1) non-prosecution
agreement between the Department of Justice and Mr. Epstein in the
matter captioned In re Investigation of Jeffrey Epstein, dated September
24, 2007 (and any addenda related thereto) (the "NPA"); (2) plea
agreement between the State Attorney's Office for the 15th Judicial
District in and for Palm Beach County and Mr. Epstein, dated that resulted
in his plea of guilty on June 30, 2008 (the "Guilty Plea").
26.
Relating to communications with any lawyer for the alleged victims and
the Department of Justice, including but not limited to communications
with the United States Attorney's Offices for the Northern District of
Georgia, Southern District of Florida, and the Southern District of New
York.
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27.
Relating to any investigation undertaken by the Department of Justice, the
United States Congress4, Palm Beach County Sheriff's Office, or any
other governmental entity into matters related to the NPA, Guilty Plea, or
Mr. Epstein's incarceration in Palm Beach County.
28.
Relating to the "53-page indictment prepared by the FBI" in 2006-2007
and any documents related thereto.
29.
Relating to the redacted footnote in each of the Affidavits in support of the
Search Warrants for the E71st residence that were provided in the first
discovery production
III.
Particulars
A.
The general nature of certain portions of the Indictment does "not advise [Mr.
Epstein] of the specific acts of which he is accused." United States V. Torres, 901
F.2d 205, 234 (2d Cir. 1990). See also United States V. Rigas, 490 F.3d 208, 237
(2d Cir. 2007); United States V. Davidoff, 845 F.2d 1151, 1154 (2d Cir. 1988);
United States V. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). Accordingly,
pursuant to the Sixth Amendment to the U.S. Constitution and Rule 7(f) of the
Federal Rules of Criminal Procedure, Mr. Epstein requests that the government
provide the following information relating to the allegations in the Indictment:
1.
Specifically identify the "dozens of minor girls" and "multiple minor
victims" referenced in the Indictment. See, e.g., Indictment 11 1, 6, 22.
2.
Specifically identify the "other locations" and "multiple states" referenced
in 1 1 and 1 4 of the Indictment, respectively.
3.
Specifically identify each of the individuals referenced in the Indictment,
including but not limited to "Employee-1," "Employee-2," "Employee-3,"
and "other employees." See Indictment 1 18.
4.
Specifically identify the "others" alleged in the Indictment to have
conspired with Mr. Epstein.
4 See Nicholas Fandos, Democrats Demand Briefing and Documents on Epstein Plea Deal, N.Y. Times
(July 11, 2019), https://www.nytimes.com/2019/07/11/us/politics/democrats-acusta.html.
5 See id.
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5.
Specifically identify the "various ways" in which victims were
"particularly vulnerable to exploitation" referenced in 1 3 of the
Indictment.
6.
Specifically identify the "instances" in which "minor victims expressly
told [Mr. Epstein] their age" referenced in 1 4 of the Indictment.
7.
Specifically identify the instances in which Mr. Epstein "escalat[ed] the
nature and scope of physical conduct," including but not limited to
identifying whether any of those instances amounted to physical force,
referenced in 11 9 and 15 of the Indictment.
8.
Specifically identify the property referenced in " 25 of the Indictment.
9.
Specifically identify the "other" overt acts ("the following overt acts,
among others") referenced in 1 22 of the Indictment.
IV.
Brady Material
A.
Pursuant to Brady V. Maryland, 373 U.S. 83 (1963) and its progeny, including
Giglio V. United States, 405 U.S. 150 (1972), United States V. Agurs, 427 U.S. 97
(1976), United States V. Bagley, 473 U.S. 667 (1985), and Kyles V. Whitney, 514
U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests
immediate identification and disclosure of all materials that are exculpatory,
would tend to negate the guilt of Mr. Epstein or mitigate the offenses, would tend
to impeach any potential witnesses, or are relevant to issues of punishment or
sentencing, which are in the government's possession, custody, or control, or
otherwise known to the government, including but not limited to:
1.
Any documents or information indicating or tending to establish that any
of the allegations in the Indictment are not true;
2.
Any documents or information indicating or tending to establish that the
conduct that is the subject of the Indictment did not violate government
laws or regulations;
3.
Any documents or information indicating or tending to establish that Mr.
Epstein did not instigate, control, authorize, approve, or acquiesce in any
conduct that is the subject of the Indictment;
4.
Any documents or information indicating or tending to establish that:
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a.
Mr. Epstein engaged in any conduct that forms the basis of the
Indictment with the good faith belief that his conduct did not
constitute a crime;
b.
Mr. Epstein did not believe the alleged victims were under the age
of eighteen;
C.
Mr. Epstein took steps to prevent minors from entering his
residences;
d.
The alleged sex acts were not the result of force, restraint,
coercion, fraud, or undue influence;
e.
The alleged "recruiters" or any alleged co-conspirators or
accomplices were over the age of eighteen;
f.
Alleged co-conspirators, witnesses, or their counsel have
represented to the government that no wrongdoing occurred in
connection with the conduct alleged in the Indictment;
g.
The alleged victims deceived Mr. Epstein in any way including but
not limited as to their age, family, associates, or history;
h.
The alleged victims received money (or other things of value) from
Mr. Epstein, whether as gifts or in exchange for things other than
sex acts;
i.
The alleged victims received money (or other things of value) after
refusing to perform sex acts.
5.
Any documents or information indicating or tending to establish that:
a.
Some or all of the conduct in the Indictment is subject to the NPA;
and
b.
Some or all of the conduct was known to the government prior to
June 30, 2008.
c.
The identity of "Victims 1,2, and/or 3" were known to the
Government before June 30, 2008
d.
The instant prosecution was initiated as a result of undue political
pressure.
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6.
Any documents or information that may serve to impeach any government
witness, including but not limited to:
a.
Any documents or information that show any conviction or arrest
of any government witness;
b.
Any documents or information relating to promises made or any
consideration or inducements made to any prospective government
witness, whether directly to the witness or indirectly to the
witness's attorney, friends, family, or business associates.
"Consideration" means anything of value or use, including
immunity grants, whether formal or informal, witness fees,
transportation assistance, money, or assurance of favorable
treatment with respect to any criminal, civil, or administrative
matter;
c.
Any documents or information relating to material inconsistencies
between statements given or transmitted by any person to the
government or to any private person or entity, and any statements
or other information which would tend to impeach the credibility
of any intended witness;
d.
Any information bearing adversely on the character or reputation
of any intended government witness, including any evidence of
community reputation for lack of truthfulness;
e.
Each specific instance of conduct from which it could be inferred
that any intended government witness is untruthful;
f.
Any documents or information tending to show the bias of a
potential government witness, including animosity toward Mr.
Epstein, animosity toward a group of which Mr. Epstein is a
member or with which Mr. Epstein is affiliated, a relationship with
an alleged victim, or known but uncharged criminal conduct that
may provide an incentive to curry favor with a prosecutor;
g.
Any documents or information affecting the reliability of a
potential government witness's testimony, including known
alcohol or substance abuse, mental health issues, or other issues
that could affect the witness's ability to perceive and recall events;
h.
Any documents or information relating to a witness or potential
witness's interest in bringing a civil lawsuit against Mr. Epstein or
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August 1, 2019
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seeking restitution or any other form of monetary benefit as a
potential result of his conviction.
B.
The date of and participants in each and every interview (including not only
interviews conducted by the U.S. Attorney's Office for the Southern District of
New York, but also interviews conducted by other law enforcement entities and
any third parties), debriefing, "queen for a day" session, proffer, deposition, or
other statement or description of the alleged facts made by each potential
government witness (whether directly or indirectly, such as a proffer made by
counsel). In addition, please specify, as to each such witness, the first date on
which the witness made any allegation that Mr. Epstein engaged in any allegedly
unlawful conduct or any conduct alleged in the Indictment.
C.
As you are aware, New York has adopted Rule of Professional Conduct 3.8,
entitled "Special Responsibilities of Prosecutors and Other Government
Lawyers," which provides that a prosecutor shall "make timely disclosure to
counsel for the defendant
of the existence of evidence or information known
the prosecutor or other government lawyer that tends to negate the guilt of the
accused, mitigate the degree of the offense, or reduce the sentence " Rule
3.8(d). The Supreme Court has recognized that Rule 3.8 imposes a higher
standard on prosecutors than the standards mandating disclosure of exculpatory
evidence under Brady V. Maryland, 373 U.S. 83 (1963). See Kyles V. Whitley, 514
U.S. 419, 437 (1995) ("[Brady] requires less of the prosecution than the ABA
Standards for Criminal Justice, which call generally for prosecutorial disclosures
of any evidence tending to exculpate or mitigate"); ABA Standards for Criminal
Justice, Prosecution Function and Defensc Function 3-3.11(a) (3d ed. 1993) ("A
prosecutor should not intentionally fail to make timely disclosure to the defense,
at the earliest feasible opportunity, of the existence of all evidence or information
which tends to negate the guilt of the accused or mitigate the offense charged or
which would tend to reduce the punishment of the accused"); ABA Model Rule of
Professional Conduct 3.8(d) (1984) ("The prosecutor in a criminal case shall
make timely disclosure to the defense of all evidence or information known to the
prosecutor that tends to negate the guilt of the accused or mitigates the offense").
Mr. Epstein contends that the foregoing categories of information constitute
Brady and Rule 3.8(d) material, and that disclosure should take place
immediately. Mr. Epstein further requests that the government identify with
particularity and provide copies of all materials that qualify as Brady and Rule 3.8
material, as described above. Please advise us promptly whether the government
will be producing Brady material immediately even if it is contained in what
might otherwise be considered as Jencks material, or whether you take the
position that you are not obligated to produce such material at this time.
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D.
Mr. Epstein also requests the underlying source material for any Brady and Rule
3.8(d) information, as opposed to any summary letter or paraphrased description
of the information. Please advise us promptly whether the government will be
producing underlying source material.
E.
For purposes of the Brady doctrine, "the format of the information does not
determine whether it is discoverable." Department Memorandum for Department
Prosecutors Providing Guidance for Prosecutors Regarding Criminal Discovery,
at 6 (Jan. 4, 2010). For example, material exculpatory information that is
provided "during a conversation with an agent or a witness is no less discoverable
than if that same information were contained in an email." Id. Similarly, the
Second Circuit has recognized that attorney proffers are equally subject to Brady
obligations as witness proffers. States P. Triumph Capital Group, Inc., 544 F.3d
149, 157, 165 (2d Cir. 2008) (recognizing that "[a]n attorney proffer apprises the
government of what the client would be able to provide by way of testimony" and
finding a Brady violation where the government failed to turn over notes from an
attorney proffer). Mr. Epstein therefore expects that all such information will be
memorialized and produced to Mr. Epstein.
F.
Finally, Mr. Epstein notes Rule 4.C.3 of Judge Berman's Individual Practices,
which, inter alia, (1) requires disclosure of Brady materials within two weeks of
its discovery; (2) re-affirms that the government's obligation applies "regardless
of whether the Government 'credits' the Brady Material"; and (3) re-affirms that
the government's obligations extend to "law enforcement and regulatory agencies
that are or have been involved in the prosecution of the defendant or in parallel
proceedings or investigations involving the defendant."
V.
Jencks Material
Pursuant to the Jencks Act, 18 U.S.C. § 3500, and Rule 26.2 of the Federal Rules of
Criminal Procedure, Mr. Epstcin requests that the government provide a list of the names and
addresses of all witnesses (and their counsel) that the government intends to call in its case-in-
chief and all statements of those witnesses in the possession, custody, or control of the
government or any other governmental entity, including but not limited to notes of interviews,
FBI 302s, or other summaries prepared by government attorneys or agents, and grand jury
transcripts and any other witness statements. Mr. Epstein requests that the government begin
providing this material as soon as possible, or in any event no later than February 8, 2020 or, if
there is a setting of the trial date after June 8, 2020, one hundred and twenty days before that trial
date
Criminal Records
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Pursuant to Rule 16(a)(1)(D) of the Federal Rules of Criminal Procedure, Mr. Epstein
requests copies of the prior criminal records, if any, of Mr. Epstein or any indicted or unindicted
co-conspirators.
VI.
Purportedly Privileged Material
Mr. Epstein requests that you identify any person or entity that has asserted any attorney-
client privilege, work-product privilege, common-interest privilege, or any other privilege as the
basis for withholding or not producing, in whole or in part, any documents to the government or
the grand jury during the investigation. Mr. Epstein further requests that you provide all
documents (including all privilege logs) with respect to the assertion of or challenge to any such
claimed privileges.
VII.
Scientific Evidence
A.
Pursuant to Rule 16(a)(1)(F) of the Federal Rules of Criminal Procedure, Mr.
Epstein requests documentation relating to all requests for, and the results of,
physical or mental examinations, scientific tests, or experiments that were
conducted in connection with the investigation of the charges contained in the
Indictment. This includes but is not limited 10:
1.
All forensic examinations of any computer hard drive or handheld mobile
device that Mr. Epstein possessed or to which Mr. Epstein had access;
2.
All handwriting exemplars, handwriting samples, handwriting or
document analyses, and all documents examined or used in or related to
such analyses;
3.
All fingerprint and palm print exemplars, fingerprint samples,
comparisons, and opinions of fingerprint experts, and all documents
examined or used in connection with, or that relate to, those opinions; and
4.
All polygraph examinations, psychological stress examinations, hypnotic
procedures, or any other scientific procedures devised to determine
whether a subject is telling the truth, or to refresh a witness's memory, and
all documents that refer or relate to such examinations.
VIII. Rule 404(b) Evidence
Pursuant to the Fifth and Sixth Amendments to the United States Constitution and Rules
403 and 404(b) of the Federal Rules of Evidence, Mr. Epstein requests that the government
disclose all evidence of similar crimes, wrongs, or acts, allegedly committed by Mr. Epstein (or
any person alleged to have been acting pursuant to his instructions), upon which the government
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intends to rely to prove motive, scheme, opportunity, intent, preparation, plan, knowledge,
identity, or absence of mistake or accident, in its case-in-chief.
IX.
Grand Jury
Mr. Epstein requests that the government disclose the empanelment and adjournment
dates of each grand jury that heard evidence concerning this case and the legal instructions
provided to the grand jury before the Indictment was returned.
X.
Rule 801(d)(2) Evidence
Pursuant to the provisions of Rule 104 of the Federal Rules of Evidence, and the
Defendant's right to a fair trial, Mr. Epstein requests that the government disclose whether it
intends to offer, in its casc-in-chief, any evidence covered by Rule 801(d)(2) of the Federal Rules
of Evidence and that it provide the substance of any such statement. This request includes but is
not limited to:
A.
Any statement as to which Mr. Epstein allegedly manifested his adoption or belief
in its truth. See Fed. R. Evid. 801(d)(2)(B).
B.
Any statement made by another which was purportedly authorized by Mr.
Epstein. See Fed. R. Evid. 801(d)(2)(C).
C.
Any statement made by an agent or employee of Mr. Epstein concerning a matter
within the scope of his agency or employment made during the existence of such
a relationship. See Fed. R. Evid. 801(d)(2)(D).
D.
Any statement made by an alleged co-conspirator of Mr. Epstein during the
course and in furtherance of any alleged conspiracy. See Fed. R.
Evid. 801(d)(2)(E).
XI.
Rule 1006 Evidence
Pursuant to Rule 1006 of the Federal Rules of Evidence, Mr. Epstein requests that he be
advised whether the government will seek to offer any chart, summary, or calculation in
evidence, and requests that all writings, recordings, or other information on which such charts,
summaries, or calculations are based be made available sufficiently in advance of trial for
inspection and copying.
XII.
Suppression Issues
A.
As a predicate to potential motions pursuant to Fed. R. Crim. P. 12, Mr. Epstein
requests that he be informed:
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1.
Whether the government intends to offer into evidence any statement
made by Mr. Epstein or any family member, and the substance of any such
statement;
2.
Whether any evidence in the government's possession, custody, or control
was obtained by a search and seizure conducted by the government, and a
description of such evidence;
3.
Whether any evidence in the government's possession, custody, or control
was obtained through electronic or mechanical surveillance, including
without limitation wiretaps, body wires, pen registers, and/or surveillance
of telephone calls, and a description of such evidence;
4.
Whether any evidence in the government's possession, custody, or control
was obtained through the use of a beeper or other tracking device, or
subpoenas or warrants for GPS or cell tower information that would
disclose Mr. Epstein's whereabouts at any particular time, and a
description of such evidence;
5.
In connection with any tape recording, wiretaps, or other surveillance of
Mr. Epstein during the investigation of the allegations of the Indictment or
any related allegations, Mr. Epstein seeks:
a.
the names and addresses of all such persons whose personal or
business telephones the government tapped or monitored, or whose
conversations or actions the government monitored by other means
without the person's knowledge;
b.
transcripts or other records of the statements or conversations
monitored;
c.
the original recorded tapes created during such surveillance;
d.
the procedures used to conduct such surveillance; and
e.
the authority under which such surveillance was conducted.
6.
Whether any evidence in the government's possession, custody, or control
was obtained through a mail cover and/or trash cover and a description of
such evidence; and
7.
The identities of any informant or undercover agent employed by the
government during its investigation of the charges of the Indictment.
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B.
Mr. Epstein requests that the government disclose whether it intends to introduce
any evidence obtained in the manner described in Section XIII.A.1-6. If the
government intends to do so, Mr. Epstein requests that the government: (1)
identify such evidence; (2) identify the source of the evidence; and (3) disclose
any warrant and supporting affidavits related to the collection of the evidence.
XIII. Seized Information that is Unresponsive or Subject to the Attorney-Client Privilege
It is our understanding that the government has seized materials - including computers
and other portable electronics - that are likely to contain documents and information that are: (1)
outside the scope of the search warrant which purportedly authorized the scarch ("Unresponsive
Data") and/or (2) subject to the attorney-client privilege, the attorney work product doctrine, and
other privileges ("Privileged Data") (collectively, "Seized Data"). As an initial matter, Mr.
Epstein requests that the government produce these materials to defense counsel in their entirety.
Mr. Epstein further requests that the government maintain and preserve audit logs that record
what files were searched, when and by whom, and whether additional copies were made.
With respect to Unresponsive Data, Mr. Epstein requests that the Government: (1)
employ search terms or other protocols to ensure that any review of irrelevant documents was
limited and that irrelevant documents are promptly segregated; (2) disclose such protocols to the
defense; and (3) return any non-seized documents (and the media from which they were
collected) as soon as possible to Mr. Epstein. See Federal Rule of Criminal Procedure 41(g).
With respect to Privileged Data, Mr. Epstein further requests that the government
establish sound procedures to ensure any Privileged Data is appropriately protected, including
but not limited to use of a privilege (or "taint") team to review the documents. We are pleased to
provide the privilege team a list of counsel to Mr. Epstein to aid in this review.
. . .
Please advise us whether the government will provide the requested information SO that
Mr. Epstein can determine whether it will be necessary to move for a bill of particulars or file
other discovery-related motions. For any request for which there is a dispute, Mr. Epstein
requests that you take all necessary steps to ensure the documents and information are preserved
by their custodian.
6 Mr. Epstein reserves all rights to challenge the search and seizure of these materials.
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We are available to discuss any of the foregoing requests with you when convenient. We
reserve the right to request further discovery and additional particulars as the case progresses.
And Very truly yours,
Michael C. Miller
Martin G Weinberg
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=== Page 1 ===
From:
To
Subject
broffer (re abuse)
Date: Mon, 02 Dec 2019 23:47:55 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
"
)"
To:
(USANYS) 4"
,
)"
Subject: RE: Epstein
Date: Wed, 19 Jun 2019 23:24:58 +0000
Importance: Normal
Thanks!! Been an insane pace for months but we're happy with how it's going.
Original Message
From:
(USANYS) 4
Sent: Wednesday, June 19, 2019 16:51
To:
)
i
;
)
Subject: Epstein
Amazing work on this case!
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Case 1:20-cv-00833-PAE Document 39 Filed 01/15/21 Page 1 of 18
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
No. 20-CV-833 (PAE)
V.
FEDERAL BUREAU OF PRISONS,
Defendant.
SUPPLEMENTAL DECLARATION OF KARA CHRISTENSON
I, Kara Christenson, hereby declare as follows:
1.
I am employed by the United States Department of Justice, Federal Bureau of
Prisons ("BOP"), as a Government Information Specialist ("GIS") for Central Office, stationed
at the Federal Medical Center in Rochester, Minnesota ("FMC Rochester"). My background and
employment history with BOP are described in my declaration filed in this matter on August 5,
2020.
2.
The statements made in this declaration are based upon my personal knowledge
and information available to me in my official capacity and about which I have become
knowledgeable.
3.
I submit this supplemental declaration in further support of BOP's motion for
summary judgment in this case and in opposition to plaintiffs' cross-motion for summary
judgment.
4.
Plaintiffs have raised the issue of whether BOP received FOIA requests for video
footage before plaintiffs' own request on August 12, 2020. BOP received a separate FOIA
1
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request (not from plaintiffs) for Metropolitan Correctional Center video records dated August 10,
2019, the same day BOP turned over the video records to the Federal Bureau of Investigation,
and this request was logged on August 12, 2019.
BOP's Productions Since August 5, 2020
5.
On August 11, 2020, BOP produced 77 additional pages of records to plaintiffs,
consisting of 5 pages released in full and 72 pages released in part. These pages included
approximately 57 pages of various log books pertaining to Epstein, including approximately 51
pages of attorney log books showing attorney visits to Epstein. In connection with the BOP's
releases of pages of log books, I need to make a correction to my declaration filed on August 5,
2020. In that declaration at Paragraph 22, I stated that BOP had located two pages of scanned
visitor logs, which it was reviewing and intended to release in part. Instead, BOP located
approximately 51 pages of copies of scanned attorney log books showing attorney visits to
Epstein, which it released to plaintiffs with appropriate redactions.
6.
Relatedly, at Paragraph 39 of my declaration filed on August 5, 2020, I
inadvertently stated that BOP had located and produced with redactions a page from a log
showing a visitor for Epstein on July 30, 2019. In fact, the page (copied onto two pages) that was
produced to plaintiffs with redactions came from an Intake Screening Phone Log showing that
Epstein made a phone call on July 30, 2019, not that he received a visit on that date. BOP did not
produce the cover to this log because it does not refer to Epstein and is non-responsive. Because
the log book showed a phone call, rather than a visit, Paragraph 36 of my declaration filed on
August 5, 2020, should be modified to state that BOP also located one physical log book, the
Intake Screening Phone Log, showing a call made by Epstein on July 30, 2019.
7.
On August 31, 2020, BOP produced 351 additional pages of records to plaintiffs,
consisting of 12 pages released in full and 339 pages released in part. These pages included the
2
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approximately 51 pages of attorney log books, showing attorney visits to Epstein, as attachments
to email records.
8.
In October 2020, BOP reached an agreement with plaintiffs, through counsel,
pursuant to which the Office of Inspector General of the United States Department of Justice
("OIG") would produce back to BOP certain records BOP had produced to OIG in connection
with investigations into Epstein's death, and that BOP would review these records in response to
plaintiffs' FOIA request. BOP subsequently reached a further agreement with plaintiffs, through
counsel, that it would not review emails records in OIG's possession, except for emails to or
from Epstein himself while he was at MCC. BOP has determined that Epstein did not send or
receive any emails himself while he was at MCC. Specifically, any email sent or received by
Epstein while he was at MCC would be logged in BOP's Trulines system, and Trulines shows
that Epstein did not send or receive any emails while he was at MCC. Accordingly, BOP did not
review the email records in OIG's possession.
9.
BOP received approximately 7,475 pages of records back from OIG, not
including emails. I reviewed these pages and determined that approximately 6,898 were non-
responsive or duplicative of records previously reviewed by BOP. Of the remaining pages (the
"Returned Records"), BOP withheld 387 pages in full, pursuant to Exemptions 6, 7(C), and/or
7(A). On January 8, 2021, BOP produced the remaining 190 pages of records to plaintiffs,
consisting of 14 pages released in full and 176 pages released in part. These pages included 8
pages of records that BOP had previously withheld in full pursuant to Exemption 7(A), but that
BOP has since determined in consultation with the United States Attorney's Office for the
Southern District of New York could be released with certain redactions.
BOP's Updated Index
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10.
Attached as Exhibit 1 to this declaration is an updated index of records withheld
in full by BOP in this case (the "Updated Index"). The Updated Index includes certain changes
and additions to the Index submitted as Exhibit 8 to my declaration submitted on August 5, 2020
(the "Original Index").
11.
The Updated Index reduces the number of pages of count documents noted as
withheld at Entry 24 by 18 pages. These 18 pages consist of an inmate census roster dated
August 9, 2019, containing Epstein's name and the names of other inmates held at MCC. Two of
the 18 eighteen pages, including the page showing Epstein's name, were released in part to
plaintiffs.¹ The remaining 16 pages were withheld in full under Exemptions 6 and 7(C) and are
now included at Entry 59 of the Updated Index, along with pages of other inmate census rosters
for other dates.
12.
The Updated Index omits two entries of the Original Index, Entries 34 and 37,
consisting of records from the MCC's Special Housing Unit (the "SHU") that BOP determined
could be released in part, with redactions pursuant to Exemptions 6, 7(A), and 7(C), instead of
withheld in full pursuant to Exemption 7(A).² The Updated Index also omits Entry 54, consisting
1 The first, cover page of this inmate census roster, as received from BOP, appears to have barely
legible handwriting on it. BOP located a copy of this pages with the handwriting moderately
more visible among its previously withheld records. BOP released the version returned by OIG
with the barely legible handwriting and would have redacted the handwriting pursuant to
Exemptions, 6, 7(C), 7(E), and/or 7(F) had it released the more legible version. This census
inmate roster does not appear to specifically concern Epstein (apart from his appearance on one
page of the roster, which was released in part), and the handwriting does not appear to relate to
Epstein but instead appears to relate to counting of inmates.
2 Of the three pages noted at Entry 37 of the Original Index, two pages were duplicates, with
handwritten notes on one of the pages. Because those portions of the page were redacted, only
one copy of these two pages were released in part to plaintiffs. The redacted portions and the
handwritten portions do not appear to relate to Epstein. In addition, the four pages noted at Entry
34 of the Original Index had also been counted in the pages noted at Entry 22, and the page count
noted at Entry 22 of the Updated Index has been reduced accordingly.
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of emails withheld under Exemption 5 and the attorney-client privilege, because plaintiff is not
challenging the withholding of these records.
13.
Entry 19 of the Updated Index includes 12 pages of Epstein's medical records,
withheld in full under Exemption 7(A), and in part under Exemption 6 and 7(C). On August 31,
2020, after I submitted my previous declaration, BOP produced 88 pages of Epstein's medical
records, but withheld in full 12 pages for reasons explained at Paragraph 20 of the August 5,
2020, declaration of Counsel to the Acting United States Attorney Russell Capone.
14.
The Updated Index corrects an inadvertent error that resulted in double counting
of seventeen pages of emails listed at Entry 52 and twenty-nine pages of emails listed at Entry
53.
BOP's Assertions of Exemptions 5 and 7(E) Over Documents Previously Withheld in Full
15.
The Updated Index clarifies that BOP is not asserting Exemptions 5 or 7(E) as a
basis to withhold certain documents in full. BOP has conducted a further review of certain
records that previously were withheld in full pursuant to Exemptions 5 and/or 7(E), in addition to
Exemption 7(A). As a result of that further review, and as reflected on the Updated Index, BOP
is withdrawing its assertion of Exemption 5 as a basis to withhold in full Entries 1, 2, and 12.
BOP continues to assert Exemption 5 as a basis to withhold portions of Entries 2 and 12 for the
reasons explained in my prior declaration, but not Entry 1, as reflected on the Updated Index. All
of these documents are separately withheld in full pursuant to Exemption 7(A).
16.
With respect to the responses to the psychological reconstruction prepared after
Epstein's death, listed at Entry 12 on the Updated Index, the majority of the pages withheld are
drafts, containing comments from various perspectives within BOP on versions of the document
preceding its final version. Five pages of the responses to the psychological reconstruction
5
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=== Page 6 ===
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prepared after Epstein's death consist of a timeline of events, over which BOP is no longer
asserting Exemption 5.
17.
As a result of its further review, BOP is no longer asserting Exemption 7(E) to
withhold any document in full. Specifically, and as reflected on the Updated Index, BOP is
withdrawing its assertion of Exemption 7(E) as a basis to withhold in full Entries 2, 9, 10, 12, 13,
15, 17, 18, and 36. As reflected on the Updated Index, BOP continues to assert Exemption 7(E)
as to non-public information in these documents that would reveal investigatory techniques and
procedures or the specific application thereof, except for Entries 10 and 36, over which BOP no
longer asserts Exemption 7(E). All of these documents are separately withheld in full pursuant to
Exemption 7(A).
18.
BOP is asserting Exemption 7(E) to protect information in the incident report,
listed at Entry 1 on the Updated Index, which would reveal specific steps taken in responding to
an inmate emergency in the Special Housing Unit. Releasing this type of information would
allow inmates to learn the manner in which MCC staff are likely to respond to emergencies and
potentially interfere with staff's ability to manage emergency situations.
19.
BOP is asserting Exemption 7(E) to protect information in the psychological
reconstruction of inmate death, listed at Entry 2 on the Updated Index, which would reveal
particular sources of information that such investigations typically rely on or seek to rely on.
Specifically, it discusses how the availability or lack thereof of specific sources of information
affected an investigation, as well as typical sources routinely relied upon. Because of the specific
constraints under which investigations must proceed in the correctional facility setting,
identification of sources that are typically relied upon or that are unavailable or relied upon in a
specific instance are part of BOP investigatory plans and response, and disclosure of sources that
were unavailable or relied upon or typical sources relied upon could hamper BOP's ability to
6
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=== Page 7 ===
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conduct investigations in the future by alerting staff and/or inmates to such sources and allowing
them to take steps to interfere with sources or evidence.
20.
BOP is asserting Exemption 7(E) to protect information in the inmate
investigative report, listed at Entry 9 on the Updated Index, regarding the use of Security Threat
Group ("STG") designations. STG is an enhanced monitoring technique used to maintain
balanced prison populations in an effort to protect the safety and security of staff and inmates.
Inmates are generally not aware of their placement in an STG, and only certain inmates are
assigned an STG. Not every inmate has an STG assignment. BOP is also asserting Exemption
7(E) to protect information in the inmate investigative report concerning specific steps taken in
responding to an inmate emergency in the Special Housing Unit. Releasing this type of
information would provide an opportunity for inmates to learn the manner in which staff are
likely to respond to emergencies and potentially interfere with staff's ability to manage
emergency situations.
21.
BOP is asserting Exemption 7(E) to protect information in the responses to the
psychological reconstruction prepared following Epstein's death, listed at Entry 12 on the
Updated Index, which would reveal specific steps taken in responding to an inmate emergency in
the Special Housing Unit. Releasing this type of information would provide an opportunity for
inmates to learn the manner in which staff are likely to respond to emergencies and potentially
interfere with staff's ability to manage emergency situations.
22.
BOP is asserting Exemption 7(E) to protect information in an August 14, 2019,
letter, listed at Entry 13 on the Updated Index, that would reveal details about how a BOP team
investigating an incident, known as an After Action Review Team, conducts an investigation,
and the access it requires to BOP facilities to complete its work. Release of these details would
alert staff to systems and information reviewed as part of an investigation and could lead to
7
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=== Page 8 ===
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attempts to distort, delete, or otherwise manipulate details and data relevant to an investigation.
Release of the names of members of the After Action Review Team, contained in the August 14,
2019 letter, would also disclose law enforcement techniques and procedures because the manner
in which team members are selected, the positions they hold, and the locations from which they
were chosen and deployed are critical considerations in the assembly of an After Action Review
Team. Withholding the names of team members protects the investigative process by ensuring
staff are not aware of who is deemed an appropriate team member and reducing the opportunity
to attempt to influence the investigation of an event.
23.
BOP is asserting Exemption 7(E) to protect information in a memorandum and
report from Epstein's July 23, 2019 apparent suicide attempt (Form 583), listed at Entry 15 on
the Updated Index, regarding the use of STG designations, for the reasons stated above with
regard to the inmate investigation report. BOP is also asserting Exemption 7(E) to protect certain
information in the memorandum and report from Epstein's July 23, 2019 attempt (Form 583)
that was obtained from witnesses. In any investigation, identifying witnesses and how an
interview is conducted, including questions and responses, are critical components of the
investigatory techniques of security staff of the BOP, especially in a correctional setting where
there are often multiple witnesses and the correctional setting poses a significant risk of
contamination or influence of witness by other witnesses and/or other inmates. The investigative
techniques involved include what witnesses to interview and what procedures must be
undertaken to ensure the greatest cooperation by the witness during any interview. Witnesses to
an event might influence each other if they are not separated before any interactions or
conversations occur between them. In this sense, the investigative techniques, in a correctional
setting, include strategic decisions that account for the secure and orderly operations of the
correctional facilities to ensure inmate and staff safety is not put in jeopardy. Disclosure of this
8
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=== Page 9 ===
Case 1:20-cv-00833-PAE Document 39 Filed 01/15/21 Page 9 of 18
information in the memorandum and report would reveal how the information was gathered and
could provide an opportunity for inmates to manipulate victims or witnesses to an incident in an
effort to improperly influence an investigation.
24.
BOP is asserting Exemption 7(E) to protect information in a chain of custody
form, listed at Entry 17 on the Updated Index, about where evidence is stored. Release of this
information could provide an opportunity for staff to manipulate evidence or the staff responsible
for controlling it.
25.
BOP is asserting Exemption 7(E) to protect information in the reports of Epstein's
July 23, 2019, apparent suicide attempt, listed at Entry 18 on the Updated Index, regarding
specific procedures, including notification processes, used in an inmate emergency in the Special
Housing Unit. Releasing this type of information would provide an opportunity for inmates to
learn the manner in which staff are likely to respond to emergencies and potentially interfere
with staff's ability to manage emergency situations.
Application of Exemptions to the Returned Records
26.
The Updated Index identifies at Entries 55-61 the pages of the Returned Records
withheld in full by BOP. All of the Returned Records withheld in full by BOP are withheld
under FOIA Exemption 7(A), except for the 2 pages of records showing transferors of funds to
Epstein noted at Entry 58 of the Updated Index and the 274 pages of inmate census rosters at
Entry 59 of the Updated Index, which are withheld under Exemption 6 and 7(C) and discussed
below. The basis for withholdings of Returned Records under Exemption 7(A) is explained in
the accompanying supplemental declaration of Counsel to the Acting United States Attorney
Russell Capone. In addition to the withholdings in full under Exemptions 6, 7(A), and 7(C),
BOP has also withheld certain portions of Returned Records under Exemptions 6, 7(A), 7(C),
7(E), and 7(F).
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=== Page 10 ===
Case 1:20-cv-00833-PAE Document 39 Filed 01/15/21 Page 10 of 18
Threshold Justification for Application of Exemption 7
27.
As a threshold to applying Exemption 7, an agency has to demonstrate that the
"records or information [were] compiled for law enforcement purposes." 5 U.S.C. §552(b)(7).
28.
As explained at Paragraphs 51-53 of my previous declaration, the BOP is a law
enforcement agency.
29.
All of the Returned Records were compiled for law enforcement purposes
because they were compiled in the exercise of BOP's statutory authority to detain certain
individuals. All of these records relate to BOP's operations and were compiled in order to carry
out BOP's responsibilities to protect the safety, security, and orderly operation of BOP facilities,
specifically MCC New York, to protect the public, and/or to protect the safety and care of
inmates at MCC New York, including Epstein. In addition, as with many of the records
previously withheld in this matter, the Returned Records were gathered and provided to OIG in
connection with a law enforcement investigation of Epstein's death. The records at issue in this
FOIA request meet the law enforcement threshold of Exemption (b)(7).
Records Withheld Pursuant to Exemptions 6 and 7(C)
30.
5 U.S.C. § 552(b)(6) ("FOIA Exemption 6") protects from disclosure "personnel
and medical files and similar files the disclosure of which would constitute a clearly unwarranted
invasion of personal privacy." 5 U.S.C. § 552(b)(6).
31.
5 U.S.C. § 552(b)(7)(C) ("Exemption 7(C)") exempts from disclosure records or
information compiled for law enforcement purposes where its disclosure "could reasonably be
expected to constitute an unwarranted invasion of personal privacy." 5 U.S.C. $ 552(b)(7)(C).
32.
Some of the Returned Records withheld by BOP contain personal information
withheld under Exemptions 6 and 7(C) (the "6 & 7(C) Returned Records"). The 6 & 7(C)
Returned Records include personnel files within the meaning of Exemption 6, such as daily
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=== Page 11 ===
Case 1:20-cv-00833-PAE Document 39 Filed 01/15/21 Page 11 of 18
assignment rosters for the MCC. The remainder of the 6 & 7(C) Returned Records are "similar
files" within the meaning of Exemption 6 because they contain information about particular,
identifiable individuals. This information includes personally identifying information, such as
names and contact information, of various third-party individuals other than Epstein.
33.
Exemptions 6 and 7(C) each require a balancing of the privacy interests
implicated by disclosure of a record with the public interest in its disclosure. The privacy
interests implicated by the 6 & 7(C) Returned Records include the privacy interests of BOP
employees, BOP inmates other than Epstein, visitors or senders of funds to BOP inmates, and
legal counsel for BOP inmates. The 6 & 7(C) Returned Records contain personally identifying
information, such as names and contact information, for each of these categories of individuals
and for some individuals detail their association with Epstein or their involvement in Epstein's
incarceration. Release of this information-particularly in light of the intense media interest in
and public speculation concerning Epstein's death-could reasonably be expected to expose
these third parties to unwanted scrutiny, embarrassment, and even harassment or retaliation.
34.
The sole public interest in disclosure to be weighed against these privacy interests
under both Exemption 6 and 7(C) is the public's understanding of BOP or other government
operations. The personal information withheld from the 6 and 7(C) Records will not
significantly contribute to the public's understanding of the operation or activities of BOP or any
other government agency. The withheld personal information does not provide significant
insight into government activities or operations in connection with Epstein's incarceration or the
response of BOP or any other government agency to Epstein's death.
35.
The large volume of publicity and often unfounded speculation concerning the
circumstances of Epstein's death increase the likelihood that disclosure of the information
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=== Page 12 ===
Case 1:20-cv-00833-PAE Document 39 Filed 01/15/21 Page 12 of 18
withheld under Exemptions 6 and 7(C) would cause an unwarranted invasion of personal
privacy.
36.
In light of this public and unfounded speculation about Epstein's death and the
media coverage thereof, it is reasonable to expect that individuals identified through government
disclosures as associated with Epstein's incarceration and death, or investigation of the charges
against Epstein or the circumstances of his death, could be targeted or harassed. Accordingly,
publicizing the identity, contact information, or other personal information about a particular
individual's associations or interactions with Epstein will amount to a significant invasion of
personal privacy, with no meaningful contribution to the public's understanding of how the
government works.
37.
For each category of individuals with personally identifying information present
in the 6 & 7(C) Returned Records, the individual privacy concerns outweigh the putative public
interest in their disclosure.
a. The disclosure of personally identifying information of BOP employees, such
as their names or contact information, would significantly invade their
personal privacy without contributing significantly to public understanding of
how BOP works. Disclosing the names or contact information of individual
BOP employees does not provide insight into how BOP works.
b. The disclosure of personally identifying information of BOP inmates, such as
their names or contact information, would significantly invade their personal
privacy without contributing significantly to public understanding of how
BOP works. The names or contact information of particular inmates sheds no
light on how BOP works.
c. The disclosure of personally identifying information of visitors or senders of
funds to BOP inmates, such as their names and contact information, would
significantly invade their personal privacy without contributing significantly
to public understanding of how the government works. Identification of
individuals who visited or sent money to Epstein or other inmates does not
shed light on BOP conduct or how BOP or any other government agency
works.
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=== Page 13 ===
Case 1:20-cv-00833-PAE Document 39 Filed 01/15/21 Page 13 of 18
d. The disclosure of personally identifying information of legal counsel to
Epstein and other BOP inmates, such as their names and contact information,
would significantly invade their personal privacy without contributing
significantly to public understanding of how the government works.
Identification of counsel to Epstein or other inmates does not shed light on
BOP conduct or how BOP or any other government agency works.
38.
Two sets of Returned Records were withheld in full under Exemptions 6 & 7(C).
One set of the Returned Records, noted at Entry 59 of the Updated Index, consists of 274 pages
from inmate census rosters for July 23-25 and 27-31, 2019, and August 1-6 and 8-10, 2019.
Although Epstein's name appears once on each of these rosters, the pages with his name were
released in part. The 274 pages withheld in full contain no information about Epstein and
instead list the names and some personal information of other inmates at MCC on those dates.
Identification of other inmates incarcerated at the same time as Epstein would shed no light on
BOP's or the government's operations, but would invade the privacy of the other inmates,
including by associating them with Epstein in a government document.
39.
The other set of Returned Records withheld in full under Exemptions 6 & 7(C),
noted at Entry 58 of the Updated Index, consists of 2 pages showing the transferors of funds to
Epstein. Specifically, these pages are electronically generated pages containing details of
transfers of funds to Epstein. The transfers themselves, including the amount of the transfer but
not the names of the transferors, were documented in pages released in part. The pages withheld
in full include identifying details of the transferors. The identity of the transferors of funds to
Epstein would not shed any light on how BOP or the government works, but would invade the
privacy of the transferors, including by detailing their association with Epstein during his
incarceration.
40.
The release of the personally identifying information in the 6 & 7(C) Returned
Records would constitute a clearly unwarranted invasion under Exemption 6, and, at a minimum,
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=== Page 14 ===
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could reasonably be expected to constitute an unwarranted invasion under Exemption 7(C), of
the personal privacy of BOP employees, BOP inmates other than Epstein, visitors or senders of
funds to BOP inmates, or legal counsel for BOP inmates.
Returned Records Withheld Pursuant to Exemptions 7(E)
41.
5 U.S.C. $ 522 (b)(7)(E) ("Exemption 7(E)") exempts from disclosure "records or
information compiled for law enforcement purposes, but only to the extent that the production of
such law enforcement records or information
would disclose techniques and procedures for
law enforcement investigations or prosecutions, or would disclose guidelines for law
enforcement investigations or prosecutions if such disclosure could reasonably be expected to
risk circumvention of the law."
42.
Some of the Returned Records withheld in part by BOP contain information about
or discussion of law enforcement techniques and procedures or guidelines for law enforcement
investigations or prosecutions (the "7(E) Returned Records").
43.
Portions of the 7(E) Returned Records fall within the scope of Exemption 7(E)
because they include information or discussions that would disclose law enforcement techniques
and procedures or guidelines for law enforcement investigations and their use in managing the
MCC. With one exception, none of the information in the Returned Records withheld by BOP
under Exemption 7(E) pertains specifically to Epstein. Instead, the information concerns steps
taken by BOP staff in response to issues at the MCC unrelated to Epstein or primarily routine
actions taken by BOP staff. Specifically, BOP disclosed in part pages of lieutenant's logs,
TRUINTEL logs, inmate census roster pages, and an MCC running board page that mention or
refer to Epstein but also document techniques, procedures, and/or guidelines used in managing
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=== Page 15 ===
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the MCC and enforcing the law there.³ For example, disclosing details of counts within the MCC
or the use of body alarms there would disclose law enforcement techniques, procedures, and/or
guidelines. If the Court requires further information, BOP is prepared to file an ex parte
supplemental declaration explaining in greater detail the techniques, procedures, and guidelines
at issue.
44.
The one redaction in the 7(E) Returned Records made by BOP pursuant to
Exemption 7(E) that does pertain specifically to Epstein is the redaction of certain information
on an electronically generated inmate profile of Epstein that would disclose how BOP classifies
certain inmates for security purposes. Disclosure of that portion of Epstein's inmate profile
would disclose a law enforcement technique or procedure by disclosing how BOP classifies
certain inmates in connection with security issues.
45.
Disclosure of the information in the 7(E) Returned Records withheld pursuant to
Exemption 7(E) would create a risk of circumvention of the law. Disclosure of the information
would provide inmates or other individuals with details about how MCC works and its security.
They could use this information to destabilize the MCC and to perpetrate crimes there.
Returned Records Withheld Pursuant to Exemption 7(F)
46.
5 U.S.C. $ 522 (b)(7)(F) ("Exemption 7(F)") exempts from disclosure "records or
information compiled for law enforcement purposes, but only to the extent that the production of
such law enforcement records or information
could reasonably be expected to endanger the
life or physical safety of any individual."
3 Lieutenant's logs withheld in full pursuant to Exemption 7(A), noted at Entry 49 of the
Updated Index, also contain information that falls with the scope of Exemption 7(E) for the
reasons discussed here.
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=== Page 16 ===
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47.
Some of the Returned Records withheld by BOP in full or in part contain
information that falls within the scope of Exemption 7(F) (the "7(F) Returned Records"). Such
information falls into two categories. First, disclosure of the personally identifying information,
such as names and contact information, of third-party individuals employed by BOP could
reasonably be expected to endanger the life or physical safety of these individuals. Second,
disclosure of certain techniques and procedures used in the management of the MCC could
reasonably be expected to endanger the life or physical safety of BOP employees and inmates
held by BOP.
48.
First, some of the 7(F) Returned Records fall in part within the scope of
Exemption 7(F) because the release of the personally identifying information contained in these
records could reasonably be expected to endanger the life or physical safety of BOP employees
whose personally identifying information is contained in the 7(F) Returned Records. BOP
employees work with inmates and criminal defendants who, upon their release from
incarceration or during their incarceration, might target BOP employees for reprisal. BOP
employees in many cases live in the cities where they work, frequently utilize public
transportation, and regularly engage in community and social activities in those cities. The
release of personally identifying information of BOP employees increases the risks of such
targeting or harassment because it would make it easier for identified employees to be targeted or
harassed. Because of the attention and speculation surrounding Epstein's death, it is reasonable
to expect that individuals identified through disclosures by the government as associated with
Epstein's incarceration and death could be targeted.
49.
Second, some of the 7(F) Returned Records fall in part within the scope of
Exemption 7(F) because the release of information contained therein would reveal details about
the operation and management of the MCC that could be used to destabilize the MCC and
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=== Page 17 ===
Case 1:20-cv-00833-PAE Document 39 Filed 01/15/21 Page 17 of 18
perpetrate crimes there, endangering the lives and physical safety of BOP employees and MCC
inmates. With one exception, none of this information pertains specifically to Epstein. Instead,
the information concerns steps taken by BOP staff in response to issues at the MCC unrelated to
Epstein or primarily routine, but sensitive, actions taken by BOP staff. Specifically, BOP
disclosed in part pages of lieutenant's logs, TRUINTEL logs, inmate census roster pages, an
MCC running board page, and SHU records that mention or refer to Epstein but also document
aspects of the MCC and its operations that are not public and could enable individuals to harm
BOP employees or MCC inmates.4 For example, disclosing certain details of counts within the
MCC or the use of body alarms there could reasonably be expected to endanger the lives and
physical safety of BOP employees and MCC inmates. If the Court requires further information,
BOP is prepared to file an ex parte supplemental declaration explaining in greater detail the
information at issue.
50.
The one set of redactions in the Returned Records made by BOP pursuant to
Exemption 7(F) that does pertain specifically to Epstein is the redaction of certain information on
an electronically generated inmate profile of Epstein that would disclose how BOP classifies
certain inmates for security purposes. Disclosure of those portions of Epstein's inmate profile
could reasonably be expected to endanger the lives and physical safety of BOP employees and
MCC inmates by revealing how BOP classifies certain inmates in connection with security
issues.
4 TRUINTEL reports and lieutenant's logs withheld in full pursuant to Exemption 7(A), noted at
Entries 32 and 49 of the Updated Index, also contain information that falls with the scope of
Exemption 7(F) for the reasons discussed here.
17
EFTA00015509

