# docs_fts_content

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=== Page 1 ===
From:
To:
Subject: Epstein
Date: Fri, 04 Apr 2008 17:20:14 +0000
Importance: Normal
Hi
- I am back. Just got a child molester to plead to 360 to life, so I am feeling good.
Wondering if you have heard anything from Drew and, if not, if you would mind if I drop an e-mail.
Strangely enough, neither Jay nor Ken has followed up on my e-mail to them.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
EFTA00013728


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=== Page 1 ===
From: "Acosta. Alex (USAFLS)" <AAcosta@usa.doi.gov>
To:
Subject: Read: Victim Notification in Epstein
Date: Tue, 08 Jul 2008 16:22:15 +0000
Importance: Normal
EFTA00013677


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: MCC
Date: Sat, 16 Nov 2019 03:55:20 +0000
Sounds like it.
Sent from my iPhone
> On Nov 15, 2019, at 8:53 PM,
(USANYS)
wrote:
>
> Yes, thanks. We think the union may be the source.
V
> Sent from my iPhone
V
>> On Nov 15, 2019, at 8:47 PM,
(USANYS)
wrote:
>>
>> No doubt you've seen that the NY Post has an article this evening headlined: "Epstein jail guards had been
offered plea deal but declined."
>>
Sent from my iPhone
EFTA00010303


c1: EFTA00013216
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c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013216.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
One Saint Andrew's Plaza
New York, New York 10007
October 2, 2020
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
In recognition of the Government's ongoing discovery obligations, today we are producing
copies of the materials listed in the below index, which materials are stamped with control numbers
SDNY_GM_000174967 through SDNY_GM_00328863. The password for the drive is
"USAOsdny1!". The materials are available for pickup at the U.S. Attorney's Office in Manhattan.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case.¹ This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 00174967
SDNY GM 00270985
Deutsche Bank records
Confidential
SDNY_GM_00270986;
SDNY_GM_00328863
JPMorgan Chase records
Confidential
SDNY GM 00323935
SDNY GM 00324015
GM Documents
1 Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format. Such files include in their electronic names the
word "Confidential."
06.20.2018
EFTA00013216

=== Page 2 ===
Page 2
SDNY GM 00324016
SDNY GM 00324036
Citibank records for Ghislaine Maxwell
UBS records for Angara Trust, Montepelier
Trust, Terramar Project, Inc., Max
Foundation, Ghislaine Maxwell, Ghislaine
SDNY GM 00324037
SDNY GM 00325754
Maxwell IRA, & Ellmax, LLC
SDNY_GM_00325755
SDNY_GM_00325761
LSJ Scene2Go
American Express records for Jeffrey
SDNY GM 00325762
SDNY GM 00328069
Epstein and Ghislaine Maxwell
Confidential
The Government is also reproducing to the defendant the files specified in Defense's
September 21, 2020 letter. In order to avoid further difficulties with respect to viewing the files,
the Government offers the following instructions:
1. Any .dat, .dvt, and .vol files can be opened and viewed by right-clicking on the file and
selecting "Edit with Notepad" or a similar text-viewing program.
2. Any video file can be opened with VLC, which has been included.
3. Accessory files (i.e. .dii, .ami, .cms, etc.) are to be ignored, as they serve no functional
purpose besides assisting in the operation of other (i.e. video) files.
4. Any previously flagged files that are not noted here have been converted to PDFs and/or
had their file paths shortened to enable viewing.
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials or if you wish to arrange a time to
review physical items in the FBI's custody.
Very truly yours,
by:
Assistant United States Attorneys
06.20.2018
EFTA00013217


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=== Page 1 ===
Terms of the Agreement:
1.
Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending against him in the 15th Judicial Circuit in and for
Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
one (1) count of solicitation of prostitution, in violation of Fl. Stat. §
796.07. In addition, Epstein shall plead guilty to an Information filed
by the State Attorney's Office charging Epstein with an offense that
requires him to register as a sex offender, that is, the solicitation of
minors to engage in prostitution, in violation of Florida Statutes Section
796.03;
2.
Epstein shall make a binding recommendation that the Court impose a
thirty (30) month sentence to be divided as follows:
(a)
Epstein shall be sentenced to consecutive terms of twelve (12)
months and six (6) months in county jail for all charges, without
any opportunity for withholding adjudication or sentencing, and
without probation or community control in lieu of
imprisonment; and
(b)
Epstein shall be sentenced to a term of twelve (12) months of
community control consecutive to his two terms in county jail
as described in Term 2(a), supra.
12.
Epstein agrees that he will not be afforded any benefits with respect to
gain time, other than the rights, opportunities, and benefits as any other
inmate, including but not limited to, cligibility for gain time credit
based on standard rules and regulations that apply in the State of
Florida. At the United States' request, Epstein agrees to provide an
accounting of the gain time he earned during his period of
incarceration.
EFTA00013912


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=== Page 1 ===
Case 9:08-cv-80119-KAM Document 24 Entered on FLSD Docket 07/17/2008 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA-JOHNSON
JANE DOE NO. 2,
Plaintiff,
VS.
JEFFREY EPSTEIN,
Defendant.
/
S.D. OF FLA - HIA
CLERK U.S. DIST.CT. DIST ST.
STEVEN M M. LARIMORE
08 JUL 10 PN12:20 PN 12: 20
A FILED 7
D.C.
FILED EX PARTE
UNDER SEAL
&
EFTA00013560

=== Page 2 ===
.Case 9:08-cv-80119-KAM Document 24 Entered on FLSD Docket 07/17/2008 Page 2 of 4
NOTICE OF CONTINUED PENDENCY
OF FEDERAL CRIMINAL ACTION
Defendant Jeffrey Epstein hereby notifies the Court of the continued
pendency of a federal criminal action against him, stating as follows:
On June 30, 2008, after defendant Jeffrey Epstein filed his motion to stay
[DE 12], he was sentenced in the state-court criminal case described in that motion
(State of Florida V. Jeffrey Epstein, Case No. 2006 CF 09454 AXX, Fifteenth
Judicial Circuit, Palm Beach County) (the "Florida Criminal Action"). As
explained below, the parallel federal criminal action against him described in that
motion (In re Grand Jury, No. FGJ 07-103(WPB), United States District Court for
the Southern District of Florida) (the "Federal Criminal Action"), remains pending.
On September 24, 2007, the United States Attorney's Office for the
Southern District of Florida ("USAO"), represented by Assistant United States
Attorney Ann Marie C. Villafana, Esq., and Mr. Epstein, entered into a deferred-
prosecution agreement ("Agreement"), which the parties agreed to keep
confidential. Prior to entering into that Agreement, Ms. Villafana advised that she
had already prepared a federal criminal indictment against Mr. Epstein in the
Federal Criminal Action.
Under the Agreement, beginning on the date Mr. Epstein began serving his
sentence in the Florida Criminal Action, the USAO agreed to suspend its grand
jury investigation in the Federal Criminal Action. The USAO, however, retains the
2
EFTA00013561

=== Page 3 ===
.Case 9:08-cv-80119-KAM Document 24 Entered on FLSD Docket 07/17/2008 Page 3 of 4
right to reactivate the grand jury and indict Mr. Epstein should he breach any part
of the Agreement during its term, which runs for 33 months, beginning on the date
Mr. Epstein began serving his sentence in the Florida Criminal Action.
Accordingly, the Federal Criminal Action will remain pending against Mr. Epstein
for 33 months from June 30, 2008.
Mr. Epstein will provide the Court with a copy of the confidential
Agreement for its in-camera inspection at the Court's request.
WHEREFORE, Defendant Jeffrey Epstein hereby notifies the Court of the
continued pendency of the Federal Criminal Action.
Respectfully submitted,
LEWIS TEIN, P.L.
3059 Grand Avenue, Suite 340
Coconut Grove, Florida 33133
Tel: 305 442 1101
Fax: 305 442 6744
By:
Uniqute;
GUY A. LEWIS
Fla Bar No 623740
MICHAEL R. TEIN
Fla. Bar No. 993522
3
EFTA00013562

=== Page 4 ===
Case 9:08-cv-80119-KAM Document 24 Entered on FLSD Docket 07/17/2008 Page 4 of 4
ATTERBURY, GOLDBERGER & WEISS, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, Florida 33401
Tel. 561 659 8300
Fax. 561 835 8691
By:
Jack A. Goldberger
Fla. Bar No. 262013
Attorneys for Defendant Jeffrey Epstein
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this motion, in accordance with S.D. Fla. L.R.
5.4, has not been served on opposing counsel and was filed under seal on July 10,
2008.
Uniture
Michael R. Tein
4
EFTA00013563


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Relativity access,
Date: Mon, 14 Jan 2019 15:57:03 +0000
Importance: Normal
Thanks,
From:
Sent: Monday, January 14, 2019 10:49 AM
To:
Cc:
Subject: RE: Relativity access,
Good Morning,
The documents have been uploaded to Relativity and are available for review. Please let me know if there are any
questions.
Thank you.
From:
Sent: Thursday, January 10, 2019 12:04 PM
To:
Cc:
Subject: RE: Relativity access,
We'd like to set up a Relativity database, please, for U.S. V. Epstein,
and to grant access to AUSAs
Currently the only documents we need to have uploaded are in the following folder:
EFTA00013438

=== Page 2 ===
USvEpstein-
Investigation\FBI materials (reports, FOIA,
etc)\ \2018-12-04, FBI Case File
We'd like the PDF files in the folder uploaded but NOT the files in the subfolder (titled "Files combined and manifest").
We also expect to be receiving a large amount of case files in the coming weeks, and so want to get up and running,
including agent access, so there's no delay once we receive the large batch of documents.
With respect to anticipate review process, it's possible that at some point we might receive materials that would
necessitate a privilege review, but not at this stage and not with respect to the materials in the linked folder.
Please let me know if any other information would be helpful, and thanks very much.
Assistant U.S. Attorney
Southern District of New York
EFTA00013439


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=== Page 1 ===
From:
To:
Cc:
Subject: RE:
: Yahoo Lifestyle - "Prince Harry Comments on Prince Andrew's
Friendship with Jeffrey Epstein in Prank Phone Call"
Date: Wed, 11 Mar 2020 23:04:47 +0000
This had Prince Andrew, Prince Harry and Megan Markel in the same story.
From:
Sent: Wednesday, March 11, 2020 7:03 PM
To:
Cc:
Subject: Re:
:
Yahoo Lifestyle - "Prince Harry Comments on Prince Andrew's Friendship with
Jeffrey Epstein in Prank Phone Call"
Nothing that I recall even comes close. For context, a really important WSJ or Times articles average about
$250-500k.
Sent from my iPhone
On Mar 11, 2020, at 6:48 PM,
wrote:
Has any other article come close to that? An estimated 231,333,672 readers.
From:
Sent: Wednesday, March 11, 2020 6:25 PM
To:
is
Subject: FW:
Yahoo Lifestyle - "Prince Harry Comments on Prince Andrew's Friendship with
Jeffrey Epstein in Prank Phone Call"
This article is estimated to have over $4M in publicity value. Insane.
From: Critical Mention <alert@criticalmention.com>
Sent: Wednesday, March 11, 2020 6:02 PM
To:
Subject:
: Yahoo Lifestyle - "Prince Harry Comments on Prince Andrew's Friendship with Jeffrey
Epstein in Prank Phone Call"
EFTA00009823

=== Page 2 ===
Critical Mention
You're always on it with Critical Mention.
new mention
Prince Harry Comments on Prince Andrew's Friendship with Jeffrey
Epstein in Prank Phone Call
Source Yahoo Lifestyle
Market United States
+ Add to Report
View More Mentions
Critical Mention allows users to search global TV, Radio, Online News & Social from the United States, Canada, and Europe, watch video, edit
and share coverage, receive real-time email alerts, build reports, and analyze coverage through word clouds and graphs.
To make changes to this alert, please login to Critical Mention
To stop receiving these alerts, click here to unsubscribe
completely separate from me and my wife We operate in a way of inclusivity and we are focusing on community
And so we are completely separate from the majority of my family. "Prince Harry's comments are also becoming
public as New York-based prosecutors is not cooperating with their investigation of Epstein and his associates.
Copyright c 2020 Critical Mention, All rights reserved.
"Prince Andrew has now completely shut the door Our mailing address ation, is: US Attorney for Manhattan, Geoffrey
S. Berman, said on Monday. He..
Critical Mention
521 5th Avenue
16th FI
New York, NY 10175
EFTA00009824


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=== Page 1 ===
Event: Accepted: Meet re: Epstein
Start Date: 2019-01-18 22:00:00 +0000
End Date: 2019-01-18 22:30:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-01-18 15:23:15 +0000
Date Modified: 2019-01-18 15:23:15 +0000
Priority: 5
DTSTAMP: 2019-01-18 14:56:33 +0000
EFTA00013444


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=== Page 1 ===
From:
To:
Subject: RE: epstein
Date: Tue, 10 Nov 2009 16:04:49 +0000
Importance: Normal
Next time you are here check the room to see if there is enough space.
From:
Sent: Tuesday, November 10, 2009 10:50 AM
To:
Subject: Re: epstein
It is a variety of stuff but I was hoping to store all of it in the locked gj room on 4 (that is where I had it locked up before it
went to 9).
From:
To:
Sent: Tue Nov 10 10:39:23 2009
Subject: epstein
The boxes on the 9th are they grand jury or just case files and info? When you asked about moving them, did
you mean to the room the grand jury transcripts are kept here on the 4th floor?
EFTA00013836


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=== Page 1 ===
From:
To:
Subject: Epstein
Date: Thu, 22 May 2008 21:14:36 +0000
Importance: Normal
Thank-you for your call Tuesday. It was great to hear from you. Any forward movement on this case at this point is good
news. Should there be any other developments or you need anything from us, please do not hestitate to give me a call. You
have my office number and my cell is
Thanks again for the update.
EFTA00013782


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
(USANYS)"
)"
)"
Subject: FW: letter referencing Ghislaine Maxwell
Date: Tue, 09 Nov 2021 14:06:33 +0000
Attachments:
@gmail.com - incoming.eml.pdf; 20210626_093804.jpg
could you please add this to NTW 3500? Thanks.
From:
(CRM)
@usdoj.gov>
Sent: Tuesday, November 9, 2021 7:33 AM
To:
is
is
is
is
(USANYS)
Subject: letter referencing Ghislaine Maxwell
Colleagues,
My office received the attached email as citizen correspondence. Because it references Jeffrey Epstein and
Ghislaine Maxwell, I am forwarding it to you for whatever consideration you deem appropriate. Consistent
with our standard response, we will simply advise the writer to contact the FBI. Please let me know if you have
any questions. Thanks very much,
Deputy Chief for Policy and Legislation
Child Exploitation and Obscenity Section
U.S. Department of Justice
(mobile)
EFTA00010130


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=== Page 1 ===
From:
"
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "
(USAFLS)"
Subject: Re: Epstein
Date: Tue, 13 Nov 2007 13:31:57 +0000
Importance: Normal
Hopefully I'll hear from Davis today.
Sent from my BlackBerry Wireless Handheld
Original Message
From:
(USAFLS)
To:
(USAFLS)
Sent: Tue Nov 13 08:12:41 2007
Subject: Epstein
Hi
- I am working on the response to Jay's letter. Do you know whether Judge Davis has selected a lawyer? If so, can
you let me know the person's name? I would like to include that in the response.
Thank you.
Assistant U.S. Attorney
Fax 561 820-8777
EFTA00013753


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=== Page 1 ===
From:
)"
To: "Berman, Geoffrey (USANYS)"
Subject: Accepted: Epstein Press Meeting
Date: Fri, 28 Jun 2019 15:09:08 +0000
Importance: Normal
Attachments: unnamed
EFTA00010580


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=== Page 1 ===
From:
"
\(USAFLS\)"
To:
\(USAFLS\)"
Cc:
"
\(USAFLS\)"
=
:
Subject: Draft Agreements
Date: Fri, 07 Sep 2007 00:07:13 +0000
Importance: Normal
Attachments: OLY_Plea_Agreement.wpd; OLY_Non-Prosecution_Agreement.wpd
Hi
- Here are the two agreements. I will be in early tomorrow morning if you need me to make any changes. Also,
you can see the video clip about Epstein's arrival in Palm Beach County at the following link:
http://www.wptv.com/default.aspx (Click on "Is Jeffrey Epstein making a deal?")
Perhaps he is attending the meeting tomorrow? Or there is a secret meeting with the State Attorney's office that we do not
know about?
Assistant U.S. Attorney
EFTA00013495