=== Page 18 ===
Case 1:20-cv-00833-PAE Document 39 Filed 01/15/21 Page 18 of 18
Pursuant to 28 U.S.C. $ 1746, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge and belief.
Executed this_15th_day of January 2021.
Kara Chrotenson
Kara Christenson
Government Information Specialist
FOIA/PA Section (Central Office)
Bureau of Prisons
18
EFTA00015510


c1: EFTA00015210
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015210.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Bec: "USAHUB-USAJournal111" <usahub-usajournal11@usa.doj.gov>
Subject: RE: case records scanning
Date: Mon, 19 Oct 2020 03:34:35 +0000
Embedded: RE:_case_records_scanning.msg
Sender:
Subject: RE: case records scanning
Message-Id:
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To:
To:
To:
EFTA00015210


c1: EFTA00014822
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014822.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
ACCOUNT NAME
ACCOUNT NUMBER
BILL DATE PAGE 1.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
Wireless Number Multi-Line Account
Previous
Payments
Late Payment
Adjustments
Balance
Current
Balance
Received
Charge
Forward
Charges
1,420.53
1,420.53CR
.00
.00
.00
2,074.79
Your billing cycle began on 05/13 and ended on 06/12.
Total Amt Due
2,074.79
Current Monthly Charges
Summary of Individual Number Charges
GUEST GUEST
135.85
-
53.80
G. MAXWELL
892.42
56.62
936.10
Total Current Monthly Charges
DUE UPON RECEIPT
2,074.79
TOTAL AMOUNT DUE
2,074.79
PAYMENT DUE UPON RECEIPT
AMOUNT DUE:
2,074.79
AT&T WIRELESS
Acct Name: JEFFREY R ERSTEIN & CO
P.O. BOX 8220
Account:
025
AURORA IL 60572-8220
Wireless:
JEFFREY E EPSTEIN & CO
457 MADISON AVE
NEW YORK NY 10022-6843
000000030002500000005592276997180002074795
EFTA00014822

=== Page 2 ===
ACCOUNT NAME
ACCOUNT NUMBER
BILL DATE PAGE 3.0
JEFFREY E EPSTEIN &
JUN 14, 2003
AT&T Wireless VoiceDial. You Speak. It Dials.
VoiceDial is the easy and convenient way to enjoy hands-free calling. Just Dia
1 #121 from
your wireless phone, say "Call John Smith at work" and VoiceDial will place the
call. It's
that simple. At $3.99 a month, VoiceDial is a great value and when you sign up
you get
the FIRST MONTH FREE. To sign up, visit us online at www.attwireless.com/ocs,
dial 611 from
your wireless phone or stop by your nearest AT&T Wireless Store. Thanks for ch
oosing
AT&T Wireless.
Regulatory Programs Fee
The Regulatory Programs Fee helps to fund AT&T Wireless compliance with various
government-
mandated programs. This is not a tax or a government required charge. It is a
n additional
monthly charge created, assessed and collected by AT&T Wireless. For more info
rmation and
a description of these government programs, please visit our website at:
http://www.attws.com/legal/rpf.html
PAYMENTS AND ADJUSTMENTS
DETAIL OF PAYMENTS
6/10/03 PAYMENT RECEIVED THANK YOU!
1,420.53CR
TOTAL OF PAYMENTS RECEIVED THROUGH 6/14/03
1,420.53CR
EFTA00014823

=== Page 3 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE
5.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
5/13/03 Through 6/12/03
MONTHLY SE - AT&T DIGITAL ONE RATE $99
99.99
CALL WAITING
.00
INTL DIALING
.00
PCS VOICEMAIL
.00
CALLER ID
.00
DETAIL BILLING
.00
TOTAL MONTHLY SERVICE CHARGES
99.99
HOME AIRTIME CHARGES
5/13/03 Through 6/12/03 - AT&T DIGITAL ONE RATE $99.99
Category
Minutes
Rate
Charge
INCLUDED IN PLAN
17
.000
.00
TOTAL HOME AIRTIME CHARGES
.00
HOME LONG DISTANCE CHARGES
AT&T WIRELESS
12.72
TOTAL HOME LONG DISTANCE CHARGES
12.72
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
3.68
STATE TAX
4.60
LOCAL TAX
4.73
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
2.30
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
2.36
GROSS RECEIPTS SURCHARGE
3.97
TOTAL TAXES, SURCHARGES & REGULATORY FEES
23.14
TOTAL CURRENT MONTHLY CHARGES
135.85
EFTA00014824

=== Page 4 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER
BILL DATE PAGE
6.0
JEFFREY E EPSTEIN &
JUN 14, 2003
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0001 5/13 5:00P
MOBILE
NY
1
0002
5/13
5:02P
MOBILE
NY
2
0003 5/13 6:05P
INCOMING
1
0004 5/14 12:28P
NEW YORK
NY
1
0005
5/14
1:43P
NEW YORK
NY
1
0006 5/14 2:54P S
UN. KINGDO
2
0007 5/14 3:03P
UN. KINGDO
6
9.540
0008 5/15 1:30P
UN. KINGDO
2
3.180
0009 5/15 3:39P
INCOMING
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
17
.00
12.72
CALL CHARACTERISTICS:
S = Long Distance Service Billed Separately
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014825

=== Page 5 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE
7.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
5/13/03 Through 6/12/03
MONTHLY SE - LOCAL PLAN $39.99
39.99
CALL WAITING
.00
INTL DIALING
.00
PCS VOICEMAIL
.00
CALLER ID
.00
DETAIL BILLING
.00
AT&T 2 WAY TEXT MSG $0.00
.00
AT&T TOLL FREE NATIONWIDE
2.50
AT&T TOLL FREE CREDIT
2.50CR
REGULATORY PROGRAMS FEE
.88
TOTAL MONTHLY SERVICE CHARGES
40.87
HOME AIRTIME CHARGES
5/13/03 Through 6/12/03 - LOCAL PLAN $39.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
171
.000
.00
300 ADDITIONAL MINUTES
291
.000
.00
462
.00
TOTAL HOME AIRTIME CHARGES
.00
MESSAGING, CONTENT & APPLICATION CHARGES
5/13/03 Through 6/12/03
Category
Messages
Rate
Charge
SENT MESSAGES
27
.10
2.70
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
2.70
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
1.36
STATE TAX
1.99
LOCAL TAX
2.05
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
.89
LOCAL WIRELESS SURCHARGE
.30
EFTA00014826

=== Page 6 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE
NUMBER
BILL DATE
PAGE
8.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES (CONTINUED)
UNIVERSAL CONNECTIVITY CHARGE
.91
GROSS RECEIPTS SURCHARGE
1.53
TOTAL TAXES, SURCHARGES & REGULATORY FEES
10.23
TOTAL CURRENT MONTHLY CHARGES
53.80
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0001 5/13 10:38A
NEW YORK
NY
1
0002 5/13 10:39A
NEW YORK
NY
1
0003 5/13 12:43P
NEW YORK
NY
1
0004
5/13
1:50P
INCOMING
1
0005
5/13
2:01P
NEW YORK
NY
2
0006
5/13
2:03P
CROFTON
MD
7
0007
5/13
2:10P
WASHINGTON
MD
1
0008
5/13
2:17P
WASHINGTON
MD
3
0009
5/13
2:46P
INCOMING
1
0010
5/13
3:24P
NEW YORK
NY
1
0011
5/14
10:46A
NEW YORK
NY
0012
5/14
10:50A
INCOMING
1
0013 5/14 10:54A
INCOMING
1
0014
5/14
11:39A
WASHINGTON
MD
10
0015
5/14
2:47P
WASHINGTON MD
4
0016
5/14
2:51P
MCLEAN
VA
1
0017
5/14
2:52P
WASHINGTON
DC
4
0018
5/14
2:59P
NEW YORK
NY
1
0019
5/14
3:07P
INCOMING
2
0020
5/14
4:32P
NEW YORK
NY
0021
5/14
5:31P
EVAL
LOCAL
1
0022
5/14
5:32P
NEW YORK
NY
5
0023
5/14
5:38P
MCLEAN
VA
2
0024
5/14
5:39P
WASHINGTON
MD
2
0025
5/14
6:14P
CROFTON
MD
8
0026
5/15
1:17P
NEW YORK
NY
2
0027
5/15
1:19P
CROFTON
MD
2
0028
5/15
1:23P
INCOMING
1
0029
5/15
5:41P
NEW YORK
NY
2
0030
5/15
6:58P
LOCAL
3
0031
5/15
10:02P
NEW YORK
NY
1
0032
5/16 4:26P
MCLEAN
VA
1
0033
5/17
10:56A
RETRIEVAL
LOCAL
1
0034
5/17
10:57A
CROFTON
MD
1
0035
5/17 12:05P
WESTBURY
NY
2
0036
5/17 12:09P
WASHINGTON
MD
1
0037
5/17
6:33P
WASHINGTON MD
1
0038
5/17
7:34P
NEW YORK
NY
1
0039
5/17
7:36P
NEW YORK
NY
0040
5/18
2:26P
INCOMING
1
0041
5/20
1:32P
INCOMING
1
0042
5/21
10:01A
NEW YORK
NY
1
0043
5/22
4:41P
RETRIEVAL
LOCAL
2
0044
5/23
12:00P
RETRIEVAL
LOCAL
1
0045
5/23
2:56P
MCLEAN
VA
1
0046
5/23
4:39P S
MCLEAN
VA
1
0047
5/24
1:32P
WASHINGTON
MD
3
0048
5/24
2:33P
LEVITTOWN
NY
39
EFTA00014827

=== Page 7 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE
PAGE
9.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0049
5/24
3:12P
WESTBURY
NY
9
0050
5/24
4:26P
CROFTON
MD
3
0051
5/24
4:29P
KENSINGTON
MD
1
0052
24
5:17P
WASHINGTON
MD
3
0053
24
6:21P
WESTBURY
NY
2
0054
24
6:58P
WESTBURY
NY
5
0055
24
7:07P
WESTBURY
NY
0056
26
12:16P
NEW YORK
NY
1
0057
26
12:26P
BROOKLYN
NY
4
0058
26
12:30P
QUEENS
NY
1
0059
26
12:32P
NEW YORK
NY
1
0060
26
33P
QUEENS
NY
0061
26
12:34P
NEW YORK
NY
2
0062
26
1
:47P
INCOMING
4
0063
26
12:51P
INCOMING
2
0064
26
54P
BROOKLYN
NY
4
0065
26
4:17P
WASHINGTON
MD
1
0066
26
10:01P
NEW YORK
NY
0067
27
10:55A
INCOMING
0068
27
11:47A
NEW YORK
NY
0069
27
12:09P
NEW YORK
NY
0070
27
12:10P
NEW YORK
NY
0071
27
12:54P
INCOMING
0072
27
1:08P
NEW YORK
NY
0073
27
1:09P
NEW YORK
NY
0074
27
1:34P
INCOMING
0075
27
2:31P
NEW YORK
NY
0076
27
4:19P
NEW YORK
NY
0077
27
4:20P
NEW YORK
NY
0078
27
4:27P
RETRIEVAL
LOCAL
0079
27
4:28P
NEW YORK
NY
0080
27
4:32P
CROFTON
MD
3
0081
27
8:09P
MCLEAN
VA
8
0082
28
9:29A
NEW YORK
NY
0083
28
11:37A
INCOMING
0084
28
12:10P
INCOMING
1
0085
28
1:28P
INCOMING
0086
28
2:57P
NEW YORK
NY
0087
28
4:03P
NEW YORK
NY
0088
28
4:04P
INCOMING
0089
28
4:29P
NEW YORK
NY
1
0090
28
4:36P
NEW YORK
NY
0091
28
4:49P
INCOMING
0092
28
4:59P
INCOMING
1
0093
28
7
11P
NEW YORK
NY
4
0094
28
15P
MCLEAN
VA
1
0095
28
7
16P
MCLEAN
VA
1
0096
28
7:58P
INCOMING
0097
28
10:02P
NEW YORK
NY
0098
29
1:10P
NEW YORK
NY
0099
29
:11P
NEW YORK
NY
0100
29
5:34P
INCOMING
3
0101
29
5:37P
NEW YORK
NY
8
0102
29
7:30P
INCOMING
0103
29
8:04P
NEW YORK
NY
0104
30
10:49A
WASHINGTON
DC
2
0105
30
10:51A
NEW YORK
NY
0106
30
10:56A
WASHINGTON
DC
2
0107
30
10:58A
WASHINGTON DC
4
0108
30
12:24P
INCOMING
1
EFTA00014828

=== Page 8 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 10.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE
TIME
NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0109
5/30
2:30P
LOCAL
0110
5/30
2:45P
NEW YORK
NY
1
0111
5/30
3:48P
INCOMING
1
0112
5/30
7:22P
NEW YORK
NY
3
0113
5/30
7:35P
NEW YORK
NY
1
0114
5/30
7:39P
INCOMING
1
0115
5/30
7:42P
NEW YORK
NY
1
0116
5/30
7:44P
INCOMING
1
0117
5/30
8:43P
NEW YORK
NY
1
0118
5/30
8:45P
INCOMING
1
0119
5/30
9:05P
NEW YORK
NY
1
0120
5/31 11:46A
WASHINGTON MD
3
0121
5/31 12:24P
WASHINGTON MD
10
0122
5/31 1:28P
INCOMING
1
0123
5/31
2:01P
INCOMING
1
0124
5/31
2:24P
NEW YORK
NY
6
0125
5/31
2:30P
WASHINGTON MD
7
0126
6/01 10:58A
INCOMING
1
0127
6/01 10:58A
INCOMING
1
0128
6/01
12:31P
WASHINGTON MD
4
0129
6/01
1:29P
NEW YORK
NY
1
0130
6/01
1:29P
NEW YORK
NY
1
0131
6/02
8:57A
NEW YORK
NY
1
0132
6/02
8:59A
INCOMING
1
0133
6/02
10:13A
NEW YORK
NY
1
0134
6/02 12:03P
CROFTON
MD
2
0135
6/02
3:56P
NEW YORK
NY
1
0136
6/02
4:01P
NEW YORK
NY
1
0137
6/02
7:28P
NEW YORK
NY
1
0138
6/03
9:29A
INCOMING
1
0139
6/03 12:17P
INCOMING
1
0140
6/03
1:07P
INCOMING
1
0141
6/03
2:12P
CROFTON
MD
6
0142
6/03
2:21P
NEW YORK
NY
1
0143
6/03
2:54P
NEW YORK
NY
1
0144
6/03
4:47P
INCOMING
1
0145
6/04
10:57A
NEW YORK
NY
1
0146
6/04 11:12A
WASHINGTON MD
1
0147
6/04 11:13A A
WASHINGTON MD
2
0148
6/04
11:27A
INCOMING
1
0149
6/04
11:49A
LOCAL
2
0150
6/04
11:51A
NEW YORK
NY
1
0151
6/04 11:52A
WASHINGTON MD
1
0152
6/04 11:54A A.
WASHINGTON MD
2
0153
6/04
11:55A
INCOMING
1
0154
6/04 12:05P
LEVITTOWN
NY
3
0155
6/04 12:56P
WASHINGTON MD
4
0156
6/04
12:59P
CROFTON
MD
2
0157
6/04
4:16P
NEW YORK
NY
1
0158
6/04
4:20P
NEW YORK
NY
1
0159
6/04
4:27P
INCOMING
1
0160
6/04
4:31P
NEW YORK
NY
1
0161
6/05 10:42A
CROFTON
MD
3
0162
6/05 11:48A
INCOMING
1
0163
6/05 12:01P
INCOMING
2
0164
6/05 12:08P
NEW YORK
NY
1
0165
6/05 12:21P
NEW YORK
NY
2
0166
6/05
1:02P
NEW YORK
NY
3
0167
6/05
1:52P
INCOMING
1
0168
6/05
1:55P
INCOMING
1
EFTA00014829

=== Page 9 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 11.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0169
6/05
1:56P
NEW YORK
NY
3
0170
6/05
2:24P
NEW YORK
NY
2
0171
6/05
3:12P
NEW YORK
NY
2
0172
6/05
4:25P
NEW YORK
NY
1
0173
6/05
4:39P
NEW YORK
NY
1
0174
6/05
7:09P
NEW YORK
NY
1
0175
6/06
10:17A
HAMMOND
IN
1
0176
6/06
10:19A
INCOMING
1
0177
6/06
2:11P
NEW YORK
NY
1
0178
6/06
3:18P
INCOMING
4
0179
6/06
3:57P
INCOMING
1
0180
6/06
4:01P
HAMMOND
IN
1
0181
6/06
4:10P
NEW YORK
NY
1
0182
6/06
4:40P
HAMMOND
IN
1
0183
6/06
4:41P
HAMMOND
IN
1
0184
6/06
4:43P
NEW YORK
NY
1
0185
6/07
8:48P
HAMMOND
IN
36
0186
6/07
9:41P
INCOMING
1
0187
6/07
9:42P
INCOMING
1
0188
6/08
11:00A
NEW YORK
NY
1
0189
6/08
12:08P
WASHINGTON
MD
1
0190
6/08
12:20P
CROFTON
MD
2
0191
6/08
12:22P
S
MCLEAN
VA
1
0192
6/08
12:29P
NEW YORK
NY
1
0193
6/08
12:30P
NEW YORK
NY
1
0194
6/08
12:31P
NEW YORK
NY
1
0195
6/08
8:20P
INCOMING
1
0196
6/08
8:32P
INCOMING
9
0197
6/09
10:41A
INCOMING
1
0198
6/09
1:31P
INCOMING
1
0199
6/09
1:34P
INCOMING
1
0200
6/09
5:09P
RETRIEVAL
LOCAL
1
0201
6/09
5:36P
INCOMING
1
0202
6/09
6:16P
NEW YORK
NY
1
0203
6/09
6:44P
INCOMING
1
0204 6/09 6:46P
INCOMING
3
0205
6/09
7:02P
NEW YORK
NY
1
0206
6/09
7:04P
INCOMING
1
0207
6/09
7:15P
NEW YORK
NY
1
0208
6/09
7:17P
MCLEAN
VA
1
0209
6/09
7:18P
S
MCLEAN
VA
1
0210
6/10
12:50P
NEW YORK
NY
1
0211
6/10
1:47P
INCOMING
1
0212
6/10
3:44P
NEW YORK
NY
1
0213
6/10
4:22P
INCOMING
1
0214
6/10
7:31P
INCOMING
1
0215
6/10
8:08P
RETRIEVAL
LOCAL
1
0216
6/10
8:09P
NEW YORK
NY
1
0217
6/11
1:22P
NEW YORK
NY
3
0218
6/11
4:27P
MCLEAN
VA
2
0219
6/11
4:41P
INCOMING
1
0220
6/12
3:36P
NEW YORK
NY
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
462
.00
.00
CALL CHARACTERISTICS:
S = Long Distance Service Billed Separately,
A = Automatic Dropped Call Credit
EFTA00014830

=== Page 10 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 12.0
JEFFREY E EPSTEIN &
JUN 14, 2003
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001
5/20
7:20P
10 0002
5/20
7:22P
.10
0003
5/20
7:22P
10 0004
5/20
8:17P
.10
0005
5/20
8:17P
10 0006
5/20
8:17P
.10
0007 5/20 8:18P
9:17P
cc
S
10 0008
5/20
8:18P
0009
5/20
8:18P
S
10 0010
5/20
8:19P
0011
S
10 0012
8:20P
co
.10
.10
5/20
8:19P
5/20
.10
0013
5/20
S
.10 0014
5/20
9:17P
.10
0015
5/20
9:18P
S
10 0016
5/20
9:18P
.10
0017 5/20 9:18P
10 0018
5/20
9:19P
.10
0019
5/20
9:19P
10 0020
5/20
9:19P
.10
0021 5/20 9:19P
10 0022
5/20
9:19P
.10
0023
5/20
9:20P
.10 0024
5/20
9:20P
.10
0025
5/21
7:09P
10
0026
5/21
8:09P
.10
0027 5/27 11:55A
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
2.70
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014831

=== Page 11 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 13.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
5/13/03 Through 6/12/03
MONTHLY SE - AT&T DIGITAL ONE RATE $14
149.99
CALL FORWARDING
.00
THREE WAY CALLING
.00
CALL WAITING
.00
CALLER ID
.00
LINE NUMBER BLOCKING
.00
WORLDCONNECT
7.99
DETAIL BILLING
.00
VOICEMAIL PLUS & TEXT MESSAGING
.00
TOTAL MONTHLY SERVICE CHARGES
157.98
HOME AIRTIME CHARGES
5/13/03 Through 5/29/03 - AT&T DIGITAL ONE RATE $149.99
Category
Minutes
Rate
Charge
INCLUDED IN PLAN
116
.000
.00
CALL FORWARDING MINS
99
.250
24.75
215
24.75
5/30/03 Through 6/12/03 - AT&T DIGITAL ONE RATE $149.99
Category
Minutes
Rate
Charge
INCLUDED IN PLAN
718
.000
.00
CALL FORWARDING MINS
303
.250
75.75
1021
75.75
TOTAL HOME AIRTIME CHARGES
100.50
HOME LONG DISTANCE CHARGES
AT&T WIRELESS
16.45
TOTAL HOME LONG DISTANCE CHARGES
16.45
ROAMING CHARGES
ROAMING AIR
445.41
EFTA00014832

=== Page 12 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 14.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES (CONTINUED)
ROAMING LONG DISTANCE CHARGES
116.55
TOTAL ROAMING CHARGES
561.96
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
8.92
STATE TAX
11.86
LOCAL TAX
12.20
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
5.62
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
5.75
GROSS RECEIPTS SURCHARGE
9.68
TOTAL TAXES, SURCHARGES & REGULATORY FEES
55.53
TOTAL CURRENT MONTHLY CHARGES
892.42
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0001 5/13 1:03A F
NEW YORK
NY NY
1
.25
0002 5/13 11:00A
F
NEW YORK
NY NY
2
.50
0003 5/13 11:49A
F
NEW YORK
NY NY
1
.25
0004
5/13
12:31P
F
NEW YORK
NY NY
3
.75
0005
5/13
1:27P
INCOMING
1
0006
5/13
1:33P
INCOMING
1
0007
5/13
2:06P
INCOMING
1
0008
5/13
2:09P
UN. KINGDO
4
1.400
0009
5/13
3:41P
INCOMING
11
0010
5/13
3:53P
INCOMING
2
0011
5/13
3:56P
RETRIEVAL
LOCAL
1
0012
5/13
6:17P
F
NEW YORK
NY NY
2
.50
0013
5/13
6:53P
F
NEW YORK
NY NY
1
.25
0014
5/13
7:23P
F
NEW YORK
NY NY
13
3.25
0015
5/13
7:49P
F
NEW YORK
NY NY
6
1.50
0016
5/13
8:30P
F
NEW YORK
NY NY
8
2.00
0017
5/13
8:47P
F
NEW YORK
NY NY
2
.50
0018
5/13 10:45P
F
NEW YORK
NY NY
39
9.75
0019
5/14 11:03A
F
NEW YORK
NY NY
1
.25
0020
5/14 11:09A
F
NEW YORK
NY NY
2
.50
0021
5/14
1:07P
F
NEW YORK
NY NY
1
.25
0022
5/14
1:09P
F
NEW YORK
NY NY
1
.25
0023
5/14
2:40P
INCOMING
2
0024
5/14
2:43P
INCOMING
3
0025
5/14
2:56P
INCOMING
2
0026
5/14
2:58P
LOCAL
1
0027
5/14
3:19P
MOBILE
NY
1
0028
5/14
3:20P
NEW YORK
NY
1
0029
5/14
3:26P
NWYRCYZN07
NY
2
0030
5/14
3:28P
NEW YORK
NY
2
0031
5/14
3:32P
MOBILE
NY
1
0032
5/14
3:33P
NEW YORK
NY
1
EFTA00014833