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=== Page 1 ===
From:
To:
Subject: Jeffrey Epstein: About the sex trafficking case & accusations I Miami Herald
Date: Fri, 30 Nov 2018 23:56:42 +0000
Importance: Normal
Are we open on this? Can we be?
https://www.miamiherald.com/news/local/article220097825.html
EFTA00009975


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=== Page 1 ===
From:
To: "Acosta, Alex (USAFLS)" <AAcosta@usa.doj.gov>,
Subject: Epstein
Date: Fri, 11 Apr 2008 16:04:49 +0000
Importance: Normal
Attachments: epstein_non-prosecution_agreement.pdf; epstein_12.19.07.pdf; epstein_addendum.pdf
EFTA00013679


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=== Page 1 ===
STATE
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 2, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
Enclosure
EFTA00013218


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=== Page 1 ===
From: Jack Goldberger
To:
Subject: RE: Notice of Non-Compliance
Date: Sat, 28 Jun 2008 19:38:23 +0000
Importance: Normal
not a problem.
From:
Sent: Sat 6/28/2008 11:31 AM
To: Jack Goldberger
Cc:
Subject: Re: Notice of Non-Compliance
Dear Jack:
I have conferred with a state court practitioner who stated that there is nothing that prohibits you from agreeing to a consecutive six-month
sentence of incarceration followed by one year of community control as specified in the non-prosecution agreement.
If you elect to proceed with the plea agreement as currently drafted, we ask that you insert the word "imprisoned" following the words "six
months" in the second sentencing paragraph.
Please confirm that this change is acceptable. Thank you.
Original Message
From: Jack Goldberger
A
To:
(USAFLS)
Cc: Jack Goldberger
Sent: Sat Jun 28 08:49:55 2008
Subject: RE: Notice of Non-Compliance
Dear Ms
please allow this e-mail to confirm our telephone conference of 6:30 pm on June 27 wherein we discussed the Epstein plea agreement and
we agreed that the Epstein state plea agreement was in compliance with the September 2007 non-prosecution agreement entered into
between Mr. Epstein and the USAO for the Souhern District of Florida.
Jack Goldberger
From:
Sent: Fri 6/27/2008 5:45 PM
To: Jack Goldberger; Roy BLACK
Cc
(USAFLS)
Subject: Notice of Non-Compliance
Dear Messrs. Goldberger and Black:
Please see the attached Notification Letter.
EFTA00014104

=== Page 2 ===
<<080627 Goldberger Black notification Itr.pdf>>
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
EFTA00014105


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=== Page 1 ===
From:
Subject: RE: Significant events next week?
Date: Fri, 11 Jan 2019 17:58:40 +0000
Importance: Normal
Hi
Next week, the team on our Jeffrey Epstein investigation (we can fill you in more at 3 pm) is traveling to Florida to meet
with the case agents on the original Epstein investigation and begin the process of collecting the hard copy files from that
investigation.
Not a prospective update, but today, Victor Casado, a former supervisory guard at the MCC, was sentenced to 36 months
for his role in smuggling contraband into the MCC for
in
exchange for tens of thousands of dollars in bribes.
Subject: RE: Significant events next week?
Same request. Hopefully soon l'll be in the loop enough that I won't have to ask this, but for the time being, please bear
with me. Thanks!
Subject: Significant events next week?
Just so I have a sense, can you shoot me an email about any significant events (pleas, sentencings, hearings, significant
meetings, etc.) that will be happening next week? I don't need detail - just a brief description of the event so it is on my
EFTA00013436

=== Page 2 ===
radar screen. Thanks.
EFTA00013437


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=== Page 1 ===
From:
To:
Subject: Read: Draft e-mail to Roy Black re Epstein
Date: Mon, 17 Nov 2008 14:10:02 +0000
Importance: Normal
EFTA00013844


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=== Page 1 ===
From:
To:
Cc:
Subject: Submitted Report: Case-Related Urgent: Major Development in a Significant Investigation or
Litigation
Date: Tue, 29 Jun 2021 17:18:52 +0000
Importance: Normal
Reporting District: SOUTHERN DISTRICT OF NEW YORK
Synopsis: USAO-SDNY's defense of the Bureau of Prisons ("BOP") in ongoing "FOIA" Litigation against NY
Times
Description:
SYNOPSIS:
In connection with USAO-SDNY's defense of the Bureau of Prisons ("BOP") in ongoing Freedom of
Information Act ("FOIA") litigation against The New York Times, on Friday, July 2, 2021, the USAO-
SDNY plans to release approximately 2,700 pages of BOP documents related to Jeffrey Epstein's
incarceration and suicide at the Metropolitan Correctional Center ("MCC"). These records were
previously withheld due to the ongoing criminal prosecution against Tova Noel and Michael Thomas
for falsifying records on the night of Epstein's suicide. As noted in UMR #2021-05-66021, USAO-
SDNY entered into deferred prosecution agreements with Noel and Thomas in May 2021 and as such,
USAO-SDNY no longer plans to assert a FOIA exception related to that criminal prosecution. The
BOP documents the USAO-SDNY plans to release to The New York Times, which will be immediately
available for publication by the Times, include: (i) internal BOP memoranda describing the events and
circumstances of Epstein's incarceration and suicide, including the numerous failures that allowed
Epstein the opportunity to kill himself; (ii) Epstein's psychological records from MCC; (iii) the autopsy
report prepared by the New York City Office of the Medical Examiner ("OCME"); and (iv) internal
emails within BOP and between BOP and USAO-SDNY from the day of Epstein's suicide reflecting
generally a lack of understanding of what had happened. USAO-SDNY has notified our counterparts
at the BOP and DOJ-OIG about the pending release.
DESCRIPTION:
On August 10, 2019, inmate Jeffrey Epstein committed suicide while housed in the Special Housing
Unit at the MCC. USAO-SDNY is currently defending the BOP in connection with ongoing FOIA
litigation filed by The New York Times seeking documents regarding Epstein. Previously, BOP had
withheld a number of documents based on the pendency of the criminal prosecution of Tova Noel and
Michael Thomas, the two guards on duty the night of Epstein's suicide who were accused of falsely
indicating on BOP forms that they had completed required institutional counts and rounds. As noted
in UMR # 2021-05-66021, in May 2021 USAO-SDNY entered into deferred prosecution agreements
with Noel and Thomas and as such, USAO-SDNY has notified the presiding Judge in the FOIA
EFTA00013391

=== Page 2 ===
litigation that BOP no longer plans to assert a FOIA exception related to that criminal prosecution.
Accordingly, pursuant to Court-ordered deadlines in the FOIA litigation, the USAO-SDNY must
produce the previously-withheld documents, which number approximately 2,700 pages, by July 2,
2021 to The New York Times, who will then be free to publish those materials.
The materials primarily consist of internal BOP memoranda, reports, emails, and documents, as well
as emails with USAO-SDNY, as well as the autopsy report prepared by OCME. As noted above, the
documents include the following topics and materials: (i) internal BOP memoranda from the day and
night of Epstein's suicide; (ii) a photograph of a sign that was hung in the Special Housing Unit that
stated that rounds on Epstein were mandatory, signed "God," which had been defaced to include a
question mark after "mandatory"; (iii) Epstein's psychological records at MCC, which generally show
that he claimed not to be suicidal, attempted to manipulate staff, and received some special treatment
at MCC; (iv) internal BOP memoranda evaluating the circumstances and failures that led to the
conditions in which Epstein could kill himself, including the failure to reassign a cellmate, to perform
counts or rounds, to ensure adequate staffing at MCC, and other failures at the institution; (v) emails
within BOP and between BOP and USAO-SDNY from the day of Epstein's suicide which show efforts
to find out what was happening at MCC and frustration that MCC was not providing information; (vi)
emails showing that Main Justice took an interest following Epstein's suicide, and sent individuals to
tour MCC; and (vii) the OCME autopsy report concluding that Epstein committed suicide by hanging.
Pursuant to established case law, BOP plans to redact photographs of Epstein's corpse and
photographs from the autopsy, as well as the names of AUSAs and lower-level BOP staff members.
As noted above, USAO-SDNY has notified our counterparts at the BOP and DOJ-OIG regarding this
pending release.
Report ID: 2021-06-67383
For Official Use Only (FOUO): The term used within DHS to identify unclassified information of a sensitive
nature, not otherwise categorized by statute or regulation, the unauthorized disclosure of which could adversely
impact a person's privacy or welfare, the conduct of Federal programs, or other programs or operations essential
to the national interest. Information impacting the National Security of the United States and classified
Confidential, Secret, or Top Secret under Executive Order 12958, "Classified National Security Information," as
amended, or its predecessor or successor orders, is not to be considered FOUO. FOUO is not to be considered
classified information. https://fas.org/sgp/othergov/dhs-sbu.html
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=== Page 1 ===
From:
To:
Cc:
)"
Subject: RE: travel approval request
Date: Tue, 22 Oct 2019 17:54:50 +0000
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and
we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
)
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
,
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
EFTA00010951

=== Page 2 ===
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
>
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
EFTA00010952

=== Page 3 ===
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
Subject: RE: Epstein Trust Analysis
Date: Thu, 30 Jan 2020 00:07:31 +0000
Ok. Thanks.
From:
Sent: Wednesday, January 29, 2020 7:07 PM
To:
Subject: RE: Epstein Trust Analysis
Please ignore this version, I will be circulating a revised version with some additional content tomorrow morning.
From:
Sent: Wednesday, January 29, 2020 5:51 PM
To:
Subject: Epstein Trust Analysis
Hi everyone,
I've attached a summary/analysis of the Epstein trust documents we received. This document incorporates the analysis of
the trusts from 2019 I did previously.
On the bottom, you'll see each trust has a tab and then further amendments to the trust (if any) go chronologically to the
right. There's also key and summary tabs at the beginning of the document.
Please let me know if you have any questions, or if you'd like me to walk you through how to use the document, in case it
isn't clear.
Thanks,
p.s. I wouldn't recommend printing the document, just due to the size of the excel tables.
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=== Page 1 ===
From: Sigrid McCawley
To:
)"
Subject: FW: GM VS. Estate
Date: Wed, 18 Mar 2020 15:32:08 +0000
Attachments: scan.pdf; ATT00001.ht
Hello
- I just received this from a reporter. It is an indemnification action filed in USVI by Maxwell. It contains
statements that are directly contradictory to Maxwell's previous sworn depositions including that Epstein was not
assisting in any of her legal bills and she didn't receive anything of value from him etc. and it also references
correspondence that she never produced in that case and lists companies that she was apparently employed by.
I am still reviewing but I wanted to get it to you quickly. Looks like ABC is doing a story on it.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
Fort Lauderdale, FL, 33301
(t)
(m)
www.bsfllp.com
From: Hill, James E. [mailto:
Sent: Wednesday, March 18, 2020 11:12 AM
To: Sigrid McCawley
Subject: GM VS. Estate
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
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=== Page 1 ===
Event: Meet on Epstein
Start Date: 2019-09-17 14:00:00 +0000
End Date: 2019-09-17 14:30:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2019-09-17 08:27:19 +0000
Date Modified: 2019-09-17 08:27:19 +0000
Priority: 5
DTSTAMP: 2019-09-17 00:47:22 +0000
Attendee:
(USANYS)
(USANYS)
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=== Page 1 ===
From: Chris Dilorio
To:
EFTA00011074

=== Page 2 ===
Subject: Apollo/ Epstein/Kushner connection
Date: Sat, 13 Apr 2019 17:30:57 +0000
Find a shell
Find a fraud
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0
Florida?
Pennsylvania?
or
Canada?
Welcomed on Cromwell/Wimpfheimer OTCM
De registered in 2015 and Frozen in time
Literally
http://eswgroup.com/esw-group-corporate/our-board/
Our Board - ESW Group®
MARK YUNG Mr. Yung is Co-Founder and Managing Principal of
OCV Management, LLC ("OCV"), an investor, owner and operator
of technology and life science companies based in Los Angeles.
Previously, Mr. Yung was a Managing Director at Orchard Capital
Corp., a firm he joined in 2006. Through his affiliation with [...]
eswgroup.com
Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al
Then,
There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?
The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
wait for it
Leon Black/Apollo Environmental Solutions Worldwide
https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
Enter the Amicus blocking release of Epstein docs
Krieger, Kim and Lewin
https://www.kllp.com/
Krieger Kim & Lewin LLP
EFTA00011075

=== Page 3 ===
We are committed to providing the highest level of partner-driven representation in order to efficiently
achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal
criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United
States Government.
www.kklllp.com
Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
Now,
it gets VERY interesting
https://www.cnbc.com/2018/02/28/apollo-citigroup-loaned-kushner-companies-millions-new-york-times.html
Trump: Kushner's security clearance is up to
Kelly
Kushner even discussed the possibility of a White House job for
the founder of private equity firm Apollo, the New York Times
reported on Tuesday.
www.cnbc.com
Where another Milken protégé/Apollo founding partner Josh Harris was considered for a White House job
"Coindences"
https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-company/
SEC dropped probe month after firm aided
Kushner company
The feds last year dropped an investigation into a financial
company a month after the firm gave Jared Kushner's family real
estate business a $180 million loan, a new report said Friday.
There
nypost.com
Oh, baby
$60 billion+ inflows in 2018 for Apollo
https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports-
Quarter-2018
EFTA00011076

=== Page 4 ===
Apollo Global Management, LLC Reports
Second Quarter 2018 Results
|
Business Wire
NEW YORK--(BUSINESS WIRE)--Apollo Global Management, LLC
(NYSE:APO) (together with its consolidated subsidiaries, "Apollo")
today reported results for the second quarter ended June 30,
2018.
www.businesswire.com
Mr's Krieger,Kim,Boltz et al:
Discovery will be a hoot!
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00011077


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=== Page 1 ===
From:
To: "Acosta, Alex (USAFLS)"
Subject: RE:
Date: Wed, 30 Jan 2008 18:42:11 +0000
Importance: Normal
Won't he be surprised when
isn't part of the indictment.
Assistant U.S. Attorney
Original Message
From: Acosta, Alex (USAFLS)
Sent: Wednesday, January 30, 2008 1:20 PM
To:
Subject: Fw:
Fyi.
Sent from my BlackBerry Wireless Handheld
Original Message
From: Jay Lefkowitz
To: Acosta, Alex (USAFLS)
Sent: Wed Jan 30 13:07:11 2008
Alex - I hope all is well. I miss not speaking to so
regularly, although I assume it means we are both able
to focus on some other matters.
I wanted to just give you a heads up. As you probably
saw in the papers, Jeff Sloman's former law firm
recently held a press conference to announce a 50
milion dollar civil lawsuit against Epstein. They
purportedly represent the father and stepmother of
In are light of this development, we
probably have no alternative but to go ahead and notice
deposition in accordance with state procedure in
the near future.
I am traveling today, but as you know, always
reachable.
Best regards,
Jay
The information contained in this communication is
confidential, may be attorney-client privileged, may
EFTA00013721

=== Page 2 ===
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
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=== Page 1 ===
From: Chris Dilorio
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Date: Wed, 15 May 2019 17:27:18 +0000
Attachments: IMG_7021.jpg
Inline-Images: image.png
Today (5/15/19) the grossly corrupt scumbags at the SEC approved ANOTHER massive fraud on the investing
public:
https://www.sec.gov/Archives/edgar/data/1665300/999999999519001111/xslEFFECTX01/primary_doc.xml
The "genius f'n quant" AQT/Greek shipping
/Economou/DRYS/ORIG/Astra/Nautilus/Navios/Gerber/AIPAC/Nordlicht/Glass/1MDB/Knitowski/Caneum/Trym
etris/Liquid etc etc etc money laundering shell.
Well done!
BTW, HOW is the George Economou/ Georgios EKONOMOU SEC "investigation" coming along anyway?
https://en.wikipedia.org/wiki/George_Economou_(shipbuilder)
EFTA00010710