=== Page 13 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 15.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0033
5/14
3:35P
NEW YORK
NY
2
0034
5/14
3:37P
NEW YORK
NY
2
0035
5/14
3:42P
MOBILE
NY
2
0036
5/14
3:55P
INCOMING
1
0037
5/14
4:28P
INCOMING
2
0038
5/14
4:52P
INCOMING
1
0039
5/14
5:48P
INCOMING
4
0040
5/14
6:08P
RETRIEVAL
LOCAL
1
0041
5/14
8:51P F
NEW YORK
NY NY
2
.50
0042
5/14
10:06P
F
NEW YORK
NY NY
2
.50
0043
5/14
10:56P
INCOMING
1
0044
5/14
10:56P
W PALM BCH FL
1
0045
5/14 10:56P
W PALM BCH FL
8
0046
5/15 12:20A
NEW YORK
NY
1
0047
5/15
4:36P
INCOMING
8
0048
5/15
4:43P
INCOMING
1
0049
/15
4:44P
INCOMING
3
0050
5/15
5:42P
INCOMING
1
0051
5/15
7:11P
INCOMING
2
0052
/15
7:12P W
INCOMING
1
0053
5/15
7:13P
MOBILE
NY
2
0054
/15
7:15P
MOBILE
NY
1
0055
/15
7:24P
RETRIEVAL
LOCAL
2
0056
/15
7:26P
MOBILE
NY
1
0057
5/15
7:41P
INCOMING
1
0058
5/15
7:43P
INCOMING
1
0059
/15
7:59P
INCOMING
1
0060
5/15
8:51P
MIAMI
FL
1
0061
5/15
8:55P
MOBILE
NY
2
0062
5/15
8:59P
INCOMING
12
0063
/15
9:01P W
INCOMING
1
0064
5/15
9:10P
INCOMING
2
0065
5/15
9:14P
NEW YORK
NY
1
0066
5/15
10:01P
INCOMING
5
0067
5/15
10:05P
NEW YORK
NY
2
0068
5/15
10:36P
INCOMING
1
0069
5/15
10:48P
MOBILE
NY
1
0070
5/16
10:22A
F
NEW YORK
NY
NY
1
0071
5/16
11:23A
F
NEW YORK
NY NY
1
0072
5/16
11:25A
F
NEW YORK
NY NY
2
.50
0073
5/16
12:06P
F
NEW YORK
NY NY
1
.25
0074
5/16
12:36P
F
NEW YORK
NY NY
1
.25
0075
5/16
1:01P F
NEW YORK
NY
NY
2
.50
0076
5/16
1:48P
F
NEW YORK
NY
NY
4
1.00
0077
5/20
1:26P
134/INCOMNG
LDSPAIN
NY
3.150
0078
5/27
2:36P
144/INCOMNG
LDUN.
KINGDO
NY
.350
0079
5/28
10:48A
144/INCOMNG
LDUN.
KINGDO
NY
5.250
0080
5/29
5:52A
144/INCOMNG
LDUN.
KINGDO
NY
4.550
0081
5/29
9:46A
144/INCOMNG
LDUN.
KINGDO
NY
.700
0082
5/29
1:01P
144/INCOMNG
LDUN. KINGDO
NY
.350
0083
5/30
12:54P
INCOMING
1
0084
5/30
1:06P
RETRIEVAL
LOCAL
1
0085
/30
1:07P
RETRIEVAL
LOCAL
2
0086
/30
1:08P
RETRIEVAL
LOCAL
1
0087
/30
2:42P
INCOMING
10
0088
/30
3:47P
RETRIEVAL
LOCAL
1
0089
130
3:55P
INCOMING
8
0090
5/30
4:03P
MIAMI
FL
1
0091
5/30
4:08P
INCOMING
3
0092
5/30
4:26P
NEW YORK
NY
1
EFTA00014834

=== Page 14 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 16.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0093
5/30
4:33P
NEW YORK
NY
1
0094
5/30
4:38P
INCOMING
1
0095
5/30
4:47P
RETRIEVAL
LOCAL
1
0096
5/30
4:58P
RETRIEVAL
LOCAL
1
0097
5/30
4:58P
INCOMING
1
0098
/30
4:59P
WRETRIEVAL
LOCAL
1
0099
/30
4:59P
NEW YORK
NY
3
0100
/30
5:02P
NEW YORK
NY
1
0101
/30
5:03P
NEW YORK
NY
5
0102
130
:07P
NEW YORK
NY
6
0103
/30
5:45P
NEW YORK
NY
1
0104
/30
:47P
NEW YORK
NY
2
0105
/30
:49P
NEW YORK
NY
1
0106
/30
6
:44P
INCOMING
4
0107
/30
6:49P
INCOMING
1
0108
/30
6:51P
INCOMING
1
0109
/30
6:59P
RETRIEVAL
LOCAL
2
0110
/30
7:08P
INCOMING
1
0111
/30
7:09P
INCOMING
3
0112
/30
7:09P
INCOMING
2
0113
130
9:36P
NEW YORK
NY
1
0114
/30
9:36P
NEW YORK
NY
1
0115
/30
10:10P
NEW YORK
NY
3
0116
/30
10:14P
NEW YORK
NY
1
0117
/31 12:27A
NEW YORK
NY
1
0118
5/31 10 23A F
NEW YORK
NY NY
3
.75
0119
5/31
11:34A
INCOMING
3
0120
5/31
11:37A
RETRIEVAL
LOCAL
1
0121
5/31
11:39A
NEW YORK
NY
1
0122
5/31
11:39A
NEW YORK
NY
1
0123
5/31
11:40A
NEW YORK
NY
1
0124
5/31
11:47A
INCOMING
1
0125
5/31
:04P
INCOMING
1
0126
5/31
3:06P
NEW YORK
NY
1
0127
5/31
3:09P
RETRIEVAL
LOCAL
1
0128
5/31
3:21P
INCOMING
9
0129
5/31
3:22P
INCOMING
1
0130
5/31
3:33P
INCOMING
1
0131
5/31
5:36P
RETRIEVAL
LOCAL
1
0132
/31
6:22P
INCOMING
1
0133
5/31
6:45P
NEW YORK
NY
1
0134
5/31
6:49P
MIAMI
FL
1
0135
5/31
6:53P
INCOMING
3
0136
5/31
8:03P
NEW YORK
NY
1
0137
5/31
9:03P
INCOMING
1
0138
5/31
9:04P
NEW YORK
NY
1
0139
5/31
9:17P
INCOMING
1
0140
5/31
9:27P
NEW YORK
NY
1
0141
6/01
9:07A
NEW YORK
NY
NY
14
3.50
0142
6/01
9:28A
F
NEW YORK
NY NY
2
.50
0143
6/01
9
42A
F
NEW YORK
NY NY
3
.75
0144
6/01
10
06A
F
NEW YORK
NY
NY
2
.50
0145
6/01 10:22A
F
NEW YORK
NY
NY
6
1.50
0146
6/01
11:42A
F
NEW YORK
NY NY
2
.50
0147
6/01
11:45A F
NEW YORK
NY
NY
1
0148
6/01
:37P
F
NEW YORK
NY
NY
1
0149
6/01
2:25P
NEW YORK
NY
NY
2
0150
6/01
2:29P
F
NEW YORK
NY
NY
3
0151
6/01
2:32P
MIAMI
FL
1
0152
6/01
3:04P
MOBILE
NY
2
EFTA00014835

=== Page 15 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 17.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0153
6/01
4:05P
NEW YORK
NY
1
0154
6/01
4:24P
NEW YORK
NY
1
0155
6/01
4:26P
NEW YORK
NY
1
0156
6/01
4:37P
INCOMING
3
0157
6/01
4:59P
NEW YORK
NY
2
0158
6/01
5:01P
NEW YORK
NY
1
0159
6/01
5:18P
INCOMING
2
0160
6/01
5:56P
INCOMING
4
0161
6/01
6:08P
INCOMING
1
0162
6/01
6:35P
INCOMING
35
0163
6/01
7:10P
NEW YORK
NY
2
0164
6/01
7:17P
NEW YORK
NY
5
0165
6/01
7:52P
MIAMI
FL
1
0166
6/01
9:57P
NEW YORK
NY NY
16
4.00
0167
6/02
6:21A
NEW YORK
NY NY
1
.25
0168
6/02
9:23A
E F
MOBILE
NY
1
0169
6/02
9:41A
NEW YORK
NY
NY
4
1.00
0170
6/02
11:30A
BETHESDA
DC
6
0171
6/02
11:49A
NEW YORK
NY
4
0172
6/02
12:04P
NEW YORK
NY
1
0173
6/02
12:05P
NEW YORK
NY
4
0174
6/02
12:08P
RETRIEVAL
LOCAL
1
0175
6/02
12:09P
MIAMI
FL
1
0176
6/02
12:57P
INCOMING
2
0177
6/02
12:59P
BETHESDA
DC
1
0178
6/02
12:59P
BETHESDA
DC
1
0179
6/02
1:01P
RETRIEVAL
LOCAL
1
0180
6/02
1:02P
NEW YORK
NY
2
0181
6/02
1:22P
INCOMING
2
0182
6/02
1:35P
INCOMING
2
0183
6/02
2:17P
INCOMING
6
0184
6/02
3:19P
INCOMING
1
0185
6/02
3:19P
INCOMING
8
0186
6/02
3:37P
RETRIEVAL
LOCAL
1
0187
6/02
3:39P
NEW YORK
NY
5
0188
6/02
3:43P
NEW YORK
NY
1
0189
6/02
4:32P
RETRIEVAL
LOCAL
1
0190
6/02
4:34P
BETHESDA
DC
1
0191
6/02
4:35P
MIAMI
FL
5
0192
6/02
4:37P
INCOMING
1
0193
6/02
4:38P
INCOMING
1
0194
6/02
4:38P
INCOMING
1
0195
6/02
4:40P
RETRIEVAL
LOCAL
1
0196
6/02
4:44P
INCOMING
2
0197
6/02
4:45P
NEW YORK
NY
5
0198
6/02
5:09P
NEW YORK
NY
3
0199
6/02
5:11P
INCOMING
1
0200
6/02
5:11P
W PALM BCH FL
3
0201
6/02
5:12P
INCOMING
1
0202
6/02
9:05P
F
NEW YORK
NY
NY
3
.75
0203
6/02
10:26P
F
NEW YORK
NY NY
5
1.25
0204
6/02 10:32P
F
NEW YORK
NY NY
2
.50
0205
6/02
11:04P
F
NEW YORK
NY NY
.25
0206
6/03
9:53A
F
NEW YORK
NY NY
2
.50
0207
6/03
9:55A
F
NEW YORK
NY NY
3
.75
0208
6/03
11:28A
F
NEW YORK
NY NY
1
.25
0209
6/03
12:15P
F
NEW YORK
NY NY
4
1.00
0210
6/03
12:18P
F
NEW YORK
NY NY
8
2.00
0211
6/03
12:35P
NEW YORK
NY NY
1
0212
6/03
12:50P
F212
NEW YORK
NY NY
1
.25
EFTA00014836

=== Page 16 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 18.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0213
6/03 12:56P F
NEW YORK
NY NY
1
.25
0214
6/03
12:56P
F
NEW YORK
NY NY
1
0215
6/03
1:15P F
NEW YORK
NY NY
1
.25
0216
6/03
2:09P
F
NEW YORK
NY NY
1
0217
6/03
2:17P
F
NEW YORK
NY NY
1
0218
6/03
4:06P
RETRIEVAL
LOCAL
1
0219
6/03
4:53P
RETRIEVAL
LOCAL
1
0220
6/03
4:55P
EVAL
LOCAL
1
0221
6/03
4:56P
NEW YORK
NY
1
0222
6/03
4:56P
NEW YORK
NY
1
0223
6/03
4:57P
RETRIEVAL
LOCAL
1
0224
6/03
5:09P
INCOMING
1
0225
6/03
5:33P
INCOMING
3
0226
6/03
5:45P
BETHESDA
DC
4
0227
6/03
6:04P
INCOMING
1
0228
6/03
8:17P
INCOMING
1
0229
6/03
8:28P
INCOMING
1
0230
6/03
11:33P
NEW YORK
NY
1
0231
6/03
11:35P
NEW YORK
NY
1
0232
6/04
10:20A
INCOMING
2
0233
6/04
12:14P
RETRIEVAL
LOCAL
2
0234
6/04
12:16P
NEW YORK
NY
2
0235
6/04
12:18P
INCOMING
1
0236
6/04
12:19P
NEW YORK
NY
2
0237
6/04
12:22P
INCOMING
1
0238
6/04
12:22P
INCOMING
2
0239
6/04
12:25P
NEW YORK
NY
9
0240
6/04
12:27P
INCOMING
1
0241
6/04
12:34P
NEW YORK
NY
4
0242
6/04
12:37P
INCOMING
6
0243
6/04
12:43P
NEW YORK
NY
2
0244
6/04
1:37P
NEW YORK
NY
4
0245
6/04
2:01P
RETRIEVAL
LOCAL
2
0246
6/04
2:02P
NEW YORK
NY
2
0247
6/04
2:04P
NEW YORK
NY
2
0248
6/04
2:05P
NEW YORK
NY
3
0249
6/04
2:07P
NEW YORK
NY
1
0250
6/04
2:08P
NEW YORK
NY
5
0251
6/04
2:13P
NEW YORK
NY
3
0252
6/04
2:16P
MOBILE
NY
1
0253
6/04
2:17P
RETRIEVAL
LOCAL
1
0254
6/04
2:19P
NEW YORK
NY
1
0255
6/04
2:42P
NEW YORK
NY
4
0256
6/04
2:47P
INCOMING
3
0257
6/04
2:49P
NEW YORK
NY
1
0258
6/04
2:50P
NEW YORK
NY
2
0259
6/04
2:55P
MOBILE
NY
1
0260
6/04
3:04P
MOBILE
NY
1
0261
6/04
3:35P
INCOMING
3
0262
6/04
4:21P
NEW YORK
NY
2
0263
6/04
5:18P
INCOMING
1
0264
6/04
5:23P
NEW YORK
NY
5
0265
6/04
5:39P
NEW YORK
NY
1
0266
6/04
5:54P
INCOMING
7
0267
6/04
5:55P
INCOMING
1
0268
6/04
6:29P
F
NEW YORK
NY NY
8
2.00
0269
6/04
6:42P
F
NEW YORK
NY NY
4
1.00
0270
6/04
7:02P
F
NEW YORK
NY NY
1
.25
0271
6/04
7:03P
NEW YORK
NY NY
2
.50
0272
6/04
7:04P
F
NEW YORK
NY NY
3
.75
*
EFTA00014837

=== Page 17 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 19.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0273
6/04
7:49P F
NEW YORK
NY NY
4
1.00
0274
6/04
8:08P
F
NEW YORK
NY NY
2
.50
0275
6/04
8:51P
F1
NEW YORK
NY NY
1
.25
0276
6/04
9:01P
F
NEW YORK
NY NY
5
1.25
0277
6/04
9:04P
F2
NEW YORK
NY NY
1
.25
0278
6/04
9:04P
F
NEW YORK
NY NY
1
.25
0279
6/04
9:05P
NEW *YORK
NY
1
0280
6/05
12:01A
RETRIEVAL
LOCAL
1
0281
6/05
9:03A
NEW YORK
NY NY
2
.50
0282
6/05
9:49A
NEW YORK
NY NY
8
2.00
0283
6/05
10:43A
NEW YORK
NY NY
31
7.75
0284
6/05
12:35P
INCOMING
2
0285
6/05
1:12P
INCOMING
4
0286
6/05
1:41P
INCOMING
2
0287
6/05
2:20P
INCOMING
4
0288
6/05
3:11P
INCOMING
12
0289
6/05
4:32P
RETRIEVAL
LOCAL
1
0290
6/05
4:58P
INCOMING
2
0291
6/05
5:16P
NEW YORK
NY
2
0292
6/05
5:24P
INCOMING
1
0293
6/05
5:25P
INCOMING
3
0294
6/05
6:37P
INCOMING
5
0295
6/05
6:45P
NEW YORK
NY
1
0296
6/05
6:46P
MOBILE
NY
8
0297
6/05
6:50P
INCOMING
8
0298
6/05
8:16P
F
NEW YORK
NY NY
2
.50
0299
6/05
8:18P
F
NEW YORK
NY NY
5
1.25
0300
6/05
8:24P
F
NEW YORK
NY
NY
1
.25
0301
6/05
8:36P
BETHESDA
DC
1
0302
6/05
9:05P
INCOMING
1
0303
6/05
9:16P
NEW YORK
NY
1
0304
6/05
11:15P
NEW YORK
NY
1
0305
6/06
8:47A
INCOMING
1
0306
6/06
8:55A
UN. KINGDO
2
.700
0307
6/06
9:01A
NEW YORK
NY
4
0308
6/06
10:41A
NEW YORK
NY
4
0309
6/06
10:45A
NEW YORK
NY
1
0310
6/06
10:49A
NEW YORK
NY
1
0311
6/06
10:50A
NEW YORK
NY
2
0312
6/06
10:52A
NEW YORK
NY
1
0313
6/06
11:24A
RETRIEVAL
LOCAL
1
0314
6/06
11:29A
INCOMING
11
0315
6/06
11:47A
RETRIEVAL
LOCAL
1
0316
6/06
11:52A
RETRIEVAL
LOCAL
1
0317
6/06
12:06P
INCOMING
9
0318
6/06
12:07P
INCOMING
1
0319
6/06
12:21P
INCOMING
1
0320
6/06
1:48P
INCOMING
4
0321
6/06
1:52P
NEW YORK
NY
1
0322
6/06
1:54P
NEW YORK
NY
1
0323
6/06
1:57P
NEW YORK
NY
1
0324
6/06
2:04P
INCOMING
3
0325
6/06
2:08P
INCOMING
2
0326
6/06
2:09P
SANTA FE
NM
1
0327
6/06
2:38P
INCOMING
3
0328
6/06
3:00P
INCOMING
4
0329
6/06
3:15P
INCOMING
1
0330
6/06
3:49P
NEW YORK
NY NY
1
.25
0331
6/06
3:56P
NEW YORK
NY NY
1
0332
6/06
4:09P
NEW YORK
NY NY
1
EFTA00014838

=== Page 18 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 20.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0333
6/06
4:19P
F
NEW YORK
NY NY
1
.25
0334
6/06
4:42P
NEW YORK
NY
1
0335
6/06
4:55P
INCOMING
1
0336
6/06
5:09P
INCOMING
2
0337
6/06
5:41P
INCOMING
3
0338
6/06
5:41P
INCOMING
1
0339
6/06
5:44P
NEW YORK
NY
1
0340
6/06
6:22P
RETRIEVAL
LOCAL
1
0341
6/06
6:24P
INCOMING
11
0342
6/06
6:37P
RETRIEVAL
LOCAL
1
0343
6/06
7:39P
MOBILE
NY
4
0344
6/06
7:44P
INCOMING
2
0345
6/06
7:49P
W PALM BCH FL
8
0346
6/06
11:11P
RETRIEVAL
LOCAL
1
0347
6/07
10:09A
F
NEW YORK
8
0348
6/07
MA
NY NY
2.00
10:19A
F2
NEW YORK
NY NY
2
.50
0349
6/07
11:09A
INCOMING
1
0350
6/07
11:35A
MOBILE
NY
2
0351
6/07
11:37A
MOBILE
NY
1
0352
6/07
11:44A
MOBILE
NY
1
0353
6/07
11:52A
MOBILE
NY
0354
6/07
11:54A
MOBILE
NY
1
0355
6/07
11:56A
RETRIEVAL
LOCAL
1
0356
6/07
11:56A
NEW YORK
NY
1
0357
6/07
12:37P
INCOMING
1
0358
6/07
12:39P
INCOMING
1
0359
6/07
3:30P
RETRIEVAL
LOCAL
1
0360
6/07
5:48P
PRTRI
EVAL
LOCAL
1
0361
6/07
5:49P
MOBILE
NY
2
0362
6/07
5:52P
MOBILE
NY
2
0363
6/07
5:53P
MOBILE
NY
2
0364
6/07
8:25P
MOBILE
NY
1
0365
6/07
8:27P
STATEN IS
NY
1
0366
6/07
8:28P
NORTHSALEM
NY
2
0367
6/07
8:30P
NEW YORK
NY
2
0368
6/07
8:32P
MIAMI
FL
1
0369
6/07
8:33P
MOBILE
NY
9
0370
6/07
8:37P
INCOMING
1
0371
6/07
8:45P
BETHESDA
DC
1
0372
6/07
10:28P
MIAMI
FL
1
0373
6/07
10:29P
NEW YORK
NY
1
0374
6/07
10:34P
NEW YORK
NY
1
0375
6/07
10:35P
NEW YORK
NY
1
0376
6/07
11:41P
917/INCOMNG
LDNEW YORK
NY NY
0377
6/07
11:43P
INCOMING
1
0378
6/08
12:08P
NEW YORK
NY
NY
1
.25
0379
6/08
2:11P
NEW YORK
NY NY
28
7.00
0380
6/08
3:27P
NEW YORK
NY NY
1
.25
0381
6/08
5:09P
NEW YORK
NY NY
2
.50
0382
6/08
5:54P
INCOMING
3
0383
6/08
9:45P
F F2 F F1 F F2 F1
NEW YORK
NY
NY
1
.25
0384
6/08
9:47P
NEW YORK
NY NY
2
.50
0385
6/08
9:48P
NEW YORK
NY NY
5
1.25
0386
6/09
9:54A
NEW YORK
NY NY
8
2.00
0387
6/09
10:58A
INCOMING
2
0388
6/09
12:38P
RETRIEVAL
LOCAL
1
0389
6/09
12:39P
NEW YORK
NY
5
0390
6/09
12:47P
INCOMING
4
0391
6/09
1:27P
E
NEW YORK
NY NY
1
.25
0392
6/09
1:27P
NEW YORK
NY NY
1
.25
EFTA00014839

=== Page 19 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 21.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0393
6/09
1:30P F
NEW YORK
NY NY
1
.25
0394
6/09
2:59P
F
NEW YORK
NY NY
1
.25
0395
6/09
5:15P
F
NEW YORK
NY NY
3
.75
0396
6/09
5:43P
F
NEW YORK
NY NY
6
1.50
0397
6/09
6:04P
NEW YORK
NY
1
0398
6/09
6:07P
6:15P
Date
F
NEW YORK
NY NY
11
2.75
0399
6/09
F
NEW YORK
NY NY
10
2.50
0400
6/09
6:41P
MIAMI
FL
1
0401
6/09
6:42P A
MIAMI
FL
1
0402
6/09
6:55P
NEW YORK
NY
1
0403
6/09
7:47P
NEW YORK
NY
1
0404
6/09
8:47P
RETRIEVAL
LOCAL
1
0405
6/10
6:32A
NEW YORK
NY NY
1
.25
0406
6/10
8:53A
0407
6/10
10:55A
F F F F
NEW YORK
NY NY
1
.25
NEW YORK
NY NY
1
.25
0408
6/10
11:35A
NEW YORK
NY NY
15
3.75
0409
6/10
12:47P
INCOMING
1
0410
6/10
12:49P
NEW YORK
NY
2
0411
6/10
1:10P
RETRIEVAL
LOCAL
1
0412
6/10
1:11P
NEW YORK
NY
2
0413
6/10
1:12P
MOBILE
NY
1
0414
6/10
1:13P
S
W PALM BCH FL
1
0415
6/10
1:46P
INCOMING
2
0416
6/10
1:48P
NEW YORK
NY
2
0417
6/10
2:14P
INCOMING
1
0418
6/10
2:25P
INCOMING
1
0419
6/10
2:38P
INCOMING
1
0420
6/10
2:38P
INCOMING
1
0421
6/10
2:43P
INCOMING
2
0422
6/10
2:45P
NEW YORK
NY
1
0423
6/10
2:46P
INCOMING
1
0424
6/10
2:54P
INCOMING
2
0425
6/10
3:01P
INCOMING
1
0426
6/10
3:20P
INCOMING
1
0427
6/10
4:13P
MOBILE
NY
1
0428
6/10
4:37P
INCOMING
1
0429
6/10
4:51P
NEW YORK
NY
3
0430
6/10
6:10P
NEW YORK
NY
1
0431
6/10
6:40P
INCOMING
1
0432
6/10
8:34P
INCOMING
1
0433
6/10
8:38P
NEW YORK
NY
1
0434
6/10
10:58P
NEW YORK
NY
1
0435
6/10
11:56P
INCOMING
4
0436
6/11
12:01A
INCOMING
3
0437
6/11
10:06A
INCOMING
2
0438
6/11
10:30A
INCOMING
3
0439
6/11
10:57A
INCOMING
2
0440
6/11
11:24A
INCOMING
2
0441
6/11
11:49A
INCOMING
2
0442
6/11
11:51A
BETHESDA
DC
5
0443
6/11
12:03P
NEW YORK
NY
2
0444
6/11
12:36P
LDNEW YORK
NY NY
0445
6/11
12:37P
INCOMING
9
0446
6/11
12:46P
NEW YORK
NY
2
0447
6/11
12:47P
NEW YORK
NY
1
0448
6/11
12:56P
LDNEW YORK
NY NY
0449
6/11
12:57P
INCOMING
3
0450
6/11
12:58P
LDNEW YORK
NY NY
0451
6/11
12:59P
INCOMING
13
0452
6/11
1:45P
LDNEW YORK
NY NY
EFTA00014840

=== Page 20 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 22.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0453
6/11
1:47P
INCOMING
1
0454
6/11
1:48P
NEW YORK
NY
1
0455
6/11
3:53P
INCOMING
1
0456
6/11
3:54P
INCOMING
7
0457
6/11
4:21P
NEW YORK
NY
1
0458
6/11
4:22P
NEW YORK
NY
1
0459
6/11
4:29P
INCOMING
1
0460
6/11
5:49P
NEW YORK
NY
1
0461
6/11
5:49P
NEW YORK
NY
1
0462
6/11
5:53P
NEW YORK
NY
3
0463
6/11
5:58P
INCOMING
2
0464
6/11
6:00P
NEW YORK
NY
2
0465
6/11
7:32P
NEW YORK
NY
1
0466
6/11
7:33P
NEW YORK
NY
2
0467
6/11
8:06P
NEW YORK
NY NY
1
.25
0468
6/11
9:06P
F F F F F F F
MIAMI
FL
1
0469
6/12
9:29A
NEW YORK
NY NY
1
.25
0470
6/12
10:16A
NEW YORK
NY NY
3
.75
0471
6/12
12:26P
NEW YORK
NY NY
1
.25
0472
6/12
12:34P
NEW YORK
NY NY
2
.50
0473
6/12
1:08P
NEW YORK
NY NY
2
.50
0474
6/12
1:18P
NEW YORK
NY NY
2
.50
0475
6/12
2:07P
NEW YORK
NY
2
0476
6/12
2:40P
INCOMING
3
0477
6/12
4:02P
INCOMING
1
0478
6/12
5:47P
INCOMING
1
0479
6/12
5:47P
INCOMING
3
0480
6/12
6:27P
INCOMING
3
0481
6/12
7:11P
INCOMING
1
0482
6/12
7:18P
INCOMING
3
0483
6/12
8:27P
INCOMING
1
0484 6/12 8:28P
BETHESDA
DC
1
0485
6/12
8:29P
INCOMING
1
0486 6/12 8:38P
BETHESDA
DC
1
0487
6/12
9:24P
NEW YORK
NY
1
0488
6/12
9:34P
NEW YORK
NY
1
0489 6/12 11:30P RETRIEVAL
LOCAL
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
1236
100.50
16.45
CALL CHARACTERISTICS:
F = Call Forwarding, W = Call Waiting,
A = Automatic Dropped Call Credit
S = Long Distance Service Billed Separately
"CALLS FROM" KEY:
NY = NEW YORK
ROAMING CHARGES
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
Calls Made From: ITALY
0001
5/19
2:17P
INTL NTWK
1
.99
.35
0002
5/19
2:19P
INTL NTWK
3
2.97
1.05
0003 5/19 2:22P
INTL NTWK
7
6.93
2.45
EFTA00014841

=== Page 21 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 23.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0004
5/19
2:40P
INTL NTWK
1
.99
.35
0005
5/19
2:52P
INTL NTWK
1
.99
0006
/19
3:01P
INTL NTWK
1
.99
0007
19
3:05P
INTL NTWK
1
.99
.35
0008
19
3:08P
INTL NTWK
2
1.98
.70
0009
19
3:16P
INTL NTWK
1
.99
.35
0010
19
3:32P
INTL NTWK
2
1.98
0011
19
3:36P
INTL NTWK
2
1.98
.70
0012
19
4:02P
INTL NTWK
3
2.97
1.05
0013
19
4:05P
INTL NTWK
1
.99
.35
0014
5/19
4:34P
INTL NTWK
1
.99
0015
5/19
4:35P
INTL NTWK
1
.99
.35
Subtotal for
: ITALY,
28
27.72
9.80
.00
Calls Made From: FRANCE,
0016
5/16
2:34P
INTL NTWK
1
99
0017
16
36P
INTL NTWK
1
.99
0018
16
4:50P
INTL NTWK
1
.99
.35
0019
16
6
INTL NTWK
6
5.94
2.10
0020
16
6
INTL NTWK
1
.99
.35
0021
16
6
:22P
INTL NTWK
3
2.97
1.05
0022
16
6:35P
INTL NTWK
1
.99
.35
0023
16
7:08P
INTL NTWK
2
1.98
.70
0024
16
9
INTL NTWK
2
1.98
.70
0025
16
9
:25P
INTL NTWK
3
2.97
1.05
0026
16
9
:27P
INTL NTWK
5
4.95
1.75
0027
17
12:01A
INTL NTWK
.99
.35
0028
17
5:22P
INTL NTWK
.99
0029
17
22P
INTL NTWK
2
1.98
.70
0030
17
:12P
INTL NTWK
1
.99
.35
0031
17
:13P
INTL NTWK
.99
.35
0032
17
6:14P
INTL NTWK
4
3.96
1.40
0033
17
6:49P
INTL NTWK
1
.99
.35
0034
17
8:38P
INTL NTWK
1
.99
.35
0035
17
INTL NTWK
.99
0036
17
INTL NTWK
.99
0037
18
2:13P
INTL NTWK
.99
0038
22
4:04P
INTL NTWK
.99
0039
22
4:32P
INTL NTWK
.99
0040
4:33P
INTL NTWK
1
.99
.35
0041
4:46P
INTL NTWK
4
3.96
1.40
0042
4:56P
INTL NTWK
2
1.98
.70
0043
4:59P
INTL NTWK
1
.99
.35
0044
9:11P
INTL NTWK
3
2.97
1.05
0045
10:25P
INTL NTWK
13
12.87
4.55
0046
INTL NTWK
1
.99
0047
10:57P
INTL NTWK
4
3.96
1.40
0048
1
INTL NTWK
1
.99
0049
INTL NTWK
1
.99
.35
0050
:49A
INTL NTWK
1
.99
.35
0051
L0A
INTL NTWK
1
.99
.35
0052
1A
INTL NTWK
1
.99
0053
4A
INTL NTWK
1
.99
0054
10A
INTL NTWK
4
3.96
1.40
0055
30P
INTL NTWK
1
.99
0056
INTL NTWK
29
28.71
10.15
0057
8
45P
INTL NTWK
1
.99
.35
EFTA00014842

=== Page 22 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 24.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF
DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0058 5/25 8:46P
INTL NTWK
3
2.97
1.05
0059
5/25
9:35P
INTL NTWK
1
.99
.35
0060 5/25 9:36P
INTL NTWK
1
.99
.35
Subtotal for
: FRANCE,
118
116.82
41.30
.00
Calls Made From: FRANCE,
0061
5/23
12:00A
CALL SVC
1
0062
5/23
4:47P
INTL NTWK
1
0063
23
5:18P
INTL NTWK
1
0064
/23
5:19P
INTL NTWK
1
0065
/23
5:21P
INTL NTWK
9
8.91
0066
23
7:01P
INTL NTWK
1
0067
23
10:59P
INTL NTWK
1
9
0068
24 12:00A
CALL SVC
1
9
0069
24
3:40A
INTL NTWK
2
1
0070
24
4:44A
INTL NTWK
1
0071
5/24
1:32P
INTL NTWK
1
0072
24
2:00P
INTL NTWK
1
0073
24
2:03P
INTL NTWK
1
0074
24
5:07P
INTL NTWK
9
0075
24
5:57P
INTL NTWK
0076
/24
10:33P
INTL NTWK
2
1
0077
24
11:00P
INTL NTWK
1
9
0078
25 12:00A
CALL SVC
1
0079
25
4:17A
INTL NTWK
1
0080
25
4:18A
INTL NTWK
5
4
0081
12:36P
INTL NTWK
1
0082
12:37P
INTL NTWK
1
0083
12:38P
INTL NTWK
4
3
0084
1:47P
INTL NTWK
1
0085
3:28P
INTL NTWK
1
9
0086
3:31P
INTL NTWK
1
9
0087
4:58P
INTL NTWK
1
9
0088
5:00P
INTL NTWK
1
9
0089
5:18P
INTL NTWK
1
0090
:21P
INTL NTWK
5
4
1
0091
:27P
INTL NTWK
1
0092
5:28P
INTL NTWK
1
1.75 3.15 1.40 1.40 .35 1 mmm-imm
0093
5:30P
INTL NTWK
1
0094
6:00P
INTL NTWK
1
9
0095
6:01P
INTL NTWK
2
1
8
0096
6:03P
INTL NTWK
1
9
0097
6:24P
INTL NTWK
1
9
0098
25P
INTL NTWK
1
9
0099
6:27P
INTL NTWK
4
3
0100
6:37P
INTL NTWK
1
99
0101
12:00A
CALL SVC
1
9
0102
12:25A
INTL NTWK
9
0103
11:44A
INTL NTWK
2
1.98
.35 .70
Subtotal for
: FRANCE,
69
68.31
22.75
.00
Calls Made From: ITALY,
0104
5/18
4:37P
INTL NTWK
1
.35
0105
5/18
4:44P
INTL NTWK
0106
7:41P
INTL NTWK
PWWPP
1
5/18
6:06P
INTL NTWK
3
2.97
0107
5/18
3
66666
.35
1.05
1.05
0108 5/18 8:47P
INTL NTWK
1
.99
.35
EFTA00014843

=== Page 23 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 25.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF
DATE
TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0109
5/18
9:00P
INTL NTWK
1
.99
.35
0110
5/18
9:31P
INTL NTWK
1
.99
.35
0111
18
11:16P
INTL NTWK
2
1.98
0112
19
12:05A
INTL NTWK
.99
.35
0113
19
12:06A
INTL NTWK
2
1.98
.70
0114
19
1:00A
INTL NTWK
1
.99
0115
19
1:04A
INTL NTWK
.99
0116
19
8:22A
INTL NTWK
.99
0117
19
INTL NTWK
2
1.98
0118
19
4:38P
INTL NTWK
2
1.98
70
0119
19
4:40P
INTL NTWK
1
.99
0120
/19
4:52P
INTL NTWK
.99
.35
0121
/19
4:56P
INTL NTWK
.99
0122
19
5:25P
INTL NTWK
1
.99
0123
19
5:28P
INTL NTWK
5
4.95
1.75
0124
19
5:36P
INTL NTWK
7
6.93
2.45
0125
19
:58P
INTL NTWK
1
.99
.35
0126
19
:59P
INTL NTWK
WI
2.97
1.05
0127
19
:11P
INTL NTWK
1
.99
0128
19
INTL NTWK
1
.99
.35
0129
19
8:45P
INTL NTWK
.99
0130
19
8:48P
INTL NTWK
3
2.97
1.05
0131
/19
INTL NTWK
1
.99
.35
0132
19
INTL NTWK
.99
.35
0133
19
INTL NTWK
2
1.98
.70
0134
19
9:49P
INTL NTWK
1
.99
.35
0135
19
9:50P
INTL NTWK
3
2.97
1.05
0136
19
10:02P
INTL NTWK
1
.99
0137
19
10:19P
INTL NTWK
2
1.98
.70
0138
19
10:21P
INTL NTWK
4
3.96
1.40
0139
19
10:27P
INTL NTWK
5
4.95
1.75
0140
/19
10:48P
INTL NTWK
1
.99
.35
0141
/19
10:49P
INTL NTWK
.99
0142
6/19
11:27P
INTL NTWK
.99
.35
0143
19
INTL NTWK
.99
0144
19
11:48P
INTL NTWK
5
4.95
1.75
0145
19
11:53P
INTL NTWK
1
.99
.35
0146
19
:54P
INTL NTWK
.99
0147
/20
INTL NTWK
.99
0148
5/20
INTL NTWK
.99
0149
20
10:18A
INTL NTWK
3
2.97
1.05
0150
20
10:26A
INTL NTWK
1
.99
.3
0151
5/20
10:49A
INTL NTWK
1
.99
0152
5/20 10:56A
INTL NTWK
1
.99
35
Subtotal for : ITALY,
88
87.12
30.80
.00
Calls Made From: GREAT BRITAIN,
0153 5/26 7:29P
INTL NTWK
.35
0154 5/27 12:00A
CALL SVC
0155
5/27
4:50P
INTL NTWK
1
.99
.35
0156
5/27
5:43P
INTL NTWK
1
.99
.35
0157
27
7:13P
INTL NTWK
2
1.98
.70
0158
27
7:14P
INTL NTWK
2
1.98
.70
0159
/27
7:16P
INTL NTWK
1
.99
.35
0160
/27
7:16P
INTL NTWK
1
.99
.35
0161
27
8:19P
INTL NTWK
2
1.98
.70
0162
8
INTL NTWK
1
.99
.35
EFTA00014844

=== Page 24 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 26.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0163
5/27 10:05P
INTL NTWK
2
1.98
0164
5/27
10:13P
INTL NTWK
1
99
0165
5/27
10:30P
INTL NTWK
1
99
0166
/27
10:31P
INTL NTWK
1
99
0167
/28
10:14A
INTL NTWK
99
0168
5/28
12:47P
INTL NTWK
1
.99
0169
/28
1:44P
INTL NTWK
1
99
0170
5/28
2:48P
INTL NTWK
1
.99
0171
5/28
6:06P
INTL NTWK
1
.99
.70 0000000000
70 00000000000
0172
5/28
7:20P
INTL NTWK
1
.99
0173
/28
11:30P
INTL NTWK
1
.99
0174
/29
12:00A
CALL SVC
99
0175
/29
12:46P
INTL NTWK
1
.99
0176
5/29
4:08P
INTL NTWK
1
.99
0177
5/29
4:08P
INTL NTWK
1
.99
0178
5/29
4:09P
INTL NTWK
1
.99
0179
5/29
4:11P
INTL NTWK
1
.99
0180
5/29
4:12P
INTL NTWK
1
.99
0181 5/29 4:14P
INTL NTWK
2
1.98
0182 5/29 4:45P
INTL NTWK
2
1.98
Subtotal for
: GREAT BRITAIN,
36
35.64
11.90
.00
Calls Made From: SPAIN,
0183 5/20 12:00A
CALL SVC
1
.60
0184
5/20
4:05P
INTL NTWK
3
1.80
0185
5/20
4:09P
INTL NTWK
3
1.80
0186
5/20
4:14P
INTL NTWK
1
60
0187
/20
4:14P
INTL NTWK
1
.60
0188
/20
4:28P
INTL NTWK
60
0189
/20
4:51P
INTL NTWK
2
0190
20
4:53P
INTL NTWK
60
0191
/20
5:03P
INTL NTWK
2
0192
/20
5:06P
INTL NTWK
6
0193
5/20
5:11P
INTL NTWK
5
0194
5/20
5:17P
INTL NTWK
5
0195
5/20
5:58P
INTL NTWK
8
0196
/20
:10P
INTL NTWK
1
60
0197
5/20
6:12P
INTL NTWK
2
0198
5/20
6:21P
INTL NTWK
1
60
0199
/20
6:23P
INTL NTWK
2
0200
/20
6:25P
INTL NTWK
2
0201
20
6:33P
INTL NTWK
3
0202
5/20
6:37P
INTL NTWK
3
0203
/20
6:40P
INTL NTWK
6
0204
5/20
6:55P
INTL NTWK
5
0205
/20
7:01P
INTL NTWK
1
.60
0206
5/20
7:02P
INTL NTWK
9
0207
/20
7:10P
INTL NTWK
rimmme 4.80 3.00 3.60 3.00 determ 5.40 3.00 1.80 1.20 3.00 1.20 3.60 1.20 1.80 1.20 1.20 1.20 1.20 1.20 1.20
60
0208
5/20
7:11P
INTL NTWK
2
0209
5/20
7:13P
INTL NTWK
1
60
0210
20
7:14P
INTL NTWK
2
0211
5/20
7:17P
INTL NTWK
.60
0212
20
7:18P
INTL NTWK
2
0213
20
7:19P
INTL NTWK
5
0214
20
7:34P
INTL NTWK
2
0215
20
7:36P
INTL NTWK
1
0
0216
7:42P
INTL NTWK
.60
EFTA00014845

=== Page 25 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 27.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0217
5/20
8:52P
INTL NTWK
2
1.20
0218
8:53P
INTL NTWK
2
1.20
0219
INTL NTWK
2
1.20
0220
INTL NTWK
3
1.80
0221
INTL NTWK
60
0222
INTL NTWK
60
0223
INTL NTWK
60
0224
INTL NTWK
60
0225
INTL NTWK
5
0226
INTL NTWK
4
3:00
0227
INTL NTWK
60
0228
INTL NTWK
60
0229
INTL NTWK
2
1.20
0230
20
INTL NTWK
0231
INTL NTWK
60
0232
INTL NTWK
60
0233
CALL SVC
60
0234
06A
INTL NTWK
60
0235
07A
INTL NTWK
60
0236
INTL NTWK
60
0237
6A
INTL NTWK
60
0238
7A
INTL NTWK
60
0239
INTL NTWK
60
0240
6A
INTL NTWK
60
0241
0A
INTL NTWK
0
0242
INTL NTWK
0
0243
INTL NTWK
2
1.20
0244
54A
INTL NTWK
1
60
0245
5:07A
INTL NTWK
60
0246
1
:13A
INTL NTWK
2
0247
2:00P
INTL NTWK
6
0
0248
:02P
INTL NTWK
2
0
0249
:04P
INTL NTWK
19P
INTL NTWK
5
0251
24P
must HHH 4 3.00 1:20 3 1 1 1
60
0250
00
INTL NTWK
3
80
0252
3:04P
INTL NTWK
8
0
0253
:19P
INTL NTWK
60
0254
34P
INTL NTWK
0255
4:39P
INTL NTWK
60
0256
4:39P
INTL NTWK
0257
26P
INTL NTWK
0
0258
6
:52P
INTL NTWK
0
0259
INTL NTWK
0
0260
9
OP
INTL NTWK
0261
9:11P
INTL NTWK
0262
11:36P
INTL NTWK
0
0263
CALL SVC
60
0264
01A
INTL NTWK
60
0265
INTL NTWK
6
0
0266
:47A
INTL NTWK
0
0267
7A
INTL NTWK
0
0268
11:51A
INTL NTWK
0
EFTA00014846

=== Page 26 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE
NUMBER
BILL DATE PAGE 28.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0269 5/22 1:30P
INTL NTWK
1
.60
Subtotal for : SPAIN,
183
109.80
.00
.00
TOTAL ROAMING CHARGES
522
445.41
116.55
.00
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014847

=== Page 27 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 29.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
5/13/03 Through 6/12/03
MONTHLY SE - LOCAL PLAN $39.99
39.99
CALL FORWARDING
.00
THREE WAY CALLING
.00
CALL WAITING
.00
CALLER ID
.00
ENH DISCOUNT INTL DIAL
3.99
PCS VOICEMAIL W/NUMERIC MSG
.00
DETAIL BILLING
.00
AT&T 2-WAY TEXT MSG $0.00
.00
AT&T TOLL FREE NATIONWIDE
4.99
AT&T TOLL FREE CREDIT
4.99CR
REGULATORY PROGRAMS FEE
.88
TOTAL MONTHLY SERVICE CHARGES
44.86
HOME AIRTIME CHARGES
5/13/03 Through 6/12/03 - LOCAL PLAN $39.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
196
.000
.00
300 ADDITIONAL MINUTES
300
.000
.00
INCLUDED IN PLAN
353
.000
.00
849
.00
TOTAL HOME AIRTIME CHARGES
.00
MESSAGING, CONTENT & APPLICATION CHARGES
5/13/03 Through 6/12/03
Category
Messages
Rate
Charge
SENT MESSAGES
10
.10
1.00
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
1.00
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
1.49
STATE TAX
2.10
LOCAL TAX
2.16
EFTA00014848