=== Page 2 ===
George Economou (shipbuilder) - Wikipedia
George Economou or Georgios Ekonomou (Гешруюс Olkovójiou, born 1953) is a Greek billionaire
shipowner, CEO of DryShips Inc. and Ocean Rig, and the owner of Cardiff Marine.Economou owns oil
tankers as well as dry bulk ships and manages them through Cardiff Marine. He was on the Forbes
Magazines list of the world's billionaires on place 707.
en.wikipedia.org
What a coincidence:
https://www.vanityfair.com/nevs/2018/03/andrew-ekonomou-donald-trump-legal-team/amp
Trump's Last Line of Defense Against Mueller
Is an Obscure Medieval Historian
Andrew Ekonomou had a "mid-life crisis" and became an expert
on Byzantium. Now he's helping lead the president's legal team in
the Russia investigation.
www.vanityfair.com
Dude is DEFINITELY not getting the attention he deserves
Then again,
WHO actually believes Marc Bistricer of Toronto Canada was INVESTING in the $$$ laundering Ekonomou
shell known as DryShips?
https://seekingalpha.com/article/4096781-strong-court-case-dryships-kalani
Very Strong Court Case Against DryShips And
Kalani - DryShips Inc. (NASDAQ:DRYS)
I
Seeking Alpha - Stock Market Insights
|
Seeking Alpha
Source: rgrdlaw.com (court document) In 2012, DRYS generated
$1.23 billion in total revenue, yet posted a $246 million loss. In
fact, the company has been posting losses every year for the last
seekingalpha.com
"Charity not the motive"
https://www.tradewindsnews.com/legal/1738610/kalani-claims-charity-not-a-motive-for-dryships-aid
EFTA00010711

=== Page 3 ===
Kalani claims charity not a motive for DryShips
aid I TradeWinds
Kalani claims charity not a motive for DryShips aid Marc Bistricer-
led investment house says it had risk and profit in mind lending
to George Economou's struggling public company, not attempt to
www.tradewindsnews.com
The Toronto connection runs MUCH deeper though
The overlap with AQR blank check shells and Polar Asset Mgmt Toronto
The Toronto based Bistricer and EKONOMOU
Bistricers in New Jersey TOO!
AND
DAVID Bistricer happens to be a real estate developer
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001649096&owner=exclude&count=40&hidefilings=0
1 Bistricer/Clipper "investor"
Toronto based C I Investments
https://www.sec.gov/Archives/edgar/data/1649096/000116364819000009/0001163648-19-000009-index.htm
Check out this Reg D offering Bistricer/ Clipper did in Jan 2016
https://www.sec.gov/Archives/edgar/data/1649096/000161577416004014/xslFormDX01/primary_doc.xml
$130,000 Reg D offering for this Bistricer/Clipper publicly traded "real estate" company was done with an
Atlanta based firm called H&L Equities
Atlanta is home of the obscure Trump Russia Counsel Andrew EKONOMOU
Nothing to see here.
Of Course, then there's the Hail Mary pass Kushner threw on his Toronto based Brookfield deal for 666 5th
Avenue
https://www.thestar.com/news/world/2019/03/12/toronto-based-brookfield-faces-scrutiny-from-democrats-
over-deal-with-kushner-company.html
Toronto-based Brookfield faces scrutiny from
Democrats over deal with Kushner company
|
The Star
The real estate giant says politics were not at all involved in its
decision to acquire a New York office tower from the family of
Jared Kushner, President Donald Trump's son-in-law and senior
aide.
www.thestar.com
EFTA00010712

=== Page 4 ===
which was brokered by Apollo/Epstein Degenerate Black/Harris/Rowan
https://therealdeal.com/2018/11/15/brookfield-turns-to-apollo-for-666-fifth-financing/
666 Fifth | Brookfield | Apollo Global
Management
Private equity company Apollo Global Management is funding
Brookfield Property Partners' redevelopment of 666 Fifth Avenue
with a $300 million-plus mezzanine loan, sources told The Real
Deal
therealdeal.com
Apollo and other Kushner financing pal Blackstone just happen to be BOTH granted free reign on the US
insurance/annuity industry.
Crazy shit huh?
Greek shipping Bag man Georgios Ekonomou meets Jared Kushner
But it gets better still:
Stephen Feinberg: Cerberus
https://www.bloomberg.com/news/articles/2018-05-11/trump-chooses-cerberus-s-feinberg-to-lead-spy-
advisory-panel
Trump Chooses Cerberus's Stephen Feinberg
to Lead Spy Advisory Panel - Bloomberg
President Donald Trump has chosen billionaire investor Stephen
Feinberg to lead his intelligence advisory board, the White House
said Friday. Trump intends to appoint Feinberg, the co-founder
and
www.bloomberg.com
Bawag/Refco
Virtu first bid for Knight post "glitch"
and now: Money Laundering Bank HSH
Stephen Feinberg: Scum of the Earth meet Georgio EKONOMOU
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001369241&owner=exclude&count=40&hidefilings=0
Janey, IG update my various pending TCR's and complaints
Yours VERY TRULY
And INFINITELY smarter than anyone on this e mail list
Christopher J Dilorio
EFTA00010713

=== Page 5 ===
Whistleblower
From: Chris Dilorio
Sent: Monday, May 13, 2019 5:41 AM
To
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Saturday, May 11, 2019 8:00 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Monday, May 6, 2019 6:38 AM
Subject: Apollo/ Epstem/ kushner connection
Greetings grossly corrupt SEC et al scumbags
As with ALL of my allegations: beyond a shadow of a doubt, 100% accurate
https://www.sec.gov/litigation/complaints/comp17673.htm
Complaint: SEC V.
EFTA00010714

=== Page 6 ===
COMPLAINT. Plaintiff United States Securities and Exchange Commission ("Commission") alleges as
follows: SUMMARY. 1. This case involves a $15 million "pump and dump" scheme involving the securities
of Environmental Solutions Worldwide, Inc. ("Environmental"), a public company whose common stock is
registered with the Commission under the Securities Exchange Act of 1934 ("Exchange Act"), and is
www.sec.gov
ESWW was a money laundering shell.
The SEC knows it. The degenerate Epstein knows it. The Degenerate Leon Black/Kushner BFF/ Milken
proteges/Marc Rowan/Apollo knows it.
The DOJ/IRS knows it.
IG, I have repeatedly offered to come to SEC DC HQ to have the brightest minds at the SEC totally humiliate me
by refuting my allegations 1 by 1. The grossly corrupt SEC scumbags have never taken me up on my generous
offer. For the very simple reason that ALL of my allegations are accurate and true.
So, I again put the offer out there:
refute my claims OR go to jail for the criminal obstruction ACTIVELY being facilitated by your office and the SEC.
So, let's give these scumbags the insurance/annuities market.
This will NOT end well for tens of thousands of Americans.
Who "green lighted" this take over of the insurance industry by PE/Hedge funds?
https://www.forbes.com/sites/antoinegara/2018/02/01/apollo-and-blackstone-pick-insurance-as-their-next-
bet-to-disrupt-wall-street/#5d647dbe7689
Apollo And Blackstone Pick Insurance As Their
Next Bet To Disrupt Wall Street - Forbes
For decades, Wall Street's gambit in insurance was to write
policies and use the float as a source of capital for new
investments. It's a staple of Berkshire Hathaway and copycats like
Markel and
www.forbes.com
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 2, 2019 3:35 PM
EFTA00010715

=== Page 7 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
IG,
This was a blatant attempt to intimidate a whistleblower. "HE" (I think a male although very effeminate voice)
was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that.
This is a VERY serious matter. Felony. I intend to see "him" prosecuted to the fullest extent of the law. Within
weeks of filing a complaint against the SEC and you.
I obviously have hit a nerve.
https://www.nbcnews.com/politics/white-house/white-house-tells-official-who-gave-kushner-security-
clearance-don-n997476
White House whistleblower speaks out on
security clearance controversy
Carl Kline was supposed to appear before House committee staff
Tuesday to face questions related to his handling of White House
security clearances.
www.nbcnews.com
Cheers!
Christopher Diiorio (no L's scumbag)
From: Chris Dilorio
Sent: Thursday, April 25, 2019 6:27 AM
EFTA00010716

=== Page 8 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein
The SEC has known for years that Epstein is running a extortion/Ponzi/Slush Fund
My Claims AGAIN
https://seekingalpha.com/article/3715526-environmental-solutions-worldwide-revisiting-holding-gone-dark-
can-sleep-better-night?mod=mw_quote_news
Environmental Solutions Worldwide: Revisiting
A Holding That's Gone Dark, So I Can Sleep
Better At Night - Environmental Solutions
Worldwide, Inc. (OTCMKTS:ESWW) | Seeking
Alpha - Stock Market Insights I Seeking Alpha
New CEO and recent trading activity warranted a review of a
holding that no longer files. Based on the environment, difficult
y/y comparisons and results from competitors, 2015 is likely a
down year.
seekingalpha.com
"Not credible"???
How about the SEC's OWN words?
https://www.bloomberg.com/news/articles/2018-10-01/sec-spots-a-way-to-starve-the-most-suspicious-penny-
stocks
EFTA00010717

=== Page 9 ===
SEC Spots a Way to Starve the Most
Suspicious Penny Stocks - Bloomberg
"If a company is a dark company and listed in the OTC market
and hasn't put out financials for six months, maybe it shouldn't
be quoted or offered to retail investors," Redfearn said
www.bloomberg.com
See my comment letters on this subject.
The SEC INTENTIONALLY puts the investing public at risk of frauds like this and thousands others like it.
The core biz at NITE/VIRT,CDEL etc and the reason WHY the OTCM exists: Abusive naked shorting publicly
traded shells to facilitate money laundering.
Shells go dark only AFTER a massive fraud has been perpetrated on the investing public: Main Street
ANOTHER "genius" degenerate: Apollo
the grossly corrupt SEC: Bought and paid for by common criminals and degenerates
IG, I have time for that REQUIRED 3rd party cc today
Call me
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, April 14, 2019 1:04 PM
Subject: Pw.Apolo/Epsten/Kushner connection
A little Steffie Avakian//Heiss/O'Melveny/Wilmer Hale/ Apollo/Kushner Home Cooking!
https://www.omm.com/professionals/howard-e-heiss/
EFTA00010718

=== Page 10 ===
Howard E. Heiss - O'Melveny & Myers
Howard Heiss has an extensive litigation practice focused on
government regulatory investigations and enforcement actions,
grand-jury investigations, and the defense of clients in criminal
cases, with a particular emphasis on securities matters.
www.omm.com
https://www.sec.gov/Archives/edgar/data/1411494/000119312508077312/ds1.htm
Form S-1 - SEC.gov
Table of Contents. The information in this prospectus is not complete and may be changed. The securities
may not be sold until the registration statement filed with the Securities and Exchange Commission is
effective.
www.sec.gov
https://www.wilmerhale.com/en/people/jamie-gorelick
Jamie Gorelick | WilmerHale
Jamie Gorelick's career has spanned the legal, policy and corporate landscapes. As one of Washington's
best-known litigators, Ms. Gorelick has represented corporations and individuals in a wide array of matters,
particularly in the regulatory and enforcement arenas, involving issues as diverse as antitrust,
environmental regulation, securities enforcement, national security regulation, etc.
www.wilmerhale.com
https://www.wilmerhale.com/en/insights/news/former-director-of-the-fbi-robert-mueller-ii-joins-wilmerhale
Former Director of the FBI Robert Mueller III
Joins WilmerHale
WilmerHale is pleased to announce that Robert S. Mueller III is
joining the firm as a partner after serving as the sixth Director of
the Federal Bureau of Investigation (FBI), a position he took one
week prior to the September 11 attacks and held for 12 years
under two presidents.
www.wilmerhale.com
https://www.sec.gov/biography/avakian-stephanie
EFTA00010719

=== Page 11 ===
SEC.gov | Stephanie Avakian
Stephanie Avakian was named Co-Director of the U.S. Securities and Exchange Commission's Division of
Enforcement in June 2017, after serving as Acting Director since December 2016.
www.sec.gov
SEC drops Apollo investigation after Kush Jr met with Harris at the WH
and Apollo gives Kush's some $$$$
And, Apollo gets $60 bil+ in inflows in 2018
Did I miss something?
Cheers!
You corrupt fucking scumbags
Christopher Dilorio
From: Chris Dilorio
Sent: Saturday, April 13, 2019 11:30 AM
Subject: Apollo/Epstein/Kushner connection
Find a shell
Find a fraud
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0.
Florida?
Pennsylvania?
or
Canada?
EFTA00010720

=== Page 12 ===
Welcomed on Cromwell/Wimpfheimer OTCM
De registered in 2015 and Frozen in time
Literally
http://eswgroup.com/esw-group-corporate/our-board/
Our Board - ESW Group®
MARK YUNG Mr. Yung is Co-Founder and Managing Principal of
OCV Management, LLC ("OCV"), an investor, owner and operator
of technology and life science companies based in Los Angeles.
Previously, Mr. Yung was a Managing Director at Orchard Capital
Corp., a firm he joined in 2006. Through his affiliation with [...]
eswgroup.com
Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al
Then,
There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?
The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
wait for it
Leon Black/Apollo Environmental Solutions Worldwide
https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
Enter the Amicus blocking release of Epstein docs
Krieger, Kim and Lewin
https://www.kkllp.com/
Krieger Kim & Lewin LLP
We are committed to providing the highest level of partner-driven representation in order to efficiently
achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal
criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United
States Government.
www.kklllp.com
Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
Now,
it gets VERY interesting
https://www.cnbc.com/2018/02/28/apollo-citigroup-loaned-kushner-companies-millions-new-york-times.htm)
EFTA00010721

=== Page 13 ===
Trump: Kushner's security clearance is up to
Kelly
Kushner even discussed the possibility of a White House job for
the founder of private equity firm Apollo, the New York Times
reported on Tuesday.
www.cnbc.com
Where another Milken protégé/Apollo founding partner Josh Harris was considered for a White House job
"Coindences"
https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-company/
SEC dropped probe month after firm aided
Kushner company
The feds last year dropped an investigation into a financial
company a month after the firm gave Jared Kushner's family real
estate business a $180 million loan, a new report said Friday.
There
---
nypost.com
Oh, baby
$60 billion+ inflows in 2018 for Apollo
https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports
Quarter-2018
Apollo Global Management, LLC Reports
Second Quarter 2018 Results I Business Wire
NEW YORK--(BUSINESS WIRE)--Apollo Global Management, LLC
(NYSE:APO) (together with its consolidated subsidiaries, "Apollo")
today reported results for the second quarter ended June 30,
2018.
www.businesswire.com
Mr's Krieger,Kim,Boltz et al:
Discovery will be a hoot!
EFTA00010722

=== Page 14 ===
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00010723


c1: EFTA00013605
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013605.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Alan Dershowitz"
To:
Subject: From Alan Dershowitz
Date: Fri, 27 Mar 2009 15:59:26 +0000
Importance: Normal
Dear
Sorry I didn't get back to you sooner but I've been incredibly busy since I left paradise in Miami Beach. Just
argued an appeal in NY and debated the Mideast at Georgetown. I greatly appreciate your willingness to call the
sheriff and advise him that your office would take no position on how he handled Epstein's sentence as long as
he didn't get special treatment, but let's put any call off for a while. Thanks.
Alan
EFTA00013605


c1: EFTA00011531
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00011531.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department
Aviation Safety
of Transportation
Oklahoma City, Oklahoma 73125-0504
Federal Aviation
Toll Free:
Administration
WEB Address:
Date of Issue: July 22, 2021
N550GP LLC
ONTARIO, CA 91764-5496
Fax
ATTENTION: IATS
T216269
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N550GP GULFSTREAM AEROSPACE GV-SP (G550) Serial 5173 and is valid until Aug
21, 2021.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
for
Acting Manager, Aircraft Registration Branch
Federal Aviation Administration
REGAR-FAX-4 (02/21)
EFTA00011531

=== Page 2 ===
EFTA00011532

=== Page 3 ===
:
Return Ceriificate I.A.T of Registration to S
DECLARATION
of
PRIORITY
Accepted CF Jul/22/2021
INTERNATIONAL OPERATIONS
The undersigned owner of aircraft N 550GP , Manufacturer Gulfstream Accospace
Model GVSP
Serial Number 5173
declares that this aircraft is scheduled to make an international flight* on 7-25-2021.
(date)
as flight Number
departing Ontario California (KONT)
(City/State)
with a destination of
Naples Italy (LIRN)
(City/Country)
*[If required route between two points in the United States involves international navigation, explain under
Comments below, e.g. "partly over Canada" or "partly in international airspace".)
Expedited registration in support of this international flight is requested this
21st
day of July
2021 with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of the
Government of the United States, knowingly and willfully makes or uses any
false writing or document knowing the same to contain any materially false,
fictitious or fraudulent statement of representation shall be fined under Title 18
United States Code or imprisoned not more than 5 years, or both. 18 U.S.C.
$1001(a).
Name of Owner
N550GP, LLC
CAR COPY
Signature
Typed Name and Title of Signer
Manager
Phone:
Fax:
Comments:
*[If required route between two points in the United States involves international
navigation, explain under comments below, e.g. "partly over Canada" or "partly in
international airspace".]
Comments: Please fax the flying time wire to Insured Aircraft Title Service Inc. at
Filed by:
Insured Aircraft Title Service LLC
Phone
EFTA00011533