=== Page 28 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER
BILL DATE PAGE 30.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES (CONTINUED)
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
.94
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
.96
GROSS RECEIPTS SURCHARGE
1.61
TOTAL TAXES, SURCHARGES & REGULATORY FEES
10.76
TOTAL CURRENT MONTHLY CHARGES
56.62
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0001 5/13 10:33A
NEW YORK
NY
1
0002
5/13 11:21A
INCOMING
1
0003
5/13 11:22A
LOCAL
2
0004
5/13
12:36P
NEW YORK
NY
1
0005
5/13
12:43P
INCOMING
1
0006
5/13
1:39P
NEW YORK
NY
1
0007
5/13
1:50P
NEW YORK
NY
1
0008
5/13
2:01P
INCOMING
0009
5/13
2:27P
BROOKLYN
NY
1
0010
5/13
2:28P
BROOKLYN
NY
1
0011
5/13
2:39P
INCOMING
1
0012
5/13
2:39P
BROOKLYN
NY
1
0013
5/13
2:44P
BROOKLYN
NY
2
0014
5/13
2:46P
NEW YORK
NY
1
0015
5/13
2:48P
INCOMING
1
0016
5/13
3:11P
INCOMING
1
0017
5/13
3:39P
BROOKLYN
NY
0018
5/13
3:40P
BROOKLYN
NY
2
0019
5/13
3:41P
NEW YORK
NY
1
0020
5/13
3:49P
INCOMING
5
0021
5/13
3:56P
NEW YORK
NY
1
0022
5/13
5:25P
NEW YORK
NY
1
0023
5/13
6:06P
NEW YORK
NY
2
0024
5/14
10:45A
INCOMING
2
0025
5/14
10:46A
W
INCOMING
1
0026
5/14 11:06A
INCOMING
1
0027
5/14 11:07A
NEW YORK
NY
1
0028
5/14
11:11A
BROOKLYN
NY
6
0029
5/14 12:20P
NEW YORK
NY
1
0030
5/14
12:40P
BROOKLYN
NY
1
0031
5/14
1:15P
INCOMING
1
0032
5/14
1:27P
BROOKLYN
NY
1
0033
5/14
1:27P
INCOMING
1
0034
5/14
1:56P
BROOKLYN
NY
1
0035
5/14
1:57P
BROOKLYN
NY
1
0036
5/14
2:09P
NEW YORK
NY
0037
5/14
2:13P
INCOMING
1
0038
5/14
2:28P
BROOKLYN
NY
6
0039
5/14
3:00P
INCOMING
1
0040
5/14
3:08P
NEW YORK
NY
2
0041
5/14
4:01P
NEW YORK
NY
1
0042
5/14
4:02P
INCOMING
1
0043 5/14 4:32P
INCOMING
1
0044
5/14
6:04P
INCOMING
1
EFTA00014849

=== Page 29 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 31.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0045
5/14
6:43P
INCOMING
1
0046
5/14
8:13P
BROOKLYN
NY
1
0047
5/14
8:16P
INCOMING
8
0048
15
12:07P
INCOMING
1
0049
15
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JUN 14, 2003
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=== Page 31 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 33.0
JEFFREY E EPSTEIN &
JUN 14, 2003
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MIN
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0165
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1
0166
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0167
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0202
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0203
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NY
1
0204
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9
0205
10:41P
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0206
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0207
30
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0208
30
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0210
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0211
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30
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NEW YORK
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=== Page 32 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 34.0
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JUN 14, 2003
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0225
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0226
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0227
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0268
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0270
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0272
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NY
0273
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=== Page 33 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 35.0
JEFFREY E EPSTEIN &
JUN 14, 2003
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MIN
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DISTANCE
0285
6/02
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NY
1
0286
6/02
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2
0287
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0289
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0294
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0297
6/03
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0298
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0299
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0300
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NEW YORK
NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY NY
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=== Page 34 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 36.0
JEFFREY E EPSTEIN &
JUN 14, 2003
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MIN
AIR
DISTANCE
0345
6/05
11:36A
NEW YORK
NY
1
0346
6/05
11:38A
NEW YORK
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1
0347
6/05
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0348
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0349
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0393
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0397
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0398
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0401
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NEW YORK
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=== Page 35 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 37.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0405
6/06
7:21P
NEW YORK
NY
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6/06
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0409
6/06
10:04P
LOCAL
0410
6/06
10:05P
LOCAL
2
0411
6/07
12:10P
INCOMING
0412
6/07
1:05P
INCOMING
0413
6/07
1:08P
NEW YORK
NY
0414
6/07
1:16P
INCOMING
0415
6/07
1:37P
INCOMING
0416
6/07
4:22P
BROOKLYN
NY
0417
6/07
4:49P
NEW YORK
NY
2
0418
6/07
5:00P
INCOMING
0419
6/07
5:00P
NEW YORK
NY
0420
6/07
5:45P
NEW YORK
NY
0421
6/07
6:01P
INCOMING
0422
6/07
6:22P
NEW YORK
NY
0423
6/07
6:56P
BROOKLYN
NY
0424
6/07
7:52P
INCOMING
0425
6/07
8:50P
BROOKLYN
NY
0426
6/07
9:06P
INCOMING
0427
6/07
9:22P
NEW YORK
NY
0428
6/07
9:41P
NEW YORK
NY
0429
6/07
9:42P
NEW YORK
NY
0430
6/07
10:59P
INCOMING
0431
6/07
11:22P
NEW YORK
NY
0432
6/07
11:27P
NEW YORK
NY
0433
6/08
12:01P
INCOMING
2
0434
6/08
12:08P
NEW YORK
NY
0435
6/08
12:15P
QUEENS
NY
0436
6/08
12:16P
NEW YORK
NY
0437
6/08
1:50P
NEW YORK
NY
0438
6/08
6:21P
NEW YORK
NY
0439
6/09
10:40A
INCOMING
0440
6/09
10:44A
INCOMING
0441
6/09
11:01A
NEW YORK
NY
0442
6/09
11:03A
NEW YORK
NY
0443
6/09
11:09A
INCOMING
2
0444
6/09
11:11A
NEW YORK
NY
0445
6/09
12:28P
INCOMING
2
0446
6/09
12:34P
INCOMING
0447
6/09
12:39P
NEW YORK
NY
0448
6/09
12:51P
NEW YORK
NY
0449
6/09
6:16P
INCOMING
0450
6/09
6:38P
BROOKLYN
NY
0451
6/09
6:45P
NEW YORK
NY
0452
6/09
6:47P
NEW YORK
NY
3
0453
6/09
7:04P
NEW YORK
NY
0454
6/09
7:04P
NEW YORK
NY
0455
6/09
7:15P
INCOMING
0456
6/09
7:47P
INCOMING
0457
6/09
8:04P
NEW YORK
NY
6
0458
6/09
8:21P
NEW YORK
NY
0459
6/09
8:25P
NEW YORK
NY
0460
6/09
8:28P
NEW YORK
NY
0461
6/10
10:40A
BROOKLYN
NY
0462
6/10 11:01A
NEW YORK
NY
0463
6/10
1:34P
INCOMING
0464
6/10
1:47P
NEW YORK
NY
EFTA00014856

=== Page 36 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 38.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0465
6/10
2:19P
NEW YORK
NY
0466
6/10
2:29P
INCOMING
0467
6/10
3:11P
NEW YORK
NY
0468
6/10
3:15P
INCOMING
0469
6/10
3:28P
NEW YORK
NY
0470
6/10
3:45P
INCOMING
0471
6/10
7:31P
NEW YORK
NY
0472
6/10
7:57P
NEW YORK
NY
0473
6/10
7:59P
NEW YORK
NY
0474
6/10
8:18P
NEW YORK
NY
0475
6/10
9:26P
INCOMING
0476
6/10
9:56P
NEW YORK
NY
0477
6/10 10:27P
INCOMING
0478
6/10
10:58P
INCOMING
0479
6/11
8:10A
NEW YORK
NY
0480
6/11
8:11A
LOCAL
0481
6/11
8:12A
NEW YORK
NY
0482
6/11
9:47A
INCOMING
0483
6/11
10:30A
INCOMING
0484
6/11
11:04A
INCOMING
0485
6/11
12:42P
LDNEW YORK
NY NY
0486
6/11
12:44P
INCOMING
0487
6/11
1:46P
INCOMING
0488
6/11
2:48P
INCOMING
0489
6/11
3:49P
NEW YORK
NY
0490
6/11
3:50P
NEW YORK
NY
0491
6/11
4:21P
INCOMING
0492
6/11
4:25P
NEW YORK
NY
0493
6/11
4:47P
INCOMING
0494
6/11
4:49P
INCOMING
0495
6/11
5:51P
NEW YORK
NY
0496
6/11
7:32P
INCOMING
0497
6/11
8:07P
NEW YORK
NY
0498
6/11
8:12P
LOCAL
0499
6/11
8:13P
NEW YORK
NY
0500
6/11
9:21P
NEW YORK
NY
0501
6/11
9:28P
INCOMING
0502
6/11
9:57P
NEW YORK
NY
0503
6/11
10:03P
NEW YORK
NY
0504
6/11
10:04P
BROOKLYN
NY
0505
6/11
10:09P
NEW YORK
NY
0506
6/11
10:10P
NEW YORK
NY
4 4 4 2 2 2 5 5 5 1 9 1 3 1 1 1 1 3 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
0507
6/11
10:11P
NEW YORK
NY
0508
6/11
10:14P
LDNEW YORK
NY NY
0509
6/11
10:15P
INCOMING
0510
6/12
12:08P
INCOMING
0511
6/12
12:17P
INCOMING
0512
6/12
3:37P
INCOMING
0513
6/12
3:59P
NEW YORK
NY
0514
6/12
4:01P
NEW YORK
NY
0515
6/12
4:03P
NEW YORK
NY
0516
6/12
5:43P
NEW YORK
NY
0517
6/12
8:58P
NEW YORK
NY
EFTA00014857

=== Page 37 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 39.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0518 6/12 9:24P
INCOMING
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
849
.00
.00
CALL CHARACTERISTICS:
W = Call Waiting, A = Automatic Dropped Call Credit
"CALLS FROM" KEY:
NY = NEW YORK
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001 5/20 7:52P
10 0002
5/20
7:52P
.10
0003 5/20 7:52P
.10 0004
5/20
7:53P
.10
0005 5/20 7:54P
.10 0006
5/20
8:52P
.10
0007 5/20 8:52P
.10 0008
5/20
8:53P
00
.10
0009 5/20 8:54P
.10 0010 5/20 8:55P
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
1.00
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014858

=== Page 38 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 41.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
5/13/03 Through 6/12/03
MONTHLY SE - NATIONAL PLAN $199.99
199.99
CALL FORWARDING
.00
CALL WAITING
.00
CALLER ID
.00
WORLDCONNECT
7.99
EQUIP INS PREMIUM/FEE
2.79
PCS VOICEMAIL W/NUMERIC MSG
.00
DETAIL BILLING
.00
AT&T 2-WAY TEXT MSG $0.00
.00
REGULATORY PROGRAMS FEE
1.75
TOTAL MONTHLY SERVICE CHARGES
212.52
HOME AIRTIME CHARGES
5/13/03 Through 6/12/03 - NATIONAL PLAN $199.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
431
.000
.00
200 ADDITIONAL MINUTES
200
.000
.00
INCLUDED IN PLAN
680
.000
.00
1311
.00
TOTAL HOME AIRTIME CHARGES
.00
HOME LONG DISTANCE CHARGES
AT&T WIRELESS
11.00
TOTAL HOME LONG DISTANCE CHARGES
11.00
MESSAGING, CONTENT & APPLICATION CHARGES
5/13/03 Through 6/12/03
Category
Messages
Rate
Charge
INTERNATIONAL MESSAGES
1
.10
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.10
EFTA00014859

=== Page 39 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER BILL DATE PAGE 42.0
JEFFREY E EPSTEIN &
JUN 14, 2003
SUMMARY OF CHARGES (CONTINUED)
ROAMING CHARGES
ROAMING AIR
490.71
ROAMING LONG DISTANCE CHARGES
158.30
TOTAL ROAMING CHARGES
649.01
OTHER CHARGES AND CREDITS
AT&T CONNECT CALLS
4 CALLS
5.00
TOTAL OTHER CHARGES AND CREDITS
5.00
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
9.25
STATE TAX
12.70
LOCAL TAX
13.07
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
5.84
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
5.97
GROSS RECEIPTS SURCHARGE
10.14
TOTAL TAXES, SURCHARGES & REGULATORY FEES
58.47
TOTAL CURRENT MONTHLY CHARGES
936.10
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0001
5/13
1:54A
INCOMING
5
0002
5/13
7:58A
INCOMING
1
0003
5/13
7:59A
NEW YORK
NY
2
0004
5/13
9:23A
NEW YORK
NY
1
0005 5/13 9:26A
INCOMING
1
0006 5/13 10:15A
NEW YORK
NY
4
0007
5/13
10:31A
INCOMING
1
0008
5/13
10:33A
MOBILE
NY
1
0009
5/13
10:40A
INCOMING
3
0010
5/13
10:43A
LOCAL
1
0011 5/13 11:40A
INCOMING
2
0012 5/13 11:43A
800 SERV.
6
0013 5/13 12:22P
LOCAL
1
0014 5/13 12:32P
INCOMING
2
0015
5/13
12:47P
INCOMING
1
0016
5/13
1:17P
NEW YORK
NY
12
0017
5/13
1:36P
NEW YORK
NY
1
0018
5/13
1:45P
INCOMING
1
0019
5/13
1:45P
INCOMING
2
EFTA00014860

=== Page 40 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 43.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0020
5/13
1:50P
INCOMING
1
0021
5/13
3:23P
LOSANGELES CA
2
0022
13
INCOMING
4
0023
13
D
NEW YORK
NY
2
0024
13
:33P
LOSANGELES
CA
1
0025
13
51P
INCOMING
3
0026
13
56P
INCOMING
0027
13
P
LOSANGELES
CA
2
0028
13
45P
LOSANGELES
CA
2
0029
13
51P
NEW YORK
NY
0030
13
5:00P
INCOMING
2
0031
13
5:06P
NEW YORK
NY
0032
/13
P
INCOMING
5
0033
13
5:35P
LOSANGELES
CA
3
0034
13
NEW YORK
NY
0035
13
:45P
MOBILE
NY
3
0036
/13
:49P
MOBILE
NY
2
0037
13
:51P
INCOMING
10
0038
/13
15P
NEW YORK
NY
3
0039
13
18P
LOCAL
0040
/13
20P
INCOMING
2
0041
/13
:21P
NEWYORK
NY
0042
13
INCOMING
2
0043
/13
6:36P
INCOMING
0044
/13
6:40P
INCOMING
2
0045
13
6:41P
LOCAL
0046
/13
46P
NEW YORK
NY
2
0047
13
:50P
NEW YORK
NY
0048
/13
6
:51P
NEW YORK
NY
0049
/13
6
:58P
MOBILE
NY
0050
13
6:59P
LOCAL
0051
/13
01P
NEW YORK
NY
0052
/13
7:04P
INCOMING
0053
13
7:09P
INCOMING
2
0054
/13
7:44P
INCOMING
0055
13
8:24P
INCOMING
0056
13
11:33P
MOBILE
NY
2
0057
/13
INCOMING
0058
/13
11:41P
INCOMING
3
0059
13
INCOMING
2
0060
13
:52P
NEW YORK
NY
0061
13
1
:53P
INCOMING
0062
14
07A
INCOMING
0063
14
1
1A
NEW YORK
NY
0064
14
1
3A
NEW YORK
NY
0065
14
18A
LOCAL
2
0066
14
19A
MOBILE
NY
0067
14
9:20A
INCOMING
2
0068
14
01A
INCOMING
3
0069
14
:15A
INCOMING
0070
14
2:46P
INCOMING
0071
14
2:46P
LOSANGELES CA
0072
/14
2:51P
INCOMING
0073
714
4:15P
INCOMING
2
0074
/14
4:23P
INCOMING
0075
/14
4:25P
NEWYORK
NY
0076
/14
4:25P
NEW YORK
NY
3
0077
/14
4:29P
NEW YORK
NY
0078
/14
4:30P
MOBILE
NY
2
0079
5/14
4:31P
INCOMING
4
EFTA00014861

=== Page 41 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER
BILL DATE PAGE 44.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0080
5/14
4:50P
INCOMING
1
0081
5/14
4:53P
INCOMING
8
0082
14
5:00P
NEW YORK
NY
2
0083
14
5:05P
NEW YORK
NY
1
0084
14
6:01P
INCOMING
2
0085
14
6:19P
INCOMING
16
0086
14
6:34P
LOCAL
1
0087
14
6:36P
INCOMING
2
0088
14
6:38P
NEW YORK
NY
5
0089
14
6:43P
MOBILE
NY
4
0090
14
7:42P
MOBILE
NY
2
0091
14
7:46P
INCOMING
2
0092
14
10:47P
MOBILE
NY
9
0093
15
8:56A
INCOMING
6
0094
15
9:26A
INCOMING
2
0095
15
2:06P
NEW YORK
NY
0096
2:20P
INCOMING
2
0097
15
3:01P
MOBILE
NY
2
0098
15
19P
MOBILE
NY
1
0099
15
3:52P
INCOMING
6
0100
4:29P
LOCAL
0101
4:30P
NEW YORK
NY
2
0102
5:03P
MOBILE
NY
1
0103
15
5:04P
INCOMING
3
0104
15
5:08P
NEW YORK
NY
4
0105
15
5:11P
INCOMING
5
0106
15
5:37P
INCOMING
2
0107
15
5:50P
INCOMING
3
0108
15
6:07P
LOCAL
1
0109
15
6:23P
MOBILE
NY
2
0110
15
6:34P
INCOMING
1
0111
7:00P
MOBILE
NY
0112
7:01P
MOBILE
NY
10
0113
7:12P
MOBILE
NY
2
0114
15
7:15P
INCOMING
1
0115
15
7:38P
INCOMING
7
0116
15
7:55P
INCOMING
3
0117
8:10P
MOBILE
NY
1
0118
15
8:43P
INCOMING
2
0119
15
8:46P
NEW YORK
NY
1
0120
15
8:54P
NEW YORK
NY
1
0121
15
8:55P
INCOMING
2
0122
15
9:01P
MOBILE
NY
1
0123
15
9:02P
NEW YORK
NY
0124
15
9:33P
INCOMING
15
0125
15
9:36P
INCOMING
0126
15
9:48P
LAS VEGAS
NV
3
0127
15
10:14P
MOBILE
NY
1
0128
15
10:35P
MOBILE
NY
0129
15
10:36P
LOCAL
2
0130
15
10:50P
INCOMING
1
0131
16
9:49A
LDGREENSBORO NC NY
0132
16
4:49P
LDGREENSBORO NC NY
0133
17
11:39A
LDGREENSBORO NC NY
0134
17
1:42P
LDGREENSBORO NC NY
0135
17
6:54P
LDGREENSBORO NC NY
0136
20
8:52P
LDSPAIN
NY
1.750
0137
22 10:26A
LDWINSTN SAL NC
NY
0138
22 10:40A
LDWINSTN SAL NC
NY
0139
24
6:59A
LDGREENSBORO NC NY
EFTA00014862

=== Page 42 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 45.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0140 5/24 7:18A
LDGREENSBORO NC NY
0141
5/24
11:51A
LDGREENSBORO NC NY
0142
5/24
2:50P
LDWINSTN SAL
NC
NY
0143
24
2:52P
LDWINSTN SAL NC
NY
0144
24
:52P
LDWINSTN SAL NC NY
0145
24
5:57P
LDGREENSBORO NC NY
0146
24
10:46P
LDGREENSBORO NC NY
0147
25
6:37A
LDGREENSBORO
NC
NY
0148
25
6:59A
LDGREENSBORO
NC
NY
0149
25
9:36A
LDGREENSBORO
NC
NY
0150
10:58A
LDGREENSBORO
NC
NY
0151
26
8:36A
LDGREENSBORO NC NY
0152
26
8:54A
LDGREENSBORO
NC
NY
0153
26
9:04A
LDGREENSBORO
NC
NY
0154
26
11:09A
LDGREENSBORO NC NY
0155
11:40A
LDGREENSBORO NC NY
0156
28
8:53P
LOCAL
2
0157
28
8:55P
MOBILE
NY
2
0158
28
9:09P
OAHU
HI
3
0159
28
:14P
NEW YORK
NY
1
0160
28
9:17P
LOCAL
0161
28
10:06P
MOBILE
NY
2
0162
28
10:08P
LOCAL
1
0163
28
11:34P
LAS VEGAS
NV
1
0164
28
11:36P
INCOMING
10
0165
28
11:59P
INCOMING
3
0166
29
12:02A
MOBILE
NY
13
0167
29
:52A
MOBILE
NY
13
0168
29
:09A
NEW YORK
NY
1
0169
7:18A
NEW YORK
NY
0170
27A
800 SERV.
6
0171
29
7:32A
UN. KINGDO
1
.350
0172
7:37A
FREMNTNWRK
CA
2
0173
29
8:17A
INCOMING
11
0174
29
41A
LOCAL
1
0175
29
8:42A
NEW YORK
NY
6
0176
29
9:04A
MOBILE
NY
8
0177
29
:25A
INCOMING
1
0178
29
:26A
NEW YORK
NY
5
0179
29
9:38A
INCOMING
1
0180
29
9:39A
MOBILE
NY
1
0181
10:12A
LOCAL
1
0182
10:14A
NEW YORK
NY
1
0183
11:27A
INCOMING
5
0184
11:33A
INCOMING
1
0185
11:34A
NEW YORK
NY
2
0186
29
11:42A
CHARLT AML
VI
2
.400
0187
1:44A
LOCAL
1
0188
:45A
NEW YORK
NY
8
0189
29
2:50P
INCOMING
1
0190
29
3:10P
INCOMING
4
0191
29
3:50P
LOCAL
1
0192
29
3:58P
NEW YORK
NY
1
0193
29
4:00P
OAHU
HI
1
0194
29
4:13P
NEW YORK
NY
2
0195
9
4:37P
INCOMING
1
0196
4:39P
MOBILE
NY
1
0197
4:40P
LAS VEGAS
NV
0198
4:41P
NEW YORK
NY
4
0199
4:48P
INCOMING
3
EFTA00014863

=== Page 43 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 46.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0200
5/29
4:51P
INCOMING
1
0201
5/29
5:00P
INCOMING
3
0202
29
5:09P
INCOMING
1
0203
29
5:22P
INCOMING
1
0204
29
5:39P
INCOMING
11
0205
29
5:48P
INCOMING
3
0206
29
6:04P
INCOMING
7
0207
29
6:19P
INCOMING
1
0208
29
6:28P
OAHU
HI
2
0209
29
6:33P
NEW YORK
NY
2
0210
29
6:40P
NEW YORK
NY
1
0211
29
6:50P D
NEW YORK
NY
3
0212
29
7:08P
INCOMING
5
0213
29
7:17P
INCOMING
17
0214
29
7:33P
SANTA ROSA
CA
4
0215
29
7:36P
MOBILE
NY
27
0216
29
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LOCAL
1
0217
29
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NEW YORK
NY
1
0218
29
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NY
2
0219
29
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32
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29
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NEW YORK
NY
0221
29
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NY
3
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29
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NY
2
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NY
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29
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29
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NY
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NY
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29
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NY
2
0238
29
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ANDERSON
SC
7
0239
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NEW YORK
NY
2
0240
29
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NEW YORK
NY
2
0241
29
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INCOMING
2
0242
29
10:51P
INCOMING
1
0243
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10:55P
MOBILE
NY
5
0244
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11:01P
NEW YORK
NY
1
0245
30
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4
0246
30
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LOCAL
2
0247
30
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NY
1
0248
30
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2
0249
30
12:14A
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1
0250
30
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NEW YORK
NY
1
0251
30
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NY
1
0252
30
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5
0253
30
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NY
1
0254
30
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NEW YORK
NY
1
0255
30
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NY
1
0256
30
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INCOMING
1
0257
30
8:35A
INCOMING
0258
0
8:54A
NEW YORK
NY
0259
30
9:07A
LOCAL
2
EFTA00014864

=== Page 44 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 47.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0260 5/30 10:20A
LOCAL
1
0261 5/30 11:01A
LOCAL
1
0262
6/01
5:31P
LDSANTURCE
PR NY
.200
0263
6/02
2:26P
LDSANTURCE
PR NY
.200
0264
6/03
10:42A
LDSANTURCE
PR NY
.200
0265
6/03
1:09P
LDSANTURCE
PR
NY
.800
0266
6/03
1:59P
LDSANTURCE
PR NY
.400
0267
6/03
7:34P
LDSANTURCE
PR NY
1.800
0268
6/03
10:10P
LDSANTURCE
PR NY
.200
0269
6/03
10:10P
LDSANTURCE
PR
NY
.200
0270
6/04
12:08P
LDSANTURCE
PR NY
.200
0271
6/04
12:26P
LDSANTURCE
PR NY
.400
0272
6/04
8:33P
LOCAL
1
0273
6/04
8:35P
NEW YORK
NY
1
0274
6/04
NEW YORK
NY
1
0275
6/04
NEW YORK
NY
4
0276
6/04
10:12P
INCOMING
2
0277
6/04
10:18P
LOCAL
3
0278
6/04
10:19P
INCOMING
2
0279
6/05
12:33A
LOCAL
1
0280
6/05
3:19A
NWYRCYZN01 NY
4
0281
6/05
3:23A
NWYRCYZN01 NY
1
0282
6/05
3:24A
NEW YORK
NY
4
0283
6/05
8:42A
INCOMING
5
0284
6/05
8:47A
INCOMING
8
0285
6/05
9:12A
INCOMING
2
0286
6/05
9:52A
INCOMING
2
0287
6/05
11:43A
INCOMING
2
0288
6/05
INCOMING
0289
6/05
2:32P
INCOMING
1
0290
6/05
2:34P
INCOMING
6
0291
6/05
2:48P
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1
0292
6/05
3:19P
INCOMING
3
0293
6/05
3:34P
INCOMING
2
0294
6/05
4:11P
INCOMING
2
0295
6/05
4:18P
MOBILE
NY
1
0296
6/05
4:20P
NWYRCYZN01 NY
2
0297
6/05
4:24P
INCOMING
2
0298
6/05
5:12P
INCOMING
8
0299
6/05
5:50P
INCOMING
3
0300
6/05
6:21P
OAHU
HI
2
0301
6/05
6:22P
NEW YORK
NY
1
0302
6/05
6:27P
OAHU
HI
4
0303
6/05
6:37P
NEW YORK
NY
1
0304
6/05
6:42P
NEW YORK
NY
1
0305
6/05
6:56P
SANTA ROSA
CA
1
0306
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7:02P
SANTA ROSA
CA
25
0307
6/05
7:34P
LOCAL
2
0308
6/05
7:36P
LOSANGELES
CA
1
0309
6/05
7:41P
NEW YORK
NY
1
0310
6/05
7:43P
NEW YORK
NY
1
0311
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7:43P
MOBILE
NY
2
0312
6/05
8:03P
INCOMING
3
0313
6/05
8:05P
INCOMING
11
0314
6/05
8:15P
INCOMING
1
0315
6/05
8
16P
NWYRCYZN01 NY
1
0316
6/05
6
NWYRCYZN01 NY
1
0317
8
NWYRCYZN01 NY
2
0318
6/05
8
INCOMING
3
0319
6/05
8:56P
NEW YORK
NY
2
EFTA00014865

=== Page 45 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 48.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0320
6/05
9:13P
NEW YORK
NY
1
0321
6/05
NEW YORK
NY
1
0322
6/05
9:21P
NEW YORK
NY
5
0323
6/05
MOBILE
NY
2
0324
6/05
NEW YORK
NY
1
0325
6/05
NEW YORK
NY
3
0326
6/05
P
D
DIR ASST
3
0327
6/05
NEW YORK
NY
1
0328
6/05
INCOMING
2
0329
6/05
10:54P
MOBILE
NY
4
0330
6/06
9:02A
MOBILE
NY
3
0331
6/06
9:04A
INCOMING
3
0332
6/06
9:08A
MOBILE
NY
2
0333
6/06
1
INCOMING
4
0334
6/06
LOCAL
6
0335
6/06
7A
INCOMING
5
0336
6/06
3A
OAHU
HI
0337
6/06
4A
LOCAL
0338
6/06
5A
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0339
6/06
6A
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0340
6/06
2A
INCOMING
3
0341
6/06
9A
NEW YORK
NY
0342
6/06
0A
QUEENS
NY
2
0343
6/06
2A
NEW YORK
NY
2
0344
6/06
5A
NEW YORK
NY
0345
6/06
12:07P
INCOMING
0346
6/06
OP
INCOMING
2
0347
6/06
12:30P
MOBILE
NY
3
0348
6/06
INCOMING
2
0349
6/06
INCOMING
4
0350
6/06
1:50P
INCOMING
0351
6/06
2:47P
LOCAL
0352
6/06
3:04P
INCOMING
2
0353
6/06
INCOMING
1
0354
6/06
26P
INCOMING
0355
6/06
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INCOMING
1
0356
6/06
3:39P
INCOMING
0357
6/06
3:50P
INCOMING
0358
6/06
P
INCOMING
1
0359
6/06
5:23P
INCOMING
1
0360
6/06
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NEW YORK
NY
2
0361
6/06
5:36P
INCOMING
3
0362
6/06
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INCOMING
3
0363
6/06
6:17P
FRANCE
2.100
0364
6/06
6
52P
INCOMING
3
0365
6/06
6:59P
MOBILE
NY
1
0366
6/06
7:06P
NEW YORK
NY
0367
6/06
7:07P
UN. KINGDO
.350
0368
6/06
7:08P
INCOMING
3
0369
6/06
7:13P
NEW YORK
NY
1
0370
6/06
7:32P
INCOMING
1
0371
6/06
9:13P
LOCAL
0372
6/06
NWYRCYZN01 NY
0373
6/06
11:06P
QUEENS
NY
0374
6/06
OAHU
HI
0375
6/06
11
INCOMING
0376
6/06
13P
INCOMING
2
0377
6/06
S
OAHU
HI
0378
6/06
11:29P
NEW YORK
NY
0379
6/06
11:49
INCOMING
2
EFTA00014866

=== Page 46 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 49.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0380 6/06 11:57P
MOBILE
NY
2
0381
6/07
7:01A
INCOMING
3
0382
6/07
7:04A
NEW YORK
NY
0383
6/07
7:06A
NEW YORK
NY
2
0384
6/07
7:09A
INCOMING
2
0385
6/07
8:09A
INCOMING
0386
6/07
8:11A
INCOMING
5
0387
6/07
18A
MOBILE
NY
0388
6/07
20A
S
LOSANGELES
CA
0389
6/07
8:22A
LOSANGELES
CA
2
0390
6/07
9:41A
MOBILE
NY
0391
6/07
9:48A
W PALM BCH FL
0392
6/07
9:51A
W PALM BCH FL
0393
6/07
9:53A
S
W PALM BCH FL
2
0394
6/07
9:54A
W PALM BCH FL
0395
6/07
9:59A
W PALM BCH FL
0396
6/07
10:12A
INCOMING
3
0397
6/07
10:26A
INCOMING
0398
6/07
10:27A
W PALM BCH FL
0399
6/07
10:50A
INCOMING
0400
6/07
10:51A
NEW YORK
NY
0401
6/07
7A
INCOMING
0402
6/07
11
19A
W PALM BCH FL
0403
6/07
11:20A
MOBILE
NY
0404
6/07
11:21A
MOBILE
NY
2
0405
6/07
11:22A
NEW YORK
NY
2
0406
6/07
11:24A
NEW YORK
NY
0407
6/07
25A
LOCAL
3
0408
6/07
11
25A
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3
0409
6/07
1
28A
W
LOCAL
0410
6/07
1
28A
LOCAL
2
0411
6/07
11:53A
INCOMING
0412
6/07
11:53A
MOBILE
NY
0413
6/07
11:54A
W
INCOMING
0414
6/07
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NEW YORK
NY
0415
6/07
2:36P
INCOMING
0416
6/07
2:40P
MOBILE
NY
0417
6/07
1:56P
LOCAL
0418
6/07
2:58P
MOBILE
NY
0419
6/07
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INCOMING
2
0420
6/07
3:07P
INCOMING
1
0421
6/07
3:08P
LOCAL
1
0422
6/07
3:09P
INCOMING
4
0423
6/07
3:16P
NEW YORK
NY
1
0424
6/07
3:32P
NEW YORK
NY
1
0425
6/07
3:45P
NEW YORK
NY
1
0426
6/07
3:57P
NEW YORK
NY
1
0427
6/07
3:58P
NEW YORK
NY
2
0428
6/07
3:59P
NEW YORK
NY
0429
6/07
4:00P
INCOMING
1
0430
6/07
4:00P
NEW YORK
NY
1
0431
6/07
4:24P
INCOMING
4
0432
6/07
4:28P
MOBILE
NY
1
0433
6/07
4:29P
NEW YORK
NY
1
0434
6/07
4:29P
MOBILE
NY
13
0435
6/07
4:52P
NEW YORK
NY
2
0436
6/07
5:44P
MOBILE
NY
3
0437
6/07
5:47P
MOBILE
NY
2
0438
6/07
5:49P
INCOMING
2
0439
6/07
5:51P
LOCAL
4
EFTA00014867

=== Page 47 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE NUMBER
BILL DATE PAGE 50.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0440
6/07
5:53P W
INCOMING
0441
6/07
5:55P
MOBILE
NY
0442
6/07
5:57P
LOCAL
0443
6/07
5:58P
S
W PALM BCH FL
0444
6/07
5:59P
W PALM BCH FL
0445
6/07
6:01P
NEW YORK
0446
6/07
6:32P
INCOMING
0447
6/07
6:40P
INCOMING
0448
6/07
6:47P
NEW YORK
0449
6/07
7:52P
INCOMING
0450
6/07
11:24P
NEW YORK
WP
0451
6/08
10:13A
NEW YORK
WP
0452
6/08
11:13A
WEST PALM
WP
0453
6/08
12:46P
LDW PALM BCH NY
0454
6/08
12:47P
INCOMING
WP
0455
6/08
2:07P
LDW PALM BCH
NY
0456
6/08
2:08P
INCOMING
WP
0457
6/08
2:13P
OAHU
WP
0458
6/08
6:32P
NEW YORK
NY NY NY NY NY NY NY NY NY NY VI NY NY NY NY NY NY NY NY NY NY HI CA CA FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL
WP
0459
6/08
9:17P
NEW YORK
WP
0460
6/08
9:47P
LDW PALM BCH
NY
0461
6/08
9:49P
INCOMING
WP
0462
6/08 10:05P
NEW YORK
WP
0463
6/09
1:53P
MOBILE
WP
0464
6/09
1:58P
WEST PALM
WP
0465
6/09
2:11P
LDW PALM BCH
NY
0466
6/09
2:12P
INCOMING
WP
0467
6/09
2:45P
ST HELENA
WP
0468
6/09
2:47P
CALISTOGA
WP
0469
6/09
3:16P
NEW YORK
WP
0470
6/09
3:17P
MOBILE
WP
0471
6/09
5:32P
NEW YORK
WP
0472
6/09
8:36P
LDW PALM BCH
NY
0473
6/09
8:37P
INCOMING
WP
0474
6/10
9:29A
LDW PALM BCH
NY
0475
6/10
9:30A
INCOMING
WP
0476
6/10
9:34A
NEW YORK
WP
0477
6/10
1:11P
WEST PALM
WP
0478
6/10
1:32P
NEW YORK
WP
0479
6/10
1:45P
LDW PALM BCH
NY
0480
6/10
1:46P
INCOMING
WP
0481
6/10
2:22P
WEST PALM
WP
0482
6/10
2:29P
NEW YORK
WP
0483
6/10
2:33P
NEW YORK
WP
0484
6/10
2:38P
NEW YORK
WP
0485
6/10
4:38P
LDW PALM BCH
NY
0486
6/10
4:39P
INCOMING
WP
4 Namel Neldel 2 2 2 2 2 2 2 2 2 2 2 2 1 3 3 2 2 1 6 2 3 1 1 3 1 1 1 1 1 1 1 1 1 1 1 1 1
0487
6/10
6:11P
NEW YORK
WP
0488
6/10
6:58P
NEW YORK
WP
0489
6/10
7:29P
WEST PALM
WP
0490
6/10
7:42P
NEW YORK
WP
0491
6/10
7:44P
S
NEW YORK
WP
0492
6/10
7:45P
NEW YORK
WP
0493
6/10
7:48P
WEST PALM
WP
0494
6/10
7:50P
WEST PALM
WP
0495
6/11
10:05A
NEW YORK
WP
0496
6/11
10:06A
CHARLT AML
WP
.400
0497
6/11
10:10A
NEW YORK
NY
WP
0498
6/11
10:18A
LDW PALM BCH
FL
NY
0499
6/11
10:19A
INCOMING
WP
EFTA00014868

=== Page 48 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 51.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0500 6/11 10:22A
NEW YORK
NY WP
2
0501
6/11
10:23A
OAHU
HI WP
2
0502
6/11
10:48A
LDW PALM BCH
FL
NY
0503
6/11
10:49A
INCOMING
WP
2
0504
6/11
10:59A
LDW PALM BCH FL NY
0505
6/11
11:00A
INCOMING
WP
1
0506
6/11
11:47A
LDW PALM BCH FL NY
0507
6/11
11:48A
INCOMING
WP
2
0508
6/11
12:05P
LDW PALM BCH FL
NY
0509
6/11
12:06P
INCOMING
WP
1
0510
6/11
12:15P
NEW YORK
NY
WP
1
0511
6/11
12:18P
LDW PALM BCH FL
NY
0512
6/11
12:19P
INCOMING
WP
4
0513
6/11
6:05P
LOCAL
2
0514
6/11
6:42P
LOCAL
2
0515
6/11
7:20P
NEW YORK
NY
1
0516
6/11
7:51P
NEW YORK
NY
1
0517
6/11
7:54P
NEW YORK
NY
1
0518
6/11
7:59P
MOBILE
NY
8
0519
6/11
8:50P
UN. KINGDO
1
.350
0520
6/11
9:07P
NEW YORK
NY
3
0521
6/11
9:10P
NEW YORK
NY
1
0522
6/11
9:17P
MOBILE
NY
1
0523
6/11
10:10P
800 SERV.
7
0524
6/11
10:18P
800 SERV.
3
0525
6/11
10:24P
INCOMING
1
0526
6/11 10:31P
800 SERV.
5
0527
6/11 10:45P
MOBILE
NY
1
0528
6/11 11:06P
INCOMING
2
0529
6/12
12:20A
800 SERV.
7
0530
6/12
9:03A
INCOMING
1
0531
6/12
9:23A
INCOMING
1
0532
6/12
9:25A
INCOMING
1
0533
6/12
10:03A
INCOMING
1
0534
6/12
12:02P
INCOMING
2
0535
6/12
12:06P
INCOMING
1
0536
6/12
12:32P
INCOMING
1
0537
6/12
12:44P
INCOMING
1
0538
6/12
2:05P
INCOMING
10
0539
6/12
2:57P
INCOMING
1
0540
6/12
3:24P
LOCAL
1
0541
6/12
3:35P
OAHU
HI
2
0542
6/12
3:37P
NEW YORK
NY
1
0543
6/12
3:48P
INCOMING
1
0544
6/12
4:10P
OAHU
HI
24
0545
6/12
4:33P
LOCAL
1
0546
6/12
5:30P
INCOMING
3
0547
6/12
5:56P
UN. KINGDO
2
.700
0548
6/12
5:58P
MOBILE
NY
1
0549
6/12
5:59P
OAHU
HI
5
0550
6/12
6:10P
INCOMING
3
0551
6/12
6:19P
INCOMING
1
0552
6/12
6:43P
NEW YORK
NY
1
0553
6/12
7:00P
NEW YORK
NY
5
0554
6/12
7:10P
INCOMING
1
0555
6/12
7:11P
MOBILE
NY
1
0556
6/12
9:23P
INCOMING
8
0557
6/12
10:10P
LOCAL
2
0558
6/12
10:11P
NEW YORK
NY
1
EFTA00014869

=== Page 49 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 52.0
JEFFREY E EPSTEIN &
JUN 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0559 6/12 10:33P
INCOMING
2
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
1311
.00
11.00
CALL CHARACTERISTICS:
D = AT&T Connect Calls, W = Call Waiting,
S = Long Distance Service Billed Separately
"CALLS FROM" KEY:
NY = NEW YORK
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001 6/01 5:08P 447836747546 I
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.10
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
ROAMING CHARGES
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
Calls Made From: ST THOMAS VI
0001 6/01 10:43A
NEW YORK
NY
2
1.38
.40
Subtotal for : ST. THOMAS, VI
2
1.38
.40
.00
Calls Made From: USVI, VI
0002
5/30
4:17P
LOCAL
3
2.07
0003
6/01
5:32P
INCOMING
1
.69
0004
6/02
1:45P
NEW YORK
NY
2
1.38
.40
0005
6/02
2:27P
INCOMING
1
.69
0006
6/02
2:40P
LOCAL
2
1.38
0007
6/02
3:44P
LOCAL
1
.69
0008
6/02
5:11P
LOCAL
3
2.07
0009
6/02
8:19P
BROOKLYN NY
1
.69
.20
0010 6/02 9:51P
LOCAL
2
1.38
0011
6/03
10:43A
INCOMING
1
.69
0012 6/03 10:50A
800 SERV.
6
4.14
0013 6/03 12:24P
CHARLT AML VI
1
.69
.20
0014 6/03 12:38P
LOCAL
1
.69
0015
6/03
1:10P
INCOMING
4
2.76
0016
6/03
2:00P
INCOMING
2
1.38
0017 6/03 7:32P
LOCAL
2
1.38
0018
6/03
7:35P
INCOMING
9
6.21
0019
6/03
9:34P
OAHU
HI
25
17.25
5.00
0020 6/03 10:11P
INCOMING
1
.69
EFTA00014870

=== Page 50 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 53.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0021 6/03 10:11P
INCOMING
1
.69
0022 6/04 9:52A
LOCAL
1
.69
0023 6/04 12:10P
INCOMING
1
.69
0024 6/04 12:27P
INCOMING
2
1.38
0025 6/04 1:47P
LOCAL
1
.69
0026 6/04 1:52P
QUEENS
NY
1
.69
.20
Subtotal for
: USVI, VI
75
51.75
6.00
.00
Calls Made From: ITALY
0027 5/18 5:21P
INTL NTWK
1
.99
.35
0028 5/18 11:51P
INTL NTWK
3
2.97
1.05
0029 5/19 12:16A
INTL NTWK
1
.99
.35
0030 5/19 6:44P
INTL NTWK
1
.99
.35
0031 5/20 3:07A
INTL NTWK
2
1.98
.70
0032 5/20 3:19A
INTL NTWK
1
.99
.35
Subtotal for : ITALY,
9
8.91
3.15
.00
Calls Made From: FRANCE,
0033
5/16
3:29P
INTL NTWK
1
.99
.35
0034 5/16 3:30P
INTL NTWK
1
.99
.35
0035 5/16 3:32P
INTL NTWK
2
1.98
.70
0036
5/16
3:38P
INTL NTWK
1
.99
.35
0037
5/16
3:44P
INTL NTWK
4
3.96
1.40
0038
5/16
5:12P
INTL NTWK
1
.99
.35
0039
5/16
6:39P
INTL NTWK
2
1.98
.70
0040
5/16
7:19P
INTL NTWK
6
5.94
2.10
0041
5/16
7:26P
INTL NTWK
2
1.98
.70
0042
5/17
8:38P
INTL NTWK
.99
.35
0043
5/17
8:40P
INTL NTWK
1
.99
.35
0044
5/18
2:41A
INTL NTWK
1
.99
.35
0045
5/22
5:25P
INTL NTWK
2
1.98
.70
0046
5/24
1:08P
INTL NTWK
12
11.88
4.20
0047
5/24
2:10P
INTL NTWK
1
.99
.35
0048
5/24
2:11P
INTL NTWK
3
2.97
1.05
0049
5/24
5:13P
INTL NTWK
1
.99
.35
0050
5/24
5:16P
INTL NTWK
4
3.96
1.40
0051
5/24
5:20P
INTL NTWK
2
1.98
.70
0052
5/24
10:52P
INTL NTWK
1
.99
.35
0053
5/24 11:01P
INTL NTWK
1
.99
.35
0054
5/24
11:01P
INTL NTWK
1
.99
.35
0055
5/25
1:39A
INTL NTWK
2
1.98
.70
0056 5/25 1:54A
INTL NTWK
1
.99
.35
0057
5/25
4:57A
INTL NTWK
1
.99
.35
0058
11:38A
INTL NTWK
1
.99
.35
0059
12:42P
INTL NTWK
1
.99
.35
0060
/25
12:50P
INTL NTWK
1
.99
.35
0061
/25
12:58P
INTL NTWK
.99
.35
0062
/25
1:59P
INTL NTWK
3
2.97
1.05
0063
3:36P
INTL NTWK
1
.99
.35
0064
4:10P
INTL NTWK
1
.99
.35
0065
5/26
2:14P
INTL NTWK
2
1.98
.70
Subtotal for : FRANCE,
66
65.34
23.10
.00
Calls Made From: FRANCE
0066
5/17
5:50P
INTL NTWK
1
.99
.35
0067
5/17
5:56P
INTL NTWK
2
1.98
.70
0068
5/17
6:26P
INTL NTWK
2
1.98
.70
EFTA00014871

=== Page 51 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 54.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0069
5/17
6:32P
INTL NTWK
1
99
0070
5/17
6:36P
INTL NTWK
0071
17
INTL NTWK
0072
17
7:32P
INTL NTWK
17
5
4
0073
7:45P
INTL NTWK
2
0074
18
12:00A
CALL SVC
9
0075
18
2:02P
INTL NTWK
9
0076
18
2:04P
INTL NTWK
9
0077
18
:14P
INTL NTWK
2
0078
22
12
CALL SVC
HHH 1 1
9
0079
7:58P
INTL NTWK
2
8
0080
22
7:59P
INTL NTWK
2
0081
22
9:16P
INTL NTWK
8
0082
22
10:14P
INTL NTWK
9
0083
10:35P
INTL NTWK
2
0084
12:00A
CALL SVC
0085
INTL NTWK
0086
INTL NTWK
0087
INTL NTWK
0088
49A
INTL NTWK
0089
50A
INTL NTWK
0090
0A
INTL NTWK
0091
1A
INTL NTWK
0092
7P
INTL NTWK
0093
INTL NTWK
2.10 1.75 1.40 1.05 1.05 70 non-mmnne MANAN 70 mmm mmm-in
лоллллллллллл 70 70 OUTOOO our 35 35
0094
INTL NTWK
0095
INTL NTWK
0096
23
2:06P
INTL NTWK
0097
23
INTL NTWK
4
3
1
0098
23
INTL NTWK
0099
23
INTL NTWK
0100
24
0101
24
HHH
12:00A
CALL SVC
9
INTL NTWK
9
0102
24
2A
INTL NTWK
20
0103
24
A
INTL NTWK
2
191
7
0104
24
9A
INTL NTWK
0105
24
36P
INTL NTWK
9
0106
24
INTL NTWK
0107
24
INTL NTWK
0108
24
57P
INTL NTWK
0109
INTL NTWK
9
0110
INTL NTWK
9
0111
12:00A
CALL SVC
9
0112
5:36P
INTL NTWK
4
6
0113
INTL NTWK
9
0114
INTL NTWK
3
0115
INTL NTWK
0116
INTL NTWK
INTL NTWK
0118
10
INTL NTWK
2
0119
INTL NTWK
0120
1
INTL NTWK
4 3 2 1 1.
9
0117
5
0121
INTL NTWK
9
0122
INTL NTWK
2
0
11
P
INTL NTWK
0
INTL NTWK
0125
1
INTL NTWK
2
1.
EFTA00014872