=== Page 4 ===
EFTA00011534
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2021 JUL 22 AM 8: 10
OKLAHOMA CITY
OKLAHOMA

=== Page 5 ===
ASSIGNMENT OF SPECIAL
Special Registration Number
REGISTRATION NUMBERS
N550GP
U.S. Department
Aircraft Make and Model
Present Registration Number
of Transportation
GULFSTREAM AEROSPACE GV-SP (G550)
N212JE
Federal Aviation
Serial Number
Issue Date:
Accepted CF Jul/22/2021
Administration
5173
Feb 24, 2021
ICAO AIRCRAFT ADDRESS CODE FOR N550GP 51600017
This is your authority to change
the United States registration
number on the above described
N550GP LLC
aircraft to the special
registration number shown
ONTARIO CA 91764-5496
Carry duplicate of this form in the
aircraft together with the
old registration certificate as
interim authority to operate the
aircraft pending receipt of revised
certificate of aircraft registration.
The latest FAA Form 8130-6,
Application For Airworthiness
on file is dated:
Mar 07, 2008
The airworthiness classification
and category:
STD TRANSP
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, Aircraft Registration Branch, within 5 days
after the special registration number is placed on the aircraft. A revised certificate of aircraft registration will then be issued.
Obtain a revised certificate of airworthiness from your nearest Flight Standards District Office.
The authority to use the special number expires: Feb 24, 2022
CERTIFICATION: I certify that the special registration number was placed
RETURN FORM TO:
on the aircraft described above.
Civil Aviation Registry
Aircraft Registration Branch
Signature of Owner:
Oklahoma City, Oklahoma 73125-0504
Title of Owner:
CHEF OFFICER
Date Placed on Aircraft: 3-19-2021
AC FORM 8050-64 (5/2005) Supersedes Previous Edition
Return Certificate of Registration to
I.A.T.S
EFTA00011535

=== Page 6 ===
EFTA00011536
FILED WITH FAA
AIRCRAFT
AIRCRAFT FILED WITHFAA
REGISTRATION BR
2021 JUL 20 AM 7 31
2021 MAR 26 AM 8: 32
OKLAHOMA OKLAHOMA CITY
OKLAHOMA CITY
OKLAHOMA
(

=== Page 7 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
FAA AIRCRAFT REGISTRY
Oklahoma City, Oklahoma 73125
AIRCRAFT SECURITY AGREEMENT
NAME & ADDRESS OF BORROWER:
N550GP, LLC
Ontario, CA 91764
NAME & ADDRESS OF SECURED PARTY/LENDER:
CF014762 Conveyance Recorded Aug/19/2021 10:20 AM FAA
Bank of Hope
Los Angeles, CA 90010
NAME & ADDRESS OF GRANTOR:
N550GP, LLC
,
ABOVE SPACE
Ontario, CA 91764
FOR FAA USE ONLY
1.
THIS AIRCRAFT SECURITY AGREEMENT dated May 11, 2021, is made
and executed by N550GP, LLC, a California limited liability company ("Grantor"), in favor of
Bank of Hope ("Lender").
2.
GRANT OF SECURITY INTEREST. For valuable consideration, Grantor
grants to Lender a continuing security interest in the Collateral to secure the Indebtedness and
agrees that Lender shall have the rights stated in this Agreement with respect to the Collateral, in
addition to all other rights which Lender may have by law.
3. COLLATERAL. The word "Collateral" as used in this Agreement means the
following described Airframe, Engines, and Contracts, as defined herein:
151821345.3
EFTA00011537

=== Page 8 ===
EFTA00011538
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2021 MAY 14 PM 1: 46
OKLAHOMA CITY
OKLAHOMA

=== Page 9 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
AIRCRAFT
SERIAL
FAA REGISTRATION
YEAR MFG
MANUFACTURER
MODEL NUMBER
NUMBER
NUMBER
2008
Gulfstream
GV-SP (aka
5173
N212JE (Pending
Aerospace
Gulfstream GV-SP
change to N550GP)
Corporation (aka
(G550) on the
GULFSTREAM on
International
the International
Registry drop down
Registry drop down
menu)
menu)
ENGINE
MODEL NUMBER(S)
SERIAL NUMBER(S)
MAKE
Rolls-Royce
BR700-710C4-11 (aka
15449
Deutschland
BR710 on the
Ltd & Co KG
International
(aka ROLLS
Registry drop down
ROYCE on the
menu)
International
Registry drop
down menu)
Rolls-Royce
BR700-710C4-11 (aka
15448
Deutschland
BR710 on the
Ltd & Co KG
International
(aka ROLLS
Registry drop down
ROYCE on the
menu)
International
Registry drop
down menu)
AUXILIARY
MODEL NUMBER
SERIAL NUMBER
POWER UNIT
MAKE
HONEYWELL
RE220
P-500
The word "Aircraft" also means and includes without limitation, (a) the Airframe, (b) the
Engines, (c) any propellers, and (d) related log books, manuals, diagrams and records.
The word "Airframe" means the Aircraft's airframe, together with any and all parts, appliances,
components, instruments, accessories, accessions, attachments, equipment, or avionics
(including, without limitation, radio, radar, navigation systems, or other electronic equipment)
installed in, appurtenant to, or delivered with or in respect of such airframe.
The word "Engines" means any engines described above together with any other aircraft engines
which either now or in the future are installed on, appurtenant to, or delivered with or in respect
of the Airframe, together with any and all parts, appliances, components, accessories, accessions,
attachments or equipment installed on, appurtenant to, or delivered with or in respect of such
engines. The word "Engines" shall also refer to any replacement aircraft engine which, under this
Agreement, is required or permitted to be installed upon the Airframe.
2
151821345.3
EFTA00011539

=== Page 10 ===
EFTA00011540

=== Page 11 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
The word "Contracts" means any and all agreements, contracts, service contracts, repair
contracts, maintenance contracts, including the Engine Maintenance Program, insurance contracts,
leases, purchase agreements, bills of sale and assignments, and any other instruments, contracts, or
agreements of any kind with respect to the Collateral.
4.
DURATION. This Agreement, including any representations, warranties and
covenants contained herein, shall remain continuing, in full force and effect until such time as
the Indebtedness secured hereby, including principal, interest, costs, expenses, attorneys' fees
and other fees and charges, shall have been paid in full, together with all additional sums that
Lender may pay or advance on Grantor's behalf and interest thereon as provided in this
Agreement.
5.
REPRESENTATIONS, WARRANTIES, AND COVENANTS. Grantor
represents, warrants and covenants to Lender at all times while this Agreement is in effect as
follows:
5.1
Title. Grantor warrants that Grantor is the lawful owner of the Collateral and
holds good and marketable title to the Collateral, free and clear of all
Encumbrances except the lien of this Agreement. Grantor is, or concurrent with
the completion of the transactions contemplated by this Agreement will be, the
registered owner of the Aircraft pursuant to a proper registration under the
Transportation Code, and Grantor qualifies in all respects as a citizen of the
United States as defined in the Transportation Code. If Grantor acquired its
interest in the Aircraft on or after the effective date of the Convention, the
ownership rights of Grantor shall be the subject of a valid and subsisting
registered contract of sale at the International Registry. Grantor shall defend
Lender's rights in the Collateral against the claims and demands of all other
persons. The Collateral is not and will not be registered under the laws of any
foreign country, and Grantor is and will remain a citizen of the United States as
defined in the Transportation Code.
5.2
Authority; Binding Effect, etc. Grantor is a limited liability company which is.
and at all times shall be, duly organized, validly existing, and in good standing
under and by virtue of the laws of the State of California. Grantor is duly
authorized to transact business in all other states in which Grantor is doing
business, having obtained all necessary filings, governmental licenses and
approvals for each state in which Grantor is doing business. Grantor has the full
right, power and authority to enter into the Note, the Related Documents, and this
Agreement and to grant a security interest in the Collateral to Lender. The Note,
the Related Documents, and this Agreement are binding upon Grantor as well as
Grantor's successors and assigns, and are legal, valid and binding obligations of
Grantor and are legally enforceable in accordance with their terms. Grantor's
principal place of business is
Ontario,
CA 91764, and unless Grantor has designated otherwise in writing, the Grantor's
principal place of business is the office at which Grantor keeps its complete logs,
manuals, books and records including its complete logs, manuals, books and
records concerning the Collateral. Grantor's exact legal name is: N550GP, LLC.
3
151821345.3
EFTA00011541

=== Page 12 ===
EFTA00011542

=== Page 13 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
Grantor has not used any trade, assumed or previous names within the past five
years. Grantor has not merged with or into, or transferred all or substantially all
of its assets to, any other entity within the past five years. Grantor was situated in
the United States, State of California at the time of the conclusion of this
Agreement. Grantor has the power to dispose of the Aircraft, as contemplated in
the Convention.
6.
Authorization. Grantor's execution, delivery, and performance of the Note, this
Agreement and all the Related Documents have been duly authorized by all necessary action by
Grantor and do not conflict with, result in a violation of, or constitute a default under (1) any
provision of Grantor's articles of organization or membership agreements, or bylaws or articles
of incorporation, or any agreement or other instrument binding upon Grantor or (2) any law,
governmental regulation, court decree, or order applicable to Grantor or to Grantor's properties.
7.
Litigation and Claims. No litigation, claim, investigation, administrative
proceeding or similar action (including those for unpaid taxes) against Grantor is pending or
threatened, and no other event has occurred which may materially adversely affect Grantor's
financial condition or properties, other than litigation, claims, or other events, if any, that have
been disclosed to and acknowledged by Lender in writing.
8.
Taxes. All of Grantor's tax returns and reports that are or were required to be
filed, have been filed, and all taxes, assessments and other governmental charges in connection
with the Aircraft and the Collateral have been paid in full, except those presently being or to be
contested by Grantor in good faith in the ordinary course of business and for which adequate
reserves have been provided.
9.
Information. All information heretofore or contemporaneously herewith
furnished by Grantor to Lender for the purposes of or in connection with this Agreement or any
transaction contemplated hereby (including without limitation the description of the Aircraft) is,
and all information hereafter furnished by or on behalf of Grantor to Lender will be, true and
accurate in every material respect on the date as of which such information is dated or certified;
and none of such information is or will be incomplete by omitting to state any material fact
necessary to make such information not misleading.
10. Aircraft and Log Books. Grantor will keep accurate and complete logs,
manuals, books, and records relating to the Collateral, and will provide Lender with copies of
such reports and information relating to the Collateral as Lender may reasonably require from
time to time.
11.
Airframe and Engines. The Airframe is type certified to transport at least eight
persons including crew, or goods in excess of 2750 kilograms and each of the Engines has at
least 1750 pounds of thrust or at least 550 rated take off shaft horsepower.
12.
Perfection of Security Interest. The security interest granted herein constitutes a
valid and subsisting International Interest in the Aircraft under the Convention. Grantor grants
and covenants to continue a first priority perfected security interest (including an International
Interest) in and to the Collateral in favor of Lender. Grantor agrees to prepare and file financing
4
151821345.3
EFTA00011543

=== Page 14 ===

=== Page 15 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
statements and to take whatever other actions are requested by Lender to perfect and continue
Lender's security interests in the Collateral. Upon request of Lender, Grantor will deliver to
Lender any and all of the documents evidencing or constituting the Collateral, and Grantor will
note Lender's interest upon any and all chattel paper if not delivered to Lender for possession by
Lender. In particular, Grantor will perform, or will cause to be performed, upon Lender's
request, each and all of the following: (1) record, register and file this Agreement (and the
IDERA, as defined below), together with such notices, financing statements or other documents
or instruments as Lender may request from time to time to carry out fully the intent of this
Agreement, with the FAA in Oklahoma City, Oklahoma, United States of America and other
governmental agencies, either concurrent with the delivery and acceptance of the Collateral or
promptly after the execution and delivery of this Agreement; (2) take all actions necessary to
initiate or consent to the registration of an International Interest in the Aircraft (or at Lender's
option, a Prospective International Interest) with the International Registry; (3) take all actions
necessary to initiate or consent to the registration of any other interests or rights pertaining to the
Collateral with the International Registry, as requested in the sole discretion of Lender; (4)
furnish to Lender evidence of every such recording, registering, and filing; and (5) execute and
deliver or perform any and all acts and things which may be reasonably requested by Lender
with respect to complying with or remaining subject to the Geneva Convention, the Convention,
the International Registry, the laws and regulations of the FAA, the laws of the United States and
the laws and regulation of any of the various states or countries in which the Collateral is or may
fly over, operate in, or become located in. Grantor hereby appoints Lender as Grantor's
irrevocable attorney-in-fact for the sole purposes of preparing, executing, and/or filing any
documents necessary to perfect, amend or to continue the security interests granted in this
Agreement or to demand termination of filings of other secured parties. Lender may at any time,
and without further authorization from Grantor, file a carbon, photographic or other reproduction
of any financing statement or of this Agreement for use as a financing statement. Grantor will
reimburse Lender for all expenses for the perfection and the continuation of the perfection of
Lender's security interest in the Collateral.
13. Convention Requirements. Prior to funding by Lender, (a) Grantor shall
establish a valid and existing account with the International Registry, appoint an Administrator
and/or a Professional User acceptable to Lender to initiate or consent to registrations at the
International Registry with regard to the Collateral, and initiate the registration of an
International Interest (or, at Lender's option, a Prospective International Interest) in the
Collateral, with all such steps being completed except for the consent of Lender, (b) Grantor's
initiation of such registration at the International Registry shall not have expired or lapsed; (c)
Grantor shall execute and Lender shall have received a fully completed and originally executed
Irrevocable De-Registration and Export Request Authorization ("IDERA"), in the form attached
hereto as Exhibit A and acceptable to the FAA and Lender, (d) Grantor shall execute and Lender
shall have received a fully completed and originally executed Irrevocable Power of Attorney In
Fact (Aircraft Registration), in the form attached hereto as Exhibit B and acceptable to the FAA
and Lender, and (e) Grantor's Contract of Sale shall be registered and searchable in the
International Registry.
14. Performance of Contracts. Grantor hereby undertakes to perform all of its
obligations under the Note, this Agreement, any Related Documents and any Contracts and to
5
1518213453
EFTA00011545

=== Page 16 ===
EFTA00011546

=== Page 17 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
procure the performance of third parties (other than Lender) under the Related Documents and
any Contracts.
15. Notices to Lender. Grantor will promptly notify Lender in writing at Lender's
address shown above (or such other addresses as Lender may designate from time to time) prior
to any (1) change in Grantor's name; (2) change in Grantor's assumed business name(s); (3) (if
Grantor is a business) change in the ownership of the Grantor or management of the Grantor; (4)
change in the authorized signer(s); (5) change in Grantor's principal office address; (6) change in
Grantor's state of organization; (7) conversion of Grantor to a new or different type of business
entity; (8) merger of Grantor with or into, transfer by Grantor of all or substantially all of its
assets to, or acquisition by Grantor of all or substantially all of the assets of, any other entity; or
(9) change in any other aspect of Grantor that directly or indirectly relates to any agreements
between Grantor and Lender. No change in Grantor's name or state of organization will take
effect until after Lender has received notice.
16. Location of the Collateral. Grantor will hangar or keep the Collateral at its
home airport or base location (the "Home Airport"), which is:
Chino Airport (CNO)
17.
Maintenance, Use, Repairs, Inspections, and Licenses. Grantor, at its expense,
shall do, or cause to be done, in a timely manner with respect to the Collateral each and all of the
following:
17.1 Grantor shall maintain and keep the Collateral in as good condition and repair as
it is on the date of this Agreement, ordinary wear and tear excepted.
17.2 Grantor shall maintain and keep the Aircraft in good order and repair and in
airworthy condition in accordance with the requirements of the FAA and each of
the manufacturers' manuals and mandatory service bulletins and each of the
manufacturers' non-mandatory service bulletins which relate to airworthiness, and
as recommended or required by any rules, regulations, or guidelines of the FAA
and/or the manufacturer.
17.3 Grantor shall replace in or on the Airframe, any and all Engines, parts, appliances,
instruments or accessories which may be worn out, lost, destroyed or otherwise
rendered unfit for use.
17.4 Grantor shall cause to be performed, on all parts of the Aircraft, all applicable
mandatory airworthiness directives, Federal Aviation Regulations, special Federal
Aviation Regulations, and manufacturers' service bulletins relating to
airworthiness, the compliance date of which shall occur while this Agreement is
in effect.
17.5 Grantor shall be responsible for all required inspections of the Aircraft and
licensing or re-licensing of the Aircraft in accordance with all applicable FAA and
other governmental requirements. Grantor shall at all times cause the Aircraft to
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EFTA00011548