=== Page 52 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 55.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0126 5/26 12:00A
CALL SVC
1
.99
0127 5/26 12:22A
INTL NTWK
2
1.98
70
0128 5/26 10:34A
INTL NTWK
9
8.91
3.15
0129 5/26 11:37A
INTL NTWK
3
2.97
1.05
0130
5/26
2:32P
INTL NTWK
1
.99
.35
0131
5/26
2:34P
INTL NTWK
1
.99
.35
0132
5/26
2:40P
INTL NTWK
1
.99
.35
0133
5/26
5:03P
INTL NTWK
1
.99
.35
0134
5/26
5:05P
INTL NTWK
2
1.98
.70
0135 5/26 5:07P
INTL NTWK
1
.99
.35
Subtotal for
:
FRANCE,
133
131.67
44.45
.00
Calls Made From: ITALY,
0136
5/18
5:04P
INTL NTWK
1
.99
0137
5/18
6:30P
INTL NTWK
1
.99
0138 5/18 7:03P
INTL NTWK
1
.99
0139
5/18
7:11P
INTL NTWK
2
1.98
.70
0140
5/18
9:56P
INTL NTWK
1
.99
.35
0141
5/18
11:16P
INTL NTWK
1
.99
.35
0142
5/19
5:29P
INTL NTWK
.99
.35
0143
5/19
5:32P
INTL NTWK
1
.99
.35
0144 5/19 6:04P
INTL NTWK
4
3.96
1.40
0145
5/19
7:52P
INTL NTWK
5
4.95
1.75
0146 5/19 7:57P
INTL NTWK
1
.99
.35
Subtotal for : ITALY,
19
18.81
6.65
.00
Calls Made From: SPAIN
0147 5/21 5:21A
INTL NTWK
1
.99
.35
Subtotal for
: SPAIN,
1
.99
.35
.00
Calls Made From: GREAT BRITAIN,
0148
5/26
7:15P
INTL NTWK
1
.99
.35
0149 5/26 7:19P
INTL NTWK
2
1.98
.70
0150 5/26 7:22P
INTL NTWK
1
.99
.35
0151 5/27 12:00A
CALL SVC
1
.99
0152
5/27 11:42A
INTL NTWK
2
1.98
.70
0153
5/27 11:46A
INTL NTWK
1
.99
.35
0154
/27
1:21P
INTL NTWK
2
1.98
.70
0155
/27
3:13P
INTL NTWK
9
8.91
3.15
0156
/27
4:05P
INTL NTWK
1
.99
.35
0157
5/27
4:06P
INTL NTWK
5
4.95
1.75
0158
5/27
4:27P
INTL NTWK
8
7.92
2.80
0159
/27
4:41P
INTL NTWK
1
.99
.35
0160
/27
4:43P
INTL NTWK
1
.99
.35
0161
5/27
4:56P
INTL NTWK
4
3:96
1.40
0162
5/27
6:37P
INTL NTWK
4
1.40
0163
5/27
8:30P
INTL NTWK
1
.99
.35
0164
27
9:24P
INTL NTWK
5
4.95
1.75
0165
/27 10:44P
INTL NTWK
3
2.97
1.05
0166
/27 10:48P
INTL NTWK
2
1.98
.70
0167
/27
10:50P
INTL NTWK
1
.99
.35
0168
5/27 10:53P
INTL NTWK
2
1.98
.70
0169
5/27
10:56P
INTL NTWK
1
.99
.35
0170
27
11:04P
INTL NTWK
6
28 11:03A
5:94
2.10
0171
INTL NTWK
4
1.40
0172
28
1:30P
INTL NTWK
1
.99
.35
0173
1:44P
INTL NTWK
1
.99
.35
EFTA00014873

=== Page 53 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 56.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF
DATE
TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0174
5/28
2:42P
INTL NTWK
1
.99
.35
0175
5/28
2:46P
INTL NTWK
1
.99
.35
0176
5/28
3:05P
INTL NTWK
3
2.97
1.05
0177
5/28
4:46P
INTL NTWK
1
.99
.35
0178 5/28 4:47P
INTL NTWK
1
.99
.35
0179 5/28 4:48P
INTL NTWK
1
.99
.3
0180 5/28 4:49P
INTL NTWK
1
.99
-
0181 5/28 4:51P
INTL NTWK
3
2.97
1.05
Subtotal for : GREAT BRITAIN,
82
81.18
28.35
.00
Calls Made From: ITALY
0182
5/19
3:40P
INTL NTWK
1
.99
.35
0183 5/19 4:18P
INTL NTWK
1
.99
.35
0184 5/19 4:29P
INTL NTWK
2
1.98
.70
0185 5/19 4:36P
INTL NTWK
5
4.95
1.75
0186 5/20 10:46A
INTL NTWK
1
.99
.35
0187 5/20 10:47A
INTL NTWK
2
1.98
.70
0188 5/20 11:45A
INTL NTWK
1
.99
.35
Subtotal for : ITALY,
13
12.87
4.55
.00
Calls Made From: SPAIN,
0189
5/20
4:37P
INTL NTWK
1
.99
.35
0190 5/20 4:39P
INTL NTWK
1
.99
0191 5/20 4:40P
INTL NTWK
1
.99
.35
0192 5/20 5:22P
INTL NTWK
2
1.98
.70
0193
5/20
6:15P
INTL NTWK
14
13.86
4.90
0194
5/20
8:26P
INTL NTWK
4
3.96
1.40
0195
5/20
8:50P
INTL NTWK
99
.35
0196
5/20
9:30P
INTL NTWK
3
2.97
1.05
0197
5/20
9:59P
INTL NTWK
1
.99
.35
0198
5/20
10:00P
INTL NTWK
2
1.98
.70
0199
5/20
10:04P
INTL NTWK
1
.99
.35
0200
5/20
10:06P
INTL NTWK
2
1.98
.70
0201
5/20
11:04P
INTL NTWK
1
.99
.35
0202
5/20
11:36P
INTL NTWK
1
.99
0203
5/20
11:36P
INTL NTWK
1
.99
0204
5/20
11:36P
INTL NTWK
1
.99
0205
5/20
11:37P
INTL NTWK
1
.99
0206
5/20
11:38P
INTL NTWK
2
1.98
.70
0207
5/20
11:41P
INTL NTWK
1
.99
.35
0208
5/20
11:52P
INTL NTWK
1
.99
3
0209
5/20
11:54P
INTL NTWK
1
.99
0210
5/20
11:55P
INTL NTWK
1
.99
0211
5/21
2:58A
INTL NTWK
2
1.98
.70
0212
5/21
2:40P
INTL NTWK
19
18.81
6.65
0213
5/21
4:10P
INTL NTWK
2
1.98
70
0214
5/21
4:37P
INTL NTWK
.99
.35
0215
5/21
5:09P
INTL NTWK
1
.99
.35
0216
5/21
5:24P
INTL NTWK
1
.99
.35
0217
5/21
6:28P
INTL NTWK
1
.99
0218
5/21
6:30P
INTL NTWK
3
2.97
1.05
0219
5/21
6:33P
INTL NTWK
2
1.98
.70
0220
6:54P
INTL NTWK
1
.99
.35
0221
21
6:55P
INTL NTWK
1
.99
.35
0222
6:57P
INTL NTWK
2
1.98
.70
0223
7:05P
INTL NTWK
2
1.98
.70
0224
5/21
7:23P
INTL NTWK
2
1.98
.70
EFTA00014874

=== Page 54 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 57.0
JEFFREY E EPSTEIN &
JUN 14, 2003
REF
DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0225
5/21
7:25P
INTL NTWK
2
1.98
.70
0226
5/21
7:32P
INTL NTWK
3
2.97
1.05
0227
5/21
7:37P
INTL NTWK
1
.99
.35
0228
5/21
7:39P
INTL NTWK
2
1.98
.70
0229
5/21
8:39P
INTL NTWK
1
.99
.35
0230
5/21
8:56P
INTL NTWK
2
1.98
.70
0231
5/21
10:04P
INTL NTWK
4
3.96
1.40
0232
5/21
10:11P
INTL NTWK
5
4.95
1.75
0233
5/21 11:39P
INTL NTWK
1
.99
.35
0234
5/21
11:40P
INTL NTWK
1
.99
.35
0235
5/21
11:43P
INTL NTWK
1
.99
.35
0236
5/21
11:44P
INTL NTWK
.99
.35
0237
5/22
11:54A
INTL NTWK
1
.99
.35
0238
5/22
11:55A
INTL NTWK
2
1.98
.70
0239 5/22 12:57P
INTL NTWK
1
.99
.35
0240 5/22 1:00P
INTL NTWK
1
.99
.35
Subtotal for : SPAIN,
113
111.87
39.55
.00
Calls Made From: FRANCE.
0241 5/16 12:00P
INTL NTWK
1
.99
.35
0242 5/16 12:25P
INTL NTWK
1
H
.99
.35
0243 5/24 12:00A
CALL SVC
1
.99
0244 5/24 8:03P
INTL NTWK
2
1.98
.70
0245 5/24 10:11P
INTL NTWK
1
.99
.35
Subtotal for : FRANCE,
6
5.94
1.75
.00
TOTAL ROAMING CHARGES
519
490.71
158.30
.00
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
LAST
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
PAGE
EFTA00014875


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=== Page 1 ===
From:
(USANYS)"
To: Robert Glassman
Cc:
)"
, "Nathan Werksman"
, Keilah Betts
Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke
et al., SDNY Case No. 1:20-cv-00484-JGK-DCF
Date: Tue, 04 Aug 2020 03:51:11 +0000
Attachments: 080320 Letter re Request for Information Relating to Epstein.pdf;
August_2020_Document_Production_to_Glassman_re_Touhy_Request.pdf
Mr. Glassman,
Please find attached a letter responding to your Touhy request.
Thank you,
From:
(USANYS)
Sent: Tuesday, June 30, 2020 12:33 AM
To: Robert Glassman
Cc:
>; Nathan Werksman
>; Keilah
Betts
Subject: Re: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke et al., SDNY Case No.
1:20-cv-00484-JGK-DCF
Mr. Glassman,
Thank you for checking in. I hope to be able to follow up soon.
Thanks,
On Jun 26, 2020, at 12:49 AM, Robert Glassman
wrote:
Mr.
I am following up on my client's request. It would mean a lot for your office to do what it can to see that
her request is complied with in an expedient manner. Thank you.
Robert S. Glassman
Panish Shea & Boyle
psblaw.com
On Jun 8, 2020, at 4:19 PM,
(USANYS)
wrote:
Dear Mr. Glassman,
Thank you for your letter. I will follow up.
EFTA00014450

=== Page 2 ===
Thanks,
From: Robert Glassman
Sent: Monday, June 8, 2020 3:08 PM
To:
(USANYS)
Cc:
>; Nathan Werksman
>; ; Keilah
Betts
Subject: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke et al., SDNY Case No.
1:20-cv-00484-JGK-DCF
Importance: High
Dear Mr.
Please see the attached letter of today's date. A copy will also be sent via Fedex. Thank you.
Robert Glassman
Robert Glassman, Esq.
Panish Shea & Boyle LLP
Web: www.psblaw.com
CONFIDENTIALITY NOTICE:
This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use,
distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to
the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you
have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other
deadlines for your case or potential case.
EFTA00014451


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=== Page 1 ===
From:
To:
Subject: FW: proposed schedule.
Date: Fri, 20 Sep 2019 16:41:34 +0000
How's next Friday to meet? That will give us a few days to discuss internally and confer with
before we meet with
them.
Assistant United States Attorney
From: Bruce Barket
Sent: Friday, September 20, 2019 12:15 PM
To:
Cc: tonyricco
Michael Bachrach
Subject: proposed schedule.
I think we will be ready to propose a schedule sometime early next week. Is there a day and time when you can meet to
discuss? We will send you a proposed briefing schedule ahead of the meeting. I hope to have ours finalized no later than
Tuesday.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
EFTA00017124


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=== Page 1 ===
JANE DOE #9
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
Ct. 13
2/05 -
EPSTEIN
Enticement of a minor to engage in
4/05
prostitution
JANE DOES #10
and #11
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 70
12/18/04
Conspiracy to entice a minor to
engage in prostitution
Ct. 14 (Jane
12/18/04
EPSTEIN
Enticement of a minor to engage in
Doe #11 only)
prostitution
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 1
JANE DOES #9-11
EFTA00016012


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: FW: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Date: Sat, 13 Jul 2019 18:33:11 +0000
Importance: Normal
We're even able to have the Office open at 8:00 a.m., which I understand is an option not available in some other districts
From:
Sent: Saturday, July 13, 2019 14:30
To: "Weingarten, Reid'
Cc:
>;
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
No problem - didn't take it as a slight, we all just have various travel and other case obligations in the near-term and want
to make sure somebody can be responsive at all times. And that also sounds helpful re: an agenda, we'll look out for that
tomorrow evening and be ready to chat on Monday at 8:00.
thanks,
From: Weingarten, Reid
Sent: Saturday, July 13, 2019 14:17
To:
Cc:
is
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Apologies to
and
was not meant as a slight assumed you would forward hopeless on a
computer. worse on a blackberry which I am using now. (will make best efforts to CC them on this
message) probably best I send a proposed informal agenda after I meet with the client tomorrow evening so I
don't get out over my skies reid
Sent from my BlackBerry 10 smartphone.
From:
)
Sent: Saturday, July 13, 2019 2:01 PM
To: Weingarten, Reid
Cc:
);
)
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Reid,
In our experience it's rarely a waste of time to talk, and we would be available on Monday morning. And we'll be in the
best position to be able to talk productively if you could give us a general sense of what you'd like to address?
Also, if you could please include
and
on any communications- know it's often convenient to just hit
reply but we want to make sure we're all in the loop since parts of the team will be more and less available at various
times if and when you reach out.
EFTA00014326

=== Page 2 ===
thanks,
From: Weingarten, Reid
Sent: Saturday, July 13, 2019 12:05
To:
)
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Will be with the client tomorrow evening till about 7 if you will be in your office then don't think it would be a
waste of time to talk about the state of play. if not I could stop by Monday morning around 8 reid
Sent from my BlackBerry 10 smartphone.
From:
)
Sent: Friday, July 12, 2019 5:40 PM
To:
Cc:
; 'Martin Weinberg'; Weingarten, Reid;
);
)
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
To the Chambers of Judge Berman:
With apologies for the delay, attached please find a courtesy copy of the Government's reply in support of its detention
memo and in opposition to the defendant's motion for bail, including exhibits, filed this afternoon in the above-captioned
case. Defense counsel is copied.
I hope everyone has a good weekend.
Thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00014327


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Filed version of Epstein papers
Date: Wed, 17 Jul 2019 13:42:37 +0000
Attachments: 2019.07.16_Defense_Letter.pdf; 23-1.pdf; 23.pdf
Are you referring to the papers filed yesterday? If so, they are attached. These are the publicly filed versions -if you want
our unredacted version of the submission, just let me know.
From:
(USANYS)
Sent: Wednesday, July 17, 2019 9:37 AM
To:
(USANYS)
Subject: Filed version of Epstein papers
Would you pls send me? Sorry if this is request for resend, but if you sent, I can't find it.
Thanks.
Deputy United States Attorney
United States Attorney's Office
Southern District of New York
Tel.:
EFTA00014481


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=== Page 1 ===
From:
To:
Subject: RE: GSA Meeting Attendees
Date: Mon, 01 Jul 2019 13:59:51 +0000
Importance: Normal
FYI. I have an appointment with my cardiologist that conflicts with this meeting and with the Epstein meeting. I have
already rescheduled this appointment a couple of times so I think that I need to keep this appointment.
What's the purpose of the GSA meeting?
From:
Sent: Monday, July 1, 2019 9:57 AM
To:
Subject: GSA Meeting Attendees
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00015566


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: Maxwell victim website
Date: Wed, 20 Oct 2021 22:36:23 +0000
Thanks!
From:
(USANYS)
Sent: Wednesday, October 20, 2021 5:45 PM
To:
(USANYS)
Cc:
is
Subject: RE: Maxwell victim website
Updated: United States V. Ghislaine Maxwell (justice.gov)
From:
(USANYS)
Sent: Wednesday, October 20, 2021 1:19 PM
To:
(USANYS)
Cc:
is
Subject: RE: Maxwell victim website
I added some language to the text below. I don't think there is a need to include the document unless that is what we
have been doing in this case. Thanks so much!
From:
(USANYS)
Sent: Wednesday, October 20, 2021 1:16 PM
To:
(USANYS)
Cc:
is
Subject: RE: Maxwell victim website
Sure think. Include the document as well or just the text?
From:
(USANYS)
Sent: Wednesday, October 20, 2021 1:13 PM
To:
(USANYS)
Cc:
is
Subject: Maxwell victim website
Hi Nick,
Judge Nathan issued the attached order regarding the teleconference set for tomorrow. Would you be able to update the
victim website with this info, please? Some proposed language below.
The Court will hold a telephone conference to discuss jury selection matters on October 21, 2021 at 12:00 p.m. Members
of the press and the public in the United States may access the live audio feed of the proceeding by calling 844-721-
EFTA00016959

=== Page 2 ===
7237 and using access code 9991787. Those outside of the United States may access the live audio feed by calling
409-207-6951 and using the same access code. Any photographing, recording, or rebroadcasting of federal court
proceedings is prohibited by law. Violation of these prohibitions may result in fines or sanctions, including monetary
fines, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by
the Court.
Thanks very much,
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:
EFTA00016960


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=== Page 1 ===
From:
S"S
Subject: DRAFT SDNY PRESS GUIDANCE FOR MONDAY, JULY 15, 2019
Date: Fri, 12 Jul 2019 20:37:19 +0000
Importance: Normal
Attachments: Jeffrey_Epstein_indictment_PR.pdf
Inline-Images: image001.png
Chiefs,
EFTA00015348

=== Page 2 ===
Below is Monday's draft guidance. Please review and let us know if we need to make any edits.
Thanks-and have a great weekend!!
The Press Office
DEPARTMENT QUI DOMINA JUSTITIA OF JUSTICE, *
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
PRESS GUIDANCE
Monday, July 15, 2019
PROCEEDINGS AND EVENTS
-
10:00 a.m. - Detention hearing in U.S. V. Jeffrey Epstein - the defendant is charged with sex trafficking of
minors and conspiracy to commit sex trafficking of minors - before Judge Berman (courtroom 17B, 500 Pearl
Street). A relevant press release is attached.
-
NIGHT DUTY OFFICER
Follow us on Facebook I Follow us on Twitter | SDNY website I YouTube
*** FOR PLANNING PURPOSES ONLY ***
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS
OFFICE AT
EFTA00015349


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
(USANYS)"
)"
Subject: Re: Epstein investigation
Date: Mon, 15 Jul 2019 18:48:33 +0000
Importance: Normal
Hey- we are scheduling a reverse proffer for
(I think
quick first read was that
might have
been arrested, but this is a different client, so wires crossed here).
Sent from my iPhone
On Jul 15, 2019, at 2:31 PM,
wrote:
Begin forwarded message:
From: Michael Bachner
Date: July 15, 2019 at 2:28:51 PM EDT
To:
)"
Cc:
)"
)"
Subject: Re: Epstein investigation
I was just notified that a client was arrested and is being arraigned in Queens County tomorrow on a
state RICO charge at about 11 or 1130. I'm concerned that the 330 may be cutting it close. It may be better to
do it at four or on Wednesday. Please advise
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you
EFTA00014508

=== Page 2 ===
are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-mail
and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax
advice.
On Jul 15, 2019, at 1:55 PM,
wrote:
Thanks very much. Let's plan for tomorrow at 3:30pm. You and
can come to our office at 1 St.
Andrews and just give security my name.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Original Message
From: Michael Bachner
Sent: Monday, July 15, 2019 1:42 PM
To:
)
Cc:
)
i
)
Subject: RE: Epstein investigation
Hi
Tomorrow or Wednesday at 11 or 3:30. Thursday any time after 11:30 to 4.
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
www.bhlawfirm.com
EFTA00014509

=== Page 3 ===
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally privileged. If
you are not the intended recipient, you are hereby notified that any retention, dissemination, distribution, or
copying of this communication is strictly prohibited. Please reply to the sender that you have received the
message in error and then delete it. Thank you.
Original Message
From:
)
[mailto:
Sent: Monday, July 15, 2019 12:50 PM
To: Michael Bachner
Cc:
)
Subject: Re: Epstein investigation
Hi Michael,
Apologies for the delay. Would you please let us know what times would work for you and
in the
next two or three days? We'll then figure out a time when we can all meet.
Thank you,
On Jul 11, 2019, at 10:43 PM, Michael Bachner
wrote:
Hello
6 o'clock is somewhat late. The client lives in
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
[X]
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential
information, which is intended only for use of recipient. If the reader of this communication is not the
intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or
tax advice.
On Jul 11, 2019, at 9:01 PM,
)
<mailto:
wrote:
Michael,
EFTA00014510

=== Page 4 ===
Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
<mailto:
From: Michael Bachner
Sent: Thursday, July 11, 2019 12:26 PM
To:
)
<mailto:
Cc:
)
<mailto:
)
<mailto:
Subject: Re: Epstein investigation
Regarding the reverse proffer, We are available next week from the 15-18. I have a 2 o'clock meeting in my
office on the 16th and 17th that should last an hour. So I can meet with you on those days at 11 or 1030 in
the morning if that works. Please let me know
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential
information, which is intended only for use of recipient. If the reader of this communication is not the
intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or
tax advice.
On Jul 10, 2019, at 11:20 AM, Michael Bachner
wrote:
EFTA00014511

=== Page 5 ===
Sure.
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York. NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential
information, which is intended only for use of recipient. If the reader of this communication is not the
intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or
tax advice.
On Jul 10, 2019, at 11:08 AM,
)
<mailto:
wrote:
Mike,
I think it would be useful to get a better understanding of your position-it would be helpful for us to know,
for example, how much time you propose to take to evaluate matters, and whether we can provide any
additional information that might be useful for that process of evaluation. That likely will affect our
determination regarding the grand jury appearance, at which we would expect, were we to call
to
ask her a number of questions we would expect to argue to the court do not implicate a fifth amendment
privilege-i.e., that she couldn't simply blanket invoke. Would it be useful to discuss via phone?
thanks,
Alex.
From: Michael Bachner
Sent: Wednesday, July 10, 2019 10:25
To:
<mailto:
Cc:
<mailto:
<mailto:
Subject: Re: Epstein investigation
Dear Counsel:
I met with
and I need time to evaluate matters. Regarding the subpoena to testify before the
Grand Jury on
we hereby notify you that if called as a witness
would invoke her Fifth
Amendment privilege against compelled self-incrimination. Please let me know if you will require her to
invoke in person or whether this communication suffices and no appertaining will be required.
Yours truly,
EFTA00014512

=== Page 6 ===
Michael Bachner
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD026.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential
information, which is intended only for use of recipient. If the reader of this communication is not the
intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or
tax advice.
On Jul 9, 2019, at 11:43 AM,
)
<mailto:
wrote:
Mr. Bachner,
Following up on our conversation earlier this morning, we wanted to provide you with the additional
information and materials we discussed. In the first instance, so that you have full contact info for the team,
please feel free to reach out to any of us at any time; we're all available via email or at the following phone
numbers:
Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in
Florida, and a blank version of our standard proffer agreement, both as discussed.
As we mentioned, please don't hesitate to reach out with any questions, and we look forward to setting a
time to speak again after you're able to confer with
thank you,
Assistant U.S. Attorney
Southern District of New York
<blank proffer agreement.pdf>
<Epstein NPA, dated 2007-09-24.pdf>
EFTA00014513