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DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
have on board and in a conspicuous location a current Certificate of Airworthiness
issued by the FAA.
17.6 All inspections, maintenance, modifications, repairs, and overhauls of the Aircraft
(including those performed on the Airframe, the Engines or any components,
appliances, accessories, instruments, or equipment) shall be performed by
personnel authorized by the FAA to perform such services.
17.7 If any Engine, component, appliance, accessory, instrument, equipment or part of
the Aircraft shall reach such a condition as to require overhaul, repair or
replacement, for any cause whatever, in order to comply with the standards for
maintenance and other provisions set forth in this Agreement, Grantor may:
(a) Install on or in the Aircraft such items of substantially the same
type in temporary replacement of those then installed on the Aircraft, pending overhaul or repair
of the unsatisfactory item; provided, however, that such replacement items must be in such a
condition as to be permissible for use upon the Aircraft in accordance with the standards for
maintenance and other provisions set forth in this Agreement; provided further, however, that
Grantor at all times must retain unencumbered title to any and all items temporarily removed; or
(b) Install on or in the Aircraft such items of substantially the same
type and value in permanent replacement of those then installed on the Aircraft; provided,
however, that such replacement items must be in such condition as to be permissible for use
upon the Aircraft in accordance with the standards for maintenance and other provisions set forth
in this Agreement; provided further, however, that in the event Grantor shall be required or
permitted to install upon the Airframe or any Engine, components, appliances, accessories,
instruments, engines, equipment or parts in permanent replacement of those then installed on the
Airframe or such Engine, Grantor may do so provided that, in addition to any other requirements
of this Agreement:
(i)
Lender is not divested of its security interest in and lien
upon any item removed from the Aircraft and that no such removed item shall be or become
subject to the lien or claim of any person, unless and until such item is replaced by an item of the
type and condition required by this Agreement, title to which, upon its being installed or attached
to the Airframe, is validly vested in Grantor, free and clear of all liens and claims, of every kind
or nature, of all persons other than Lender;
(ii) Grantor's title to every substituted item shall immediately
be and become subject to the security interests and liens of Lender and each of the provisions of
this Agreement, and each such item shall remain so encumbered and so subject unless it is, in
turn, replaced by a substitute item in the manner permitted in this Agreement;
(iii) If an item is removed from the Aircraft and replaced in
accordance with the requirements of this Agreement, and if the substituted item satisfies the
requirements of this Agreement, including the terms and conditions above, then the item which
is removed shall thereupon be free and clear of the security interests and liens of Lender; and
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EFTA00011550

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DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
(iv) Such items are approved in writing by Lender in its sole
discretion.
17.8 In the event that any Engine, component, appliance, accessory, instrument,
equipment or part is installed upon the Airframe, and is not in substitution for or
in replacement of an existing item, such additional item shall be considered as an
accession to the Airframe.
17.9 If the Engines are enrolled in or become enrolled in an "Engine Maintenance
Program" at the time of loan application or anytime thereafter, Grantor represents,
warrants, and covenants that the Engines will continue to be enrolled in such
Engine Maintenance Program while this Agreement is in effect and until all
amounts owed to Lender are paid in full. "Engine Maintenance Program" means
the engine maintenance program provided by or similar to, but not limited to, any
of the following: AlliedSignal's MSP, Allison's Power by the Hour, CFE Corp's
CSP, Jet Support Services Inc.'s JSSI, Pratt & Whitney's ESP, Williams/Rolls'
PBH, Rolls Royce CorporateCare, and EMS.
17.10 If the auxiliary power unit ("APU") is enrolled in or becomes enrolled in a long-
term maintenance program at the time of loan application or anytime thereafter,
Grantor represents, warrants, and covenants that the APU will continue to be
enrolled in such maintenance program while this Agreement is in effect and until
all amounts owed to Lender are paid in full.
17.11 Grantor shall maintain all records, logs, and materials relating to the Aircraft
required by, and in accordance with, the FAA and its rules and regulations,
regardless of upon whom such requirements are, by their terms, normally
imposed.
17.12 The Aircraft shall be operated at all times by a currently certified pilot having the
minimum total pilot hours and pilot-in-command hours required by FAA rules or
regulations and applicable insurance policies.
17.13 Grantor shall use, operate, maintain, and store the Aircraft, and every part thereof,
carefully and in compliance with all applicable statutes, ordinances, and
regulations of all jurisdictions in which the Aircraft is used, and with all
applicable insurance policies, manufacturer's recommendations and operating and
maintenance manuals, including, without limitation, FAR 91, 121, or 135, as
applicable, and all applicable maintenance, service, repair and overhaul manuals
and service bulletins published by manufacturers of the Aircraft or of the
accessories, equipment and parts installed in the Aircraft.
18. Taxes, Assessments and Liens. Grantor will pay when due all taxes,
assessments and liens upon the Collateral, its use or operation, upon this Agreement, upon the
Note, or upon any of the other Related Documents. Grantor may withhold any such payment or
may elect to contest any lien if Grantor is in good faith conducting an appropriate proceeding to
contest the obligation to pay and so long as Lender's interest in the Collateral is not jeopardized
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=== Page 23 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
in Lender's sole opinion. If the Collateral is subjected to a lien which is not discharged within
thirty (30) days, Grantor shall deposit with Lender cash, a sufficient corporate surety bond or
other security satisfactory to Lender in an amount adequate to provide for the discharge of the
lien plus any interest, costs or other charges that could accrue as a result of foreclosure or sale of
the Collateral. In any contest Grantor shall defend itself and Lender and shall satisfy any final
adverse judgment before enforcement against the Collateral. Grantor shall name Lender as an
additional obligee under any surety bond furnished in the contest proceedings.
19. Compliance with Governmental Requirements. Grantor shall comply
promptly with all laws, ordinances and regulations of the FAA and all other governmental
authorities applicable to the use, operation, maintenance, overhauling or condition of the
Collateral. Grantor may contest in good faith any such law, ordinance or regulation and withhold
compliance during any proceeding, including appropriate appeals, so long as Lender's interest in
the Collateral, in Lender's opinion, is not jeopardized.
20. Maintenance of Insurance. Grantor shall procure and maintain at all times all
risks insurance on the Collateral, including without limitation, ground, taxiing and in flight
coverage, loss, damage, destruction, fire, theft, liability and hull insurance, and such other
insurance as Lender may require with respect to the Collateral, in form, amounts, coverages and
basis reasonably acceptable to Lender and issued by a company or companies reasonably
acceptable to Lender. Grantor shall further provide and maintain, at its sole cost and expense,
comprehensive public liability insurance, naming both Grantor and Lender as parties insured,
protecting against claims for bodily injury, death and/or property damage arising out of the use,
ownership, possession, operation and condition of the Aircraft, and further containing a broad
form contractual liability endorsement covering Grantor's obligations to indemnify Lender as
provided under this Agreement. Lender's other requirements for insurance as of the date of this
Agreement, subject to modification at Lender's reasonable discretion, include the following: (1)
the Borrower must be the named insured; (2) the policy must provide coverage to the engines
while removed from the Airframe; (3) unless otherwise consented to by Lender in writing, the
liability insurance policy must provide a minimum of $30 million liability coverage; (4) the all
risks policy must be for the greater of (a) the amount of the Indebtedness or (b) the full insurable
value of the Aircraft, and the basis must be the replacement value of the Aircraft; (5) the policy
must contain a Breach of Warranty Endorsement up to 90% of the policy; (6) coverage must be
maintained, in full force and effect, for the duration of the Note; (7) Bank of Hope (or its
assignee) must be named as lienholder and Loss Payee; (8) the policy must not prohibit the loss
payee from making insurance payments upon Grantor's failure to make payments or upon
Borrower's default; (9) the policy must include territorial limits; (10) the policy must include
coverage for possible seizure and/or impoundment, and/or war risk perils; (11) if the aircraft is to
be operated by a charter operator or is party to a lease agreement with a charter operator, and
Lender has consented to such use, the policy must include coverage for charter operation and for
spare parts (engines); and (12) the policy must provide for notification of the loss payees upon
termination of coverage. Such policies of insurance must also contain a provision, in form and
substance acceptable to Lender, prohibiting cancellation or the alteration of such insurance
without at least thirty (30) days' prior written notice to Lender of such intended cancellation or
alteration. Such insurance policies also shall include an endorsement providing that coverage in
favor of Lender will not be impaired in any way by any act, omission or default of Grantor or
any other person. Grantor agrees to provide Lender with originals or certified copies of such
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DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
policies of insurance. Grantor, upon request of Lender, will deliver to Lender from time to time
the policies or certificates of insurance in form satisfactory to Lender. In connection with all
policies covering assets in which Lender holds or is offered a security interest for the
Indebtedness, Grantor will provide Lender with such lender's loss payable or other endorsements
as Lender may require. Grantor shall not use or permit the Collateral to be used in any manner or
for any purpose excepted from or contrary to the requirements of any insurance policy or policies
required to be carried and maintained under this Agreement or for any purpose excepted or
exempted from or contrary to the insurance policies, nor shall Grantor do any other act or permit
anything to be done which could reasonably be expected to invalidate or limit any such insurance
policy or policies.
21. Failure to Provide Insurance. Grantor acknowledges and agrees that if Grantor
fails to provide any required insurance or fails to continue such insurance in force, Lender may
do so at Grantor's expense. The cost of any such insurance, at the option of Lender, shall be
added to the Indebtedness. Grantor acknowledges that if Lender so purchases any such
insurance, the insurance will provide limited protection against physical damage to the
Collateral, up to an amount equal to the unpaid balance of the debt. Grantor's equity in the
Collateral may not be insured. In addition, the insurance may not provide any public liability or
property damage indemnification and may not meet the requirements of any financial
responsibility laws.
22. Application of Insurance Proceeds. Grantor shall promptly (not to exceed
seven (7) days) notify Lender of any loss or damage to the Collateral in excess of $50,000,
whether or not such casualty or loss is covered by insurance. Lender may make proof of loss if
Grantor fails to do so within fifteen (15) days of the casualty. Lender shall have the right to
receive directly the proceeds of any insurance payable to Grantor on the Collateral; and the
insurance proceeds shall be paid directly to Lender. If Lender consents to repair or replacement
of the damaged or destroyed Collateral, Lender shall, upon satisfactory proof of expenditure, pay
or reimburse Grantor from the proceeds for the reasonable cost of repair or restoration. If Lender
does not consent to repair or replacement of the Collateral, Lender shall retain a sufficient
amount of the proceeds to pay all of the Indebtedness, and shall pay the balance to Grantor. Any
proceeds which have not been disbursed within six (6) months after their receipt and which
Grantor has not committed to the repair or restoration of the Collateral shall be used to prepay
the Indebtedness.
23. Insurance Reports. Grantor, upon request of Lender, shall furnish to Lender
reports on each existing policy of insurance showing such information as Lender may reasonably
request including, but not limited to, the following: (1) the name of the insurer; (2) the risks
insured; (3) the amount of the policy; (4) the property insured; (5) the then current value on the
basis of which insurance has been obtained and the manner of determining that value; and (6) the
expiration date of the policy. In addition, Grantor shall upon request by Lender (however not
more often than annually) have an independent appraiser satisfactory to Lender determine, as
applicable, the cash value or replacement cost of the Collateral.
24. Notice of Encumbrances and Events of Default. Grantor shall immediately
notify Lender in writing upon the filing of any attachment, lien, judicial process, or claim
relating to the Collateral. Grantor additionally agrees to immediately notify Lender in writing
10
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EFTA00011555

=== Page 26 ===

=== Page 27 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
upon the occurrence of any Event of Default, or event that with the passage of time, failure to
cure, or giving of notice, may result in an Event of Default under any of Grantor's obligations
that may be secured by any presently existing or future Encumbrance, or that may result in an
Encumbrance affecting the Collateral, or should the Collateral be seized or attached or levied
upon, or threatened by seizure or attachment or levy, by any person other than Lender.
25. Notices of Claims and Litigation. Grantor will promptly inform Lender in
writing of (1) all material adverse changes in Grantor's financial condition, (2) all existing and
all threatened litigation, claims, investigations, administrative proceedings or similar actions
affecting or concerning in any manner the Collateral, and (3) all existing and all threatened
litigation, claims, investigations, administrative proceedings or similar actions affecting or
concerning in any manner the Grantor or any Guarantor which could materially affect the
financial condition of Grantor or the financial condition of any Guarantor.
26. Inspection. Grantor shall permit employees or agents of Lender: (1) to inspect, at
Lender's cost, the Aircraft, Engines and APU once per year and thereafter as reasonably
requested by Lender; (2) to inspect all other Collateral (including the logs, books, manuals and
records comprising or related to the Collateral) for the Indebtedness, at any reasonable time, and
(3) to examine or audit Grantor's books, financial statements, accounts, and records and to make
copies and memoranda of Grantor's books, financial statements, accounts, and records, at any
reasonable time, upon reasonable notice to Grantor; provided, however, upon an Event of
Default, Lender may inspect any and all Collateral at any time, at Grantor's expense.
27. Compliance Certificates. Unless waived in writing by Lender, Grantor shall
provide Lender within forty-five (45) days after the end of the nine month period following the
Funding Date (the "Compliance Due Day") and within ninety (90) days annually of the
Compliance Due Day thereafter, with a certificate executed by Grantor's chief financial officer
and pilot, or other officer or person acceptable to Lender, certifying that or providing (a) the
representations and warranties set forth in this Agreement are true and correct as of the date of
the certificate; (b) as of the date of the certificate, no Event of Default exists under this
Agreement; (c) the Grantor has maintained and kept the Collateral in good order and repair and
in airworthy condition in accordance with the requirements of each of the manufacturers'
manuals and mandatory service bulletins and each of the manufacturers' non-mandatory service
bulletins which relate to airworthiness; (d) the Grantor has performed, on all parts of the
Collateral, all applicable mandatory airworthiness directives, and regulation of the Federal
Aviation Administration; (e) the total number of hours and landings on the Airframe; (f) the total
number of hours on the Engines since their last major overhaul or core; (g) verification that the
Engines are enrolled in an Engine Maintenance Program; (h) verification that the APU is
enrolled in a long-term maintenance program; and (i) the Engine serial numbers.
28. Additional Assurances. Grantor will make, execute and deliver to Lender such
promissory notes, mortgages, security agreements, assignments, financing statements,
instruments, documents and other agreements as Lender or its attorneys may reasonably request
to evidence and secure the Note and/or the Indebtedness.
29. Continuation. The foregoing representations and warranties, and all other
representations and warranties contained in the Note, the Related Documents, and this
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EFTA00011558

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DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
Agreement are and shall be continuing in nature and shall remain in full force and effect until
such time as the Note and all other obligations of Grantor to the Lender are paid in full and until
this Agreement is terminated or cancelled as provided herein.
30. PROHIBITIONS REGARDING COLLATERAL. Grantor represents,
warrants and covenants to Lender while this Agreement remains in effect as follows:
30.1 Transactions Involving Collateral. Without the prior written consent by
Lender, (i) Grantor shall not sell, offer to sell, or otherwise transfer or dispose of
the Collateral, and (ii) Grantor shall not lease, pledge, mortgage, encumber or
otherwise permit the Collateral to be subject to any lien, security interest,
encumbrance, or charge, other than the security interest provided for in this
Agreement. This includes security interests even if junior in right to the security
interests granted under this Agreement. Unless waived by Lender, all proceeds
from any disposition of the Collateral (for whatever reason) shall be held in trust
for Lender, and shall not be commingled with any other funds; provided however,
this requirement shall not constitute consent by Lender to any sale or other
disposition. Upon receipt, Grantor shall immediately deliver any such proceeds to
Lender.
30.2 No Commercial Use. Grantor shall use the Collateral solely for business
purposes. Grantor shall not, without prior written consent of Lender, use the
Collateral, or permit the Collateral to be used, in Commercial Operations, except
Grantor may operate the Collateral on a FAR Part 135 basis, provided the use is
covered by Grantor's insurance policy for the Collateral.
30.3 Removal of the Collateral. Except for routine use, Grantor shall not change the
Home Airport or remove the Collateral from the Home Airport without prior
written notice to Lender. Grantor shall, if an Event of Default has occurred, advise
Lender of the exact location of the Collateral upon Lender's request. Grantor
shall not base, or permit the Collateral to be based, outside the continental United
States of America.
30.4 Travel Restrictions. Grantor shall not operate or locate the Collateral, or permit
the Collateral to be operated, located, or flown (i) outside the continental United
States without war risk coverage, (ii) in or over any country for which the U.S.
State Department has issued travel restrictions (excluding any such travel
restriction made solely with respect to the spread of Covid-19), (iii) in or over any
country or jurisdiction that does not maintain full diplomatic relations with the
United States, (iv) in or over any area of hostilities, or (v) in or over any
geographic area not covered by the insurance then in effect. Without limiting the
foregoing, Grantor agrees that at no time during the effectiveness of this
Agreement shall the Collateral be operated in, flown over, or temporarily located
in any jurisdiction, unless the Geneva Convention, together with its necessary
enacting rules and regulations (or some comparable treaty and regulations
satisfactory to Lender) shall be in effect in such jurisdiction and any notices,
financing statements, documents, or instruments necessary or required, in the
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EFTA00011560

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DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
opinion of Lender, to be filed in such jurisdiction shall have been filed and file
stamped copies thereof shall have been furnished to Lender. Notwithstanding the
foregoing, at no time shall the Collateral be operated in or over any area which
may expose Lender to any penalty, fine, sanction or other liability, whether civil
or criminal, under any applicable law, rule, treaty or convention; nor may the
Collateral be used in any manner which is or may be declared to be illegal and
which may thereby render the Collateral liable to confiscation, seizure, detention
or destruction.
30.5 No Removal of Parts. Except as permitted or required in the section of this
Agreement titled "Maintenance, Use, Repairs, Inspections, and Licenses,"
Grantor shall not remove or permit the removal of any parts, engines, accessories,
avionics or equipment from the Aircraft without replacing the same with
comparable parts, engines, accessories, avionics and equipment acceptable to
Lender and the Aircraft's manufacturer and insurer.
30.6 Modifications. Grantor shall not, without the prior written consent of Lender,
modify the Aircraft in any material way, including but not limited to, the
Aircraft's function or operating capability.
31.
Future Encumbrances. Grantor shall not, without the prior written consent of
Lender, grant any Encumbrance that may affect the Collateral, or any part or parts thereof, nor
shall Grantor permit or consent to any Encumbrance attaching to or being filed against the
Collateral, or any part or parts thereof, in favor of anyone other than Lender. Grantor shall
further promptly pay when due all statements and charges of airport authorities, mechanics,
laborers, materialmen, suppliers and others incurred in connection with the use, operation,
storage, maintenance and repair of the Aircraft so that no Encumbrance may attach to or be filed
against the Aircraft or other Collateral. Grantor shall not file or register (or consent to the filing or
registration of) any International Interest, Contract of Sale, or subordination, whether prospective
or otherwise (or any amendment, assignment, modification, supplement, subordination or
subrogation thereof) pertaining to the Aircraft, with the FAA or the International Registry without
the prior written consent of Lender, which may be withheld in its sole discretion. Grantor shall not
execute or deliver an IDERA in favor of any party other than the Lender without the prior written
consent of Lender, which may be withheld in its sole discretion. Grantor additionally agrees to
obtain, upon request by Lender, and in form and substance as may then be satisfactory to Lender,
appropriate releases, terminations, discharges, waivers and/or subordinations of any
Encumbrances that may affect the Collateral at any time and, at Lender's option cause same to
be filed or registered with the FAA or International Registry as applicable.
32. GRANTOR'S RIGHT TO POSSESSION. Until an Event of Default, Grantor
shall have the possession and beneficial use of the Collateral and may use it in any lawful
manner not inconsistent with this Agreement or the Related Documents.
33. LENDER'S EXPENDITURES. If any action or proceeding is commenced that
would materially affect Lender's interest in the Collateral or if Grantor fails to comply with any
provision of this Agreement or any Related Documents, including but not limited to Grantor's
failure to discharge or pay when due any amounts Grantor is required to discharge or pay under
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EFTA00011562

=== Page 33 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
this Agreement or any Related Documents, Lender, on Grantor's behalf, may (but shall not be
obligated to) take any action that Lender deems appropriate, including but not limited to
discharging or paying all taxes, liens, security interests, International Interests, Contracts of Sale,
encumbrances and other claims (including the filing of any interest with the FAA or the
registration of any interest with the International Registry), at any time levied or placed on the
Collateral and paying all costs for inspecting, repairing, operating, insuring, maintaining and
preserving the Collateral. All such expenditures incurred or paid by Lender for such purposes
will then bear interest at the rate charged under the Note from the date incurred or paid by
Lender to the date of repayment by Grantor. All such expenses will become a part of the
Indebtedness and, at Lender's option, will (i) be payable on demand; (ii) be added to the balance
of the Note and be apportioned among and be payable with any installment payments to become
due during either (a) the terms of any applicable insurance policy; or (b) the remaining term of
the Note; or (iii) be treated as a balloon payment which will be due and payable at the Note's
maturity. This Agreement also will secure payment of these amounts. Such right shall be in
addition to all other rights and remedies to which Lender may be entitled upon an Event of
Default.
34.
DEFAULT. Each of the following shall constitute an Event of Default under this
Agreement:
34.1 Note Default. Any Event of Default under the Note or the Indebtedness.
34.2 Other Defaults. Grantor fails to comply with or to perform any other term,
obligation, covenant or condition contained in this Agreement, the Note, the
Indebtedness, or the Related Documents or to comply with or to perform any
term, obligation, covenant or condition contained in any other agreement between
Lender and Grantor.
34.3 Defective Collateralization. This Agreement, the Note, or any of the Related
Documents ceases to be in full force and effect (including failure of any collateral
document to create a valid and perfected first priority security interest or lien) at
any time and for any reason.
34.4 False Statements. Any warranty, representation or statement made or furnished
to Lender by Grantor or on Grantor's behalf under the Note, this Aircraft Security
Agreement, or the Related Documents is false or misleading in any material
respect, either now or at the time made or furnished or becomes false or
misleading at any time thereafter.
34.5 Death or Insolvency. The dissolution or termination of Grantor's existence
(regardless of whether election to continue is made), the death of Grantor (if
Grantor is an individual), the death of any member of Grantor or any member
withdraws from Grantor (if Grantor is a Limited Liability Company), or any other
termination of Grantor's existence as a going business, the insolvency of Grantor,
the appointment of a receiver for any part of Grantor's property, any assignment
for the benefit of creditors, any type of creditor workout, or the commencement of
any proceeding under any bankruptcy or insolvency laws by or against Grantor.
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34.6 Creditor or Forfeiture Proceedings. Commencement of foreclosure or
forfeiture proceedings, whether by judicial proceeding, self-help, repossession or
any other method, by any creditor of Grantor or by any governmental agency
against any collateral securing the loan. This includes a garnishment of any of
Grantor's accounts, including deposit accounts, with Lender. However, this Event
of Default shall not apply if there is a good faith dispute by Grantor as to the
validity or reasonableness of the claim which is the basis of the creditor or
forfeiture proceeding and if Grantor gives Lender written notice of the creditor or
forfeiture proceeding and deposits with Lender monies or a surety bond for the
creditor or forfeiture proceeding, in an amount determined by Lender, in its
reasonable discretion, as being an adequate reserve or bond for the dispute.
34.7 Events Affecting Guarantor. If a Guarantor(s) exists: Any of the preceding
events occurs with respect to any Guarantor, endorser, surety, or accommodation
party of any of the Indebtedness or any Guarantor, endorser, surety, or
accommodation party dies or becomes incompetent, or revokes or disputes the
validity of, or liability under, any Guaranty of the Indebtedness.
34.8 Change in Ownership or Management. If the Grantor is an entity (including
without limitation, a partnership, a limited partnership, a limited liability
company, or a corporation), any change in ownership or control of twenty-five
percent (25%) or more of the equity interests of Grantor or any change in the
management of Grantor, whether voluntary or involuntary or resulting from the
death of an owner or manager of the Grantor.
35. RIGHT TO CURE. If any Event of Default, other than a default on
Indebtedness, is curable and if Borrower or Grantor, as the case may be, has not been given a
notice of a similar Event of Default within the preceding twelve (12) months, it may be cured if
Borrower or Grantor, as the case may be, after Lender sends written notice to Borrower or
Grantor, as the case may be, demanding cure of such Event of Default: (1) cure the Event of
Default within fifteen (15) days; or (2) if the cure requires more than fifteen (15) days,
immediately initiate steps which Lender deems in Lender's sole discretion to be sufficient to cure
the Event of Default and thereafter continue and complete all reasonable and necessary steps
sufficient to produce compliance as soon as reasonably practical.
36. RIGHTS AND REMEDIES ON DEFAULT. If an Event of Default occurs
under this Agreement, at any time thereafter, Lender shall have all the rights of a secured party
under the Uniform Commercial Code and a creditor under the Convention, and Lender shall have
and may exercise any or all other rights and remedies it may have available at law, in equity, or
otherwise. In addition and without limitation, Lender may exercise any one or more of the
following rights and remedies:
36.1 Accelerate Indebtedness. Lender may declare the entire Indebtedness, including
any prepayment premium which Grantor would be required to pay, immediately
due and payable, without notice of any kind to Grantor.
15
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EFTA00011565

=== Page 36 ===
EFTA00011566

=== Page 37 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
36.2 Assemble Collateral. Lender may require Grantor to deliver to Lender all or any
portion of the Collateral and any and all certificates of title and other documents
relating to the Collateral. Lender may require Grantor to assemble the Collateral
and make it available to Lender at a place to be designated by Lender. Lender also
shall have full power to enter upon the property of Grantor to take possession of
and remove the Collateral. If the Collateral contains other goods not covered by
this Agreement at the time of repossession, Grantor agrees Lender may take such
other goods, provided that Lender makes reasonable efforts to return them to
Grantor after repossession.
36.3 Sale of the Collateral. Lender shall have full power to sell, lease, transfer, or
otherwise deal with the Collateral or proceeds thereof in Lender's own name or
that of Grantor. Lender may sell the Collateral at public auction or private sale.
Unless the Collateral threatens to decline speedily in value or is of a type
customarily sold on a recognized market, Lender will give Grantor, and other
persons as required by law, reasonable notice of the time and place of any public
sale, or the time after which any private sale or any other disposition of the
Collateral is to be made. However, no notice need be provided to any person who,
after Event of Default occurs, enters into and authenticates an agreement waiving
that person's right to notification of sale. The requirements of reasonable notice
shall be met if such notice is given at least ten (10) business days before the time
of the sale or disposition. All expenses relating to the disposition of the Collateral,
including without limitation the expenses of retaking, inspecting, repairing,
operating, holding, insuring, preparing for sale and selling the Collateral, shall
become a part of the Indebtedness secured by this Agreement and shall be payable
on demand, with interest at the Note rate from date of expenditure until repaid.
36.4 Appoint Receiver. Lender shall have the right to have a receiver appointed to
take possession of all or any part of the Collateral, with the power to protect and
preserve the Collateral, to operate the Collateral preceding foreclosure or sale, and
to collect the rents from the Collateral and apply the proceeds, over and above the
cost of the receivership, against the Indebtedness. The receiver may serve without
bond if permitted by law. Lender's right to the appointment of a receiver shall
exist whether or not the apparent value of the Collateral exceeds the Indebtedness
by a substantial amount. Employment by Lender shall not disqualify a person
from serving as a receiver.
36.5 Obtain Deficiency. If Lender chooses to sell any or all of the Collateral, Lender
may obtain a judgment against Grantor for any deficiency remaining on the
Indebtedness due to Lender after application of all amounts received from the
exercise of the rights provided in this Agreement.
36.6 Election of Remedies. Except as may be prohibited by applicable law, all of
Lender's rights and remedies, whether evidenced by this Agreement, the Related
Documents, or by any other writing, shall be cumulative and may be exercised
singularly or concurrently. Election by Lender to pursue any remedy shall not
exclude pursuit of any other remedy, and an election to make expenditures or to
16
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EFTA00011567

=== Page 38 ===
EFTA00011568

=== Page 39 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
take action to perform an obligation of Grantor under this Agreement, after
Grantor's failure to perform, shall not affect Lender's right to declare a default
and exercise its remedies.
36.7 Convention Remedies. In addition to the remedies previously set forth in this
Agreement, Lender has all remedies available to a creditor under the Convention
(and Grantor affirmatively agrees that Lender has all the rights and remedies, and
can exercise all of the rights and remedies, granted a creditor under the
Convention), including but not limited to (a) if Grantor is in possession, custody
or control of the Collateral, Lender may enter Grantor's or any other person's
premises and take possession of such Collateral; (b) to require Grantor to
assemble and make available such Collateral at a location selected by Lender; (c)
to sell, lease or otherwise dispose or cause the Grantor to sell, lease or otherwise
dispose of the Collateral; (d) collect or receive any income, rents or profits arising
from the management or use of the Collateral; and (e) procure the deregistration
of the registration of the Aircraft and export of the Aircraft to a jurisdiction of
Lender's choice pursuant to the IDERA.
37.
INDEMNIFICATION OF LENDER. Grantor agrees to indemnify, to defend
and to save and hold Lender harmless from any and all claims, suits, obligations, damages,
losses, costs and expenses (including, without limitation, Lender's reasonable attorneys' fees),
demands, liabilities, penalties, fines and forfeitures of any nature whatsoever that may be
asserted against or incurred by Lender, its officers, directors, employees, and agents arising out
of, relating to, or in any manner occasioned by this Agreement and the exercise of the rights and
remedies granted Lender under this Agreement, except in the case of any such claims, losses, or
expenses arising out of Lender's gross negligence or willful misconduct. The foregoing
indemnity provisions shall survive the cancellation of this Agreement as to all matters arising or
accruing prior to such cancellation and the foregoing indemnity shall survive in the event that
Lender elects to exercise any of the remedies as provided under this Agreement following an
Event of Default hereunder.
38.
MISCELLANEOUS PROVISIONS. The following miscellaneous provisions
are a part of this Agreement:
38.1 Assignment. Lender may transfer or assign all or any part of its interest in this
Agreement, together with any Related Documents, and Grantor hereby consents
to any and all assignments or sales of, or the granting of participations in, this
Agreement and any Related Documents, by Lender and any purchaser or assignee
of any interest in this Agreement and any Related Documents. Grantor shall not
sell, assign, transfer, encumber or convey any of its interests in the Collateral or in
this Agreement or any Related Documents, without the prior written consent of
Lender, which may be withheld in its sole discretion.
38.2 Amendments. This Agreement, together with any Related Documents,
constitutes the entire understanding and agreement of the parties as to the matters
set forth in this Agreement. No alteration of or amendment to this Agreement
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EFTA00011569

=== Page 40 ===
EFTA00011570

=== Page 41 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
shall be effective unless given in writing and signed by the party or parties sought
to be charged or bound by the alteration or amendment.
38.3 Anti-Money Laundering/International Trade Law Compliance. The
Borrower represents and warrants to the Lender, as of the date of this Agreement,
the date of each advance of proceeds under the Note, the date of any renewal,
extension or modification of the Note, and at all times until the Note has been
terminated and all amounts thereunder have been indefeasibly paid in full, that:
(a) no Covered Entity (i) is a Sanctioned Person; (ii) has any of its assets in a
Sanctioned Country or in the possession, custody or control of a Sanctioned
Person; or (iii) does business in or with, or derives any of its operating income
from investments in or transactions with, any Sanctioned Country or Sanctioned
Person in violation of any law, regulation, order or directive enforced by any
Compliance Authority; (b) the proceeds of the Note will not be used to fund any
operations in, finance any investments or activities in, or, make any payments to,
a Sanctioned Country or Sanctioned Person in violation of any law, regulation,
order or directive enforced by any Compliance Authority; (c) the funds used to
repay the Note are not derived from any unlawful activity; and (d) each Covered
Entity is in compliance with, and no Covered Entity engages in any dealings or
transactions prohibited by, any laws of the United States, including but not limited
to any Anti-Terrorism Laws. Borrower covenants and agrees that it shall
immediately notify the Lender in writing upon the occurrence of a Reportable
Compliance Event. As used herein: "Anti-Terrorism Laws" means any laws
relating to terrorism, trade sanctions programs and embargoes, import/export
licensing, money laundering, or bribery, all as amended, supplemented or
replaced from time to time; "Compliance Authority" means each and all of the (a)
U.S. Treasury Department/Office of Foreign Assets Control, (b) U.S. Treasury
Department/Financial Crimes Enforcement Network, (c) U.S. State
Department/Directorate of Defense Trade Controls, (d) U.S. Commerce
Department/Bureau of Industry and Security, (e) U.S. Internal Revenue Service,
(f) U.S. Justice Department, and (g) U.S. Securities and Exchange Commission;
"Covered Entity" means the Borrower, its affiliates and subsidiaries, all
guarantors, pledgors of collateral, all owners of the foregoing, and all brokers or
other agents of the Borrower acting in any capacity in connection with the Note;
"Reportable Compliance Event" means that any Covered Entity becomes a
Sanctioned Person, or is indicted, arraigned, investigated or custodially detained,
or receives an inquiry from regulatory or law enforcement officials, in connection
with any Anti-Terrorism Law or any predicate crime to any Anti-Terrorism Law,
or self-discovers facts or circumstances implicating any aspect of its operations
with the actual or possible violation of any Anti-Terrorism Law; "Sanctioned
Country" means a country subject to a sanctions program maintained by any
Compliance Authority; and "Sanctioned Person" means any individual person,
group, regime, entity or thing listed or otherwise recognized as a specially
designated, prohibited, sanctioned or debarred person or entity, or subject to any
limitations or prohibitions (including but not limited to the blocking of property or
rejection of transactions), under any order or directive of any Compliance
18.
151821345.3
EFTA00011571

=== Page 42 ===
EFTA00011572

=== Page 43 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
Authority or otherwise subject to, or specially designated under, any sanctions
program maintained by any Compliance Authority.
38.4 Caption Headings. Caption headings in this Agreement are for convenience
purposes only and are not to be used to interpret or define the provisions of this
Agreement.
38.5 Governing Law and Jurisdiction. The Note, this Aircraft Security Agreement,
and the Related Documents have been delivered to Lender and accepted by
Lender in the State of California. The Note, this Aircraft Security Agreement,
and the Related Documents will be governed by, construed and enforced in
accordance with federal laws and the laws of the State of California. If there is a
lawsuit, Grantor consents to the jurisdiction of all state and federal courts located
within Los Angeles County, State of California, and Grantor agrees upon
Lender's request to submit to the jurisdiction of the courts of Los Angeles
County, State of California.
38.6 Notices. Any notice required to be given under the Note, the Related Documents,
or this Agreement shall be given in writing, and shall be effective when actually
delivered, when actually received by telefacsimile (unless otherwise required by
law), when deposited with a nationally recognized overnight courier, or, if mailed,
when deposited in the United States mail, as first class, certified or registered mail
postage prepaid, directed to the addresses shown near the beginning of this
Agreement. For notice purposes, Grantor agrees to keep Lender informed at all
times of Grantor's current address. Unless otherwise provided or required by law,
if there is more than one Grantor, any notice given by Lender to any Grantor is
deemed to be notice given to all Grantors.
38.7 Severability. If a court of competent jurisdiction finds any provision of the Note,
the Related Documents, or this Agreement to be illegal, invalid, or unenforceable
as to any circumstance, that finding shall not make the offending provision illegal,
invalid, or unenforceable as to any other circumstance. If feasible, the offending
provision shall be considered modified so that it becomes legal, valid and
enforceable. If the offending provision cannot be so modified, it shall be
considered deleted from the Note, the Related Documents, or this Agreement.
Unless otherwise required by law, the illegality, invalidity, or unenforceability of
any provision of the Note, the Related Documents, or this Agreement shall not
affect the legality, validity or enforceability of any other provision of the Note,
the Related Documents, or this Agreement.
38.8 Successors and Assigns. Subject to any limitations stated in the Note, the
Related Documents, or this Agreement, on transfer of Grantor's interest, the Note,
the Related Documents, and this Agreement shall be binding upon and inure to
the benefit of the parties, their successors and assigns. If ownership of the
Collateral becomes vested in a person other than Grantor, Lender, without notice
to Grantor, may deal with Grantor's successors with reference to this Agreement
and the Indebtedness by way of forbearance or extension without releasing
19
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EFTA00011573

=== Page 44 ===
EFTA00011574

=== Page 45 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
Grantor from the obligations and liabilities of the Note, the Related Documents or
this Agreement.
38.9 Survival of Representations and Warranties. All representations, warranties,
and agreements made by Grantor in this Agreement, the Note, and the Related
Documents shall survive the execution and delivery of this Agreement, the Note,
and the Related Documents, and shall be continuing in nature, and shall remain in
full force and effect until such time as Grantor's Indebtedness shall be paid in full.
38.10 No Waiver by Lender. Lender shall not be deemed to have waived any rights
under the Note, the Related Documents, or this Agreement unless such waiver is
given in writing and signed by Lender. No delay or omission on the part of
Lender in exercising any rights under the Note, the Related Documents, or this
Agreement shall operate as a waiver of such right or any other right. A waiver by
Lender of a provision of the Note, the Related Documents, or this Agreement
shall not prejudice or constitute a waiver of Lender's right otherwise to demand
strict compliance with that provision or any other provision of the Note, the
Related Documents, or this Agreement. No prior waiver by Lender, nor any
course of dealing between Lender and Grantor, shall constitute a waiver of any of
Lender's rights or of any of Grantor's obligations as to any future transactions.
Whenever the consent of Lender is required under the Note, the Related
Documents or this Agreement, the granting of such consent by Lender in any
instance shall not constitute continuing consent to subsequent instances where
such consent is required and in all cases such consent may be granted or withheld
in the sole discretion of Lender.
38.11 Waive Jury. All parties to this Agreement hereby waive the right to any jury trial
in any action, proceeding, or counterclaim brought by any party against any other
party.
39.
DEFINITIONS. The following capitalized words and terms shall have the
following meanings when used in this Agreement, the Note, and any Related Documents. Unless
specifically stated to the contrary, all references to dollar amounts shall mean amounts in lawful
money of the United States of America. Words and terms used in the singular shall include the
plural, and the plural shall include the singular, as the context may require. Words and terms not
otherwise defined in this Agreement shall have the meanings attributed to such terms in the
United States Code and Regulations thereunder dealing with or involving Aircraft, commercial
instruments relating to such Aircraft, and in the Uniform Commercial Code:
39.1 Agreement. The word "Agreement" means this Aircraft Security Agreement, as
this Aircraft Security Agreement may be amended or modified from time to time,
together with all exhibits and schedules attached to this Aircraft Security
Agreement from time to time.
39.2 Aircraft and Business Loan Agreement. The words "Aircraft and Business
Loan Agreement" mean that certain Aircraft and Business Loan Agreement dated
as of May 11, 2021, by and between Lender and Borrower.
20
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EFTA00011575

=== Page 46 ===

=== Page 47 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
39.3 Borrower. The word "Borrower" means N550GP, LLC.
39.4 Collateral. The word "Collateral" means (1) all of Grantor's right, title and
interest in and to all the Collateral as described in the Collateral section of this
Agreement, and (2) all other property and assets granted as security for the Note,
whether real or personal property, whether granted directly or indirectly, whether
granted now or in the future, and whether granted in the form of a security
interest, assignment, pledge, chattel mortgage, trust receipt, lien, or any other
security or lien interest whatsoever, whether created by law, contract, or
otherwise.
39.5 Commercial Operations. The words "Commercial Operations" mean the
carriage by aircraft in air commerce of persons or property for compensation or
hire. Commercial Operations do not include carriage by aircraft in air commerce
of Grantor's employees or invitees or Grantor's own property.
39.6 Consolidated Text. The words "Consolidated Text" mean the combination of
the Convention and Protocol that was authorized pursuant to Resolution No. I
adopted by the Cape Town Diplomatic Conference.
39.7 Convention. The word "Convention" means the Convention on International
Interests in Mobile Equipment, and the Protocol to the Convention on
International Interests in Mobile Equipment on Matters Specific to Aircraft
Equipment, both signed in Cape Town, South Africa on November 16, 2001, as
ratified by the United States, together with the Regulations for the International
Registry and the International Registry Procedures, and all other rules,
modifications, amendments, supplements, and revisions thereto.
39.8 Encumbrance. The word "Encumbrance" means any and all presently existing
or future mortgages, liens, privileges, International Interest and other contractual
and statutory security interests and rights, of every nature and kind, whether in
admiralty, at law, or in equity, that now and/or in the future may affect the
Collateral or any part or parts thereof.
39.9 Event of Default. The words "Event of Default," "Default" or "default" mean
any of the events of default set forth in this Agreement, the Aircraft and Business
Loan Agreement, or the Note in the sections entitled Default.
39.10 FAA. The word "FAA" means the United States Federal Aviation
Administration, or any successor or replacement administration or governmental
agency having the same or similar authority and responsibilities.
39.11 Funding Date. The words "Funding Date" mean the date the loan is funded.
39.12 Geneva Convention. The words "Geneva Convention" mean the Convention on
the International Recognition of Rights in Aircraft made at Geneva, Switzerland
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EFTA00011577

=== Page 48 ===

=== Page 49 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
on June 19, 1948, (effective September 17, 1953), together with the necessary
enacting rules and regulations promulgated by any particular signatory country.
39.13 Grantor. The word "Grantor" means N550GP, LLC.
39.14 Guarantor. The word "Guarantor" means any guarantor, surety, or
accommodation party of any or all of the Indebtedness.
39.15 Guaranty. The word "Guaranty" means the guaranty from Guarantor, endorser,
surety, or accommodation party to Lender, including without limitation a guaranty
of all or part of the Note.
39.16 Indebtedness. The word "Indebtedness" means the indebtedness evidenced by
the Note or Related Documents, including all principal and interest together with
all other indebtedness and costs and expenses for which Grantor is responsible
under this Agreement or under any of the Related Documents.
39.17 International Registry. The words "International Registry" shall mean the
international registry created pursuant to the Convention.
39.18 Lender. The word "Lender" means Bank of Hope, or any other direct or indirect
subsidiary of Bank of Hope.
39.19 Note. The word "Note" means the promissory note executed by Grantor dated as
of May 11, 2021, from Grantor to Lender, together with all renewals of,
extensions of, modifications of, refinancings of, consolidations of, and
substitutions for the note or credit agreement.
39.20 Related Documents. The words "Related Documents" mean all promissory
notes, credit agreements, loan agreements (including, without limitation, the
Aircraft and Business Loan Agreement), environmental agreements, guaranties,
security agreements, collateral mortgages, cooperation covenants, agreements to
provide insurance, resolutions, chattel mortgages, trust receipts, assignment
pledges, and all other instruments, agreements and documents, whether now or
hereafter existing, executed in connection with the Indebtedness.
39.21 Transportation Code. The words "Transportation Code" shall mean Subtitle
VII, Part A of Title 49 of the United States Code, as amended.
39.22 Uniform Commercial Code. The words "Uniform Commercial Code" mean the
California Commercial Code Sec. 1101, et seq.
39.23 The terms "Administrator", "Contract of Sale", "International Interest",
"International Registry", "Professional User Entity", "Professional User",
"Prospective Contract of Sale", "Prospective International Interest",
"Transacting User Entity", shall have the meanings given them in the
Convention, unless the context requires otherwise. The term "searchable" shall
have the meaning contemplated by Article 32 of the Consolidated Text.
22
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EFTA00011579

=== Page 50 ===
EFTA00011580

=== Page 51 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
39.24 Counterpart. This Agreement may be executed in several counterparts and all
such executed counterparts shall constitute one agreement which shall be binding
on Borrower and Grantor notwithstanding that both parties are not signatories to
the same counterpart or counterparts.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
23
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EFTA00011581

=== Page 52 ===
EFTA00011582

=== Page 53 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
GRANTOR ACKNOWLEDGES HAVING READ ALL THE PROVISIONS OF THIS
AIRCRAFT SECURITY AGREEMENT AND GRANTOR AGREES TO ITS TERMS.
THIS AIRCRAFT SECURITY AGREEMENT IS DATED MAY 11, 2021.
GRANTOR:
N550GP, LLC
By:
Name:
Title: Manager
SIGNATURE PAGE - AIRCRAFT SECURITY AGREEMENT
EFTA00011583

=== Page 54 ===

=== Page 55 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
EXHIBIT A
FORM OF IRREVOCABLE DE-REGISTRATION
AND EXPORT REQUEST AUTHORIZATION
May 11, 2021
This Irrevocable De-Registration and Export Request Authorization is filed with the Federal Aviation
Administration in connection with that certain Aircraft Security Agreement, dated May 11, 2021 by N550GP, LLC
as the Grantor in favor of Bank of Hope as Lender, covering the Aircraft.
To:
United States Federal Aviation Administration
Re:
Irrevocable De-Registration and Export Request Authorization
The undersigned is the registered owner of the Gulfstream Aerospace Corporation (shown on the
International Registry as GULFSTREAM), model GV-SP (shown on the International Registry as Gulfstream
GV-SP (G550)) aircraft bearing manufacturer's serial number 5173 and registration N212JE (pending change to
N550GP) (together with all installed, incorporated or attached accessories, parts and equipment, the "Aircraft").
This instrument is an irrevocable de-registration and export request authorization issued by the
undersigned in favor of Bank of Hope ("the authorized party") under the authority of Article XIII of the Protocol
to the Convention on International Interests in Mobile Equipment on Matters specific to Aircraft Equipment. In
accordance with that Article, the undersigned hereby requests:
(i) recognition that the authorized party or the person it certifies as its designee is the sole person
entitled to:
(a) procure the de-registration of the aircraft from the United States Civil Aviation Registry as
maintained by the Federal Aviation Administration (the "FAA") for the purposes of Chapter
III of the Convention on International Civil Aviation, signed at Chicago, on 7 December
1944; and
(b) procure the export and physical transfer of the aircraft from the United States; and
(ii) confirmation that the authorized party or the person it certifies as its designee may take the action
specified in clause (i) above on written demand without the consent of the undersigned and that,
upon such demand, the authorities in the United States shall co-operate with the authorized party
with a view to the speedy completion of such action.
The rights in favor of the authorized party established by this instrument may not be revoked by the
undersigned without the written consent of the authorized party.
Please acknowledge your agreement to this request and its terms by appropriate notation in the space
provided below and filing this instrument at the FAA.
This Exhibit may be executed in multiple counterparts, which taken together shall constitute one instrument
and cach of which shall be considered an original for all purposes.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
151821345.3
EFTA00011585

=== Page 56 ===
EFTA00011586

=== Page 57 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
N550GP, LLC
By:
Name:
Title: Manager
Agreed to and filed this
FAA notations if applicable
SIGNATURE PAGE - IDERA
EFTA00011587

=== Page 58 ===
EFTA00011588

=== Page 59 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
EXHIBIT B
FORM OF IRREVOCABLE POWER OF ATTORNEY IN FACT
(AIRCRAFT REGISTRATION)
N550GP, LLC, a limited liability company organized and validly existing under the laws
of the State of California (the "Registered Owner"), is the grantor under that certain Aircraft
Security Agreement, dated as of May 11, 2021 (as amended, supplemented, and modified,
the "Security Agreement"), executed in favor of Bank of Hope ("Lender"), and with respect, in
part, to:
One (1) Gulfstream Aerospace Corporation (shown on the International Registry as
GULFSTREAM) model GV-SP (shown on the International Registry as Gulfstream GV-SP
(G550)) aircraft, bearing manufacturer's serial number 5173 and U.S. Registration Number
N212JE (pending change to N550GP), together with two (2) Rolls-Royce Deutschland Ltd & Co
KG (shown on the International Registry as ROLLS ROYCE) model BR700-710C4-11 (shown
on the International Registry as BR710) engines, bearing manufacturer's serial numbers 15449
and 15448 (collectively, the "Aircraft"); and Registered Owner is the registered owner of the
Aircraft with the Federal Aviation Administration ("FAA") Aircraft Registry (the "Registry").
Except as otherwise set forth herein, capitalized terms used herein shall have the meanings set
forth in the Security Agreement.
In consideration of the loan made by Lender that is secured by the Security Agreement
(the receipt and sufficiency of which is hereby acknowledged) and in accordance with the
Security Agreement, Registered Owner hereby:
1.
IRREVOCABLY AND UNCONDITIONALLY APPOINTS Lender as its true
and lawful Attorney in Fact (in such capacity the "Attorney in Fact") to generally do any and all
such acts and things as may be required and to execute and deliver upon its behalf and in its
name any documents, instruments or certificates and any amendments thereto (if any) which may
be required to:
(a) register, re-register or renew the registration of the Aircraft in the name of
Registered Owner with the Registry, including but not limited to the execution of any
FAA AC Forms 8050-1, 8050-1A or 8050-1B and the submission of any information or
forms on or through the FAA website established to allow for the registration, re-
registration or renewal of said registration;
(b) to reserve or extend the reservation of the United States Registration
Number associated with the Aircraft or to release or assign the United States Registration
Number to another entity and/or aircraft; and
(c) to take any action and to execute any instrument which Lender may
reasonably deem necessary or advisable to accomplish the purposes of the Security
Agreement or any other Related Document, or to exercise or enforce any right or remedy
available to Lender thereunder or under any Applicable Law, including, without
limitation, the right to execute and file documents with the Registry pertaining to the
151821345.3
EFTA00011589

=== Page 60 ===
EFTA00011590

=== Page 61 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
registration, deregistration or termination, assignment or amendment of recorded liens or
encumbrances with respect to the Aircraft, receive, endorse and collect all instruments
made payable to Registered Owner representing any dividend, interest payment or other
distribution in respect of the Collateral or any part thereof, and to give full discharge for
the same.
2.
AGREES that:
(a)
Registered Owner shall indemnify, defend and hereby undertakes from
time to time and at all times to indemnify and defend the Attorney in Fact against all
costs, claims, expenses and liabilities properly incurred by any Attorney in Fact in
connection herewith;
(b)
Registered Owner ratifies and confirms and will ratify and confirm any
action taken and document executed by the Attorney in Fact by virtue of this Irrevocable
Power of Attorney in Fact (the "Power of Attorney");
(c) any officer, director, or manager of Attorney in Fact may execute
documents for Attorney in Fact in its capacity as Attorney in Fact for Registered Owner;
(d)
this Power of Attorney shall be conclusive and binding upon Registered
Owner and no person or corporation shall be under any obligation to make any inquiries
as to whether or not this Power of Attorney has been revoked, all parties may rely on an
executed copy or facsimile of this Power of Attorney and the revocation or termination of
this Power of Attorney shall be ineffective as to any documents executed pursuant to this
Power of Attorney; and
(e)
this Power of Attorney may be filed with the Registry.
The power of attorney set forth herein shall be deemed coupled with an interest and shall
expire sixty-one (61) months from the date set forth below. This Power of Attorney shall in all
respects be interpreted in accordance with and governed by the laws of the State of California.
[Signature page follows.]
151821345.3
EFTA00011591

=== Page 62 ===
EFTA00011592

=== Page 63 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
IN WITNESS WHEREOF this Power of Attorney was executed on this
, 2021.
N550GP, LLC
By:
Name:
Title: Manager
SIGNATURE PAGE- IRREVOCABLE POWER OF ATTORNEY (AIRCRAFT REGISTRATION)
EFTA00011593

=== Page 64 ===
EFTA00011594

=== Page 65 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
IRREVOCABLE DE-REGISTRATION
AND EXPORT REQUEST AUTHORIZATION
May 11, 2021
This Irrevocable De-Registration and Export Request Authorization is filed with the Federal Aviation
Administration in connection with that certain Aircraft Security Agreement, dated May 11, 2021 by N550GP, LLC
as the Grantor in favor of Bank of Hope as Lender, covering the Aircraft.
To:
United States Federal Aviation Administration
Re:
Irrevocable De-Registration and Export Request Authorization
The undersigned is the registered owner of the Gulfstream Aerospace Corporation (shown on the
International Registry as GULFSTREAM), model GV-SP (shown on the International Registry as Gulfstream
GV-SP (G550)) aircraft bearing manufacturer's serial number 5173 and registration N212JE (pending change to
N550GP) (together with all installed, incorporated or attached accessories, parts and equipment, the "Aircraft").
This instrument is an irrevocable de-registration and export request authorization issued by the
undersigned in favor of Bank of Hope ("the authorized party") under the authority of Article XIII of the Protocol
to the Convention on International Interests in Mobile Equipment on Matters specific to Aircraft Equipment. In
accordance with that Article, the undersigned hereby requests:
(i) recognition that the authorized party or the person it certifies as its designee is the sole person
entitled to:
(a) procure the de-registration of the aircraft from the United States Civil Aviation Registry as
maintained by the Federal Aviation Administration (the "FAA") for the purposes of Chapter
III of the Convention on International Civil Aviation, signed at Chicago, on 7 December
1944; and
(b) procure the export and physical transfer of the aircraft from the United States; and
(ii) confirmation that the authorized party or the person it certifies as its designee may take the action
specified in clause (i) above on written demand without the consent of the undersigned and that,
upon such demand, the authorities in the United States shall co-operate with the authorized party
with a view to the speedy completion of such action.
The rights in favor of the authorized party established by this instrument may not be revoked by the
undersigned without the written consent of the authorized party.
Please acknowledge your agreement to this request and its terms by appropriate notation in the space
provided below and filing this instrument at the FAA.
This Exhibit may be executed in multiple counterparts, which taken together shall constitute one instrument
and each of which shall be considered an original for all purposes.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
151870876.1
EFTA00011595

=== Page 66 ===
EFTA00011596

=== Page 67 ===
DocuSign Envelope ID: C9C42BF8-7BCA-4108-A29F-423F14801D14
N550GP, LLC
By:
Name:
Title: Manager
Agreed to and filed this
FAA notations if applicable
SIGNATURE PAGE - IDERA
EFTA00011597

=== Page 68 ===
EFTA00011598
:
FILED WITH FAÁ
AIRCRAFT
REGISTRATION BR
2021 MAY 14 PM 1: 46
OKLAHOMA CITY
OKLAHOMA

=== Page 69 ===
DOCUMENT LEVEL ANNOTATIONS FOR DOCUMENT ARE012567787
76128425114 $15 07/23/2021
EFTA00011599

=== Page 70 ===
EFTA00011600

=== Page 71 ===
U.S. Department
Aviation Safety
of Transportation
Oklahoma City, Oklahoma 73125-0504
Federal Aviation
Toll Free:
Administration
WEB Address:
Date of Issue: February 24, 2021
N550GP LLC
ONTARIO, CA 91764-5496
Fax
HAND DELIVERED TO IN THE PD ROOM
T211438
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N212JE GULFSTREAM AEROSPACE GV-SP (G550) Serial 5173 and is valid until Mar
26, 2021.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
for
Acting Manager, Aircraft Registration Branch
Federal Aviation Administration
REGAR-FAX-4 (02/21)
EFTA00011601

=== Page 72 ===
EFTA00011602

=== Page 73 ===
LETTER OF EXTENSION
(For Authority to Operate an Aircraft Pending Registration)
The authority to operate Aircraft N212JE, GULFSTREAM AEROSPACE GV-SP
(G550), S/N 5173 is extended for 120 days from the date stamped below, or until the
Certificate of Aircraft Registration (AC Form 8050-3) is issued, whichever date occurs
first.
DATE
CF
Feb 24, 2021
This Letter of Extension must be carried in the aircraft with a copy of the aircraft
registration application as temporary authority to continue to operate the aircraft without
registration within the United States. This is not an authorization to operate the aircraft
without an appropriate Airworthiness Certificate (FAA Form 8100-2 or 8130-7), or its
equivalent.
U.S. Department
of Transportation
Federal Aviation
Civil Aviation Registry
Administration
Oklahoma City, Oklahoma 73125-0504
REGAR-37 (08/19)
EFTA00011603

=== Page 74 ===
EFTA00011604

=== Page 75 ===
Return Certificate of Registration to
I.A.T.S
DECLARATION
of
Accepted PRIDATTY Go Feb/24/2021
INTERNATIONAL OPERATIONS
The undersigned owner of aircraft N 212JE
, Manufacturer Gulfstream Acrospace
Model G550 GV-SP
Serial Number 5173
declares that this aircraft is scheduled to make an international flight* on 02-26-2021
,
(date)
as flight Number N212JE
departing Chino/California
(City/State)
with a destination of Cabo San Lucas/Mexico
.
(City/Country)
*[If required route between two points in the United States involves international navigation, explain under
Comments below, e.g. "partly over Canada" or "partly in international airspace".]
Expedited registration in support of this international flight is requested this
17
day of February
2021 with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of the
Government of the United States, knowingly and willfully makes or uses any
false writing or document knowing the same to contain any materially false,
fictitious or fraudulent statement of representation shall be fined under Title 18
United States Code or imprisoned not more than 5 years, or both. 18 U.S.C.
$1001(a).
Name of Owner
CAR COPY COPY
Signature
Typed Name and Title of Signer
of FH 11,40 It's Member
Phone:
Fax:
Comments:
*[If required route between two points in the United States involves international
navigation, explain under comments below, e.g. "partly over Canada" or "partly in
international airspace".]
Comments: Please fax the flying time wire to Insured Aircraft Title Service Inc. at
Insured Aircraft Title Service LLC
Phone
CAR
EFTA00011605

=== Page 76 ===
EFTA00011606
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2021 FEB 23 AM II: 09
OKLAHOMA CITY
OKLAHOMA

=== Page 77 ===
ACTION
2/NCG NCG
I
A
Insured Aircraft Title Service, LLC
Accepted CF Jul/22/2021
T
S
FEDERAL AVIATION ADMINISTRATION
CENTRAL RECORDS DIVISION
OKLAHOMA CITY, OKLAHOMA
Date: February 11, 2021
Dear Sir/Madam:
Please Reserve N
in NAME ONLY for:
N# CHANGE REQUEST
Please Reserve N 550GP** and assign for the following aircraft:
Θ
2
N 212JE Make Gulfstream Aerospace Model GV-SP (G550) Serial #
5173
Which is (1) being purchased by
XX (2) registered to
XX
:
N550GP, LLC
Ontario, CA 91764
Payment of the required $10.00 fee per number to reserve/assign is attached. If the preferred N number is not
available, please contact the undersigned for a selection of a new number. Please send the confirmation of
reservation/8050-64 form to Insured Aircraft Title Service, LLC in the Public Documents room of the FAA.
Additional Information: **Relinquishment Attached
210421440037
20 00 02/11/2021
Requested by:
Fee:
$20.00
EFTA00011607

=== Page 78 ===
EFTA00011608
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2021 FEB 11 PM 2: 02
OKLAHOMA CITY
OKLAHOMA

=== Page 79 ===
UNITED STATES OF AMERICA - DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION- MIKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
1) UNITED STATES
1. Individual
REGISTRATION
N
212JE
4) TYPE OF REGISTRATION
2. Partnership
NUMBER
3. Corporation
2) AIRCRAFT
4. Co-Owner
MANUFACTURER
GULFSTREAM AEROSPACE GV-SP (G550)
Accepted GC Feb/24/2021
AND MODEL
5. Government
(Check one box.)
3) AIRCRAFT
7. Limited Liability Company (LLC)
SERIAL
8. Non-Citizen Corporation
5173
NUMBER
9. Non-Citizen Corporation Co-Owner
6) NAME(S) OF APPLICANT(S) (Person(s) shown on evidence of ownership If individual give last name, first name and middle initial.)
N550GP, LLC
6) TELEPHONE NUMBER
7) MAILING ADDRESS (Permanent mailing address for first applicant on list.)
NUMBER AND STREET
RURAL ROUTE
P.O. BOX
CITY: Ontario
STATE CA
ZIP: 91764
8) PHYSICAL ADDRESS/LOCATION IF PO BOX MAIL DROP OR RURAL ROUTE BOX USED FOR MAILING ADDRESS
NUMBER AND STREET
DESCRIPTION OF
LOCATION
CITY:
STATE
ZIP:
9)
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
10) CERTIFICATION
WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant who is: (MUST CHECK AND/OR COMPLETE a. D.C. or d)
a. A citizen of the United States as defined by 49 USC 40102(a)(15):
b. A resident alien with alien registration (Form 1-551) No.
c. A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft
is based and primarily used in the United States. Records of flight hours are available for inspection at (provide complete physical address)
d. A corporation using a voting trust to qualify. Enter name of trustee
(2) If box C or d above is checked I, the below signed, certify that am authorized by the applicant shown above to sign corporate documents and to
seek aircraft registration on behalf of the entity and that I will provide the same authorization if requested
(3) That the aircraft is not registered under the laws of any foreign country: and
(4) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
ANY AND ALL SIGNATORIES OF THIS APPLICATION MUST READ THE FOLLOWING AND UNDERSTAND THAT, BY APPLYING
A SIGNATURE TO THIS DOCUMENT, THEY ARE SUBJECT TO THE REFERENCED STATUTES AND ASSOCIATED PENALTIES.
I/we hereby certify that the information provided in, and in any attachments to, this application for aircraft registration is true, accurate and correct to the best of my/our
knowledge and belief. I/we understand that the FAA administrator will rely on the information I/we provide in determining my/our qualification for aircraft registration. I/we
understand that whoever, in any matter within the jurisdiction of any department or agency of the United States. knowingly and willfully falsifies, conceals, or covers up by
any trick, scheme, or device any material fact(s). statement(s), representation(s) or entry(ies) may be fined up to $500,000 or imprisoned for not more than five (5) years or
both (18 U.S.C. §§ 1001 and 3571). I/we understand that to knowingly and wilfully: a) falsify or conceal a material fact; or b) use a document knowing it contains a false,
fictitious or fraudulent statement/entry: or c) provide any inaccurate, false statement/information can subject me to criminal prosecution (49 U.S.C. § 46306), and the
registration of the subject aircraft may be delayed, denied and/or revoked.
NOTE: If executed for co-ownership, all applicants must sign. Use next page and add page(s) if necessary.
SIGNATURE:
DATE: 12-22-2020
11)
TYPED/PRINTED
NAME:
E: Manager of Frontier JV LLC, its Member
SIGNATURE
DATE:
12)
TYPED/PRINTED
NAME:
TITLE:
NOTE: Except when the most recent registration of the subject aircraft is expired or cancelled, 14 CFR 47.31(c) provides for an airworthy
U.S. aircraft to be operated for up to 90 days within the United States when a copy of the signed aircraft registration application is carried
in the aircraft while awaiting issuance and receipt of the new registration certificate.
AC Form 8050-1 (02/20)
Page 1
EFTA00011609

=== Page 80 ===
EFTA00011610
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2020 DEC 22 AM 10: 53
OKLAHOMA CITY
OKLAHOMA

=== Page 81 ===
UNITED STATES OF AMERICA
OMB Control No. 2120-0042
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
Exp. 04/30/2017
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $ 1.00 + OVC THE
UNDERSIGNED OWNER(S) OF THE FULL
LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
N212JE
AIRCRAFT MANUFACTURER & MODEL
GULFSTREAM AEROSPACE, GV-SP (G550)
AIRCRAFT SERIAL No.
5173
DOES THIS
22nd
DAY OF December
, 2020
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
GC009140 Conveyance Recorded Feb/24/2021 04:21 PM FAA
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write In This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
N550GP, LLC
PURCHASER
Ontario, CA 91764
DEALER CERTIFICATE NUMBER
AND TO ITS SUCCESSORS
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF:
I
IN TESTIMONY WHEREOF
MY
HAVE SET
HAND AND SEAL THIS 22nd DAY OF Dec., 2020
NAME(S) OF SELLER
SIGNATURE(S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED FOR
(TYPED OR PRINTED)
CO-OWNERSHIP, ALL MUSTSIGN.
Six G Aviation LLC
Manager
SELLER
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED BY LOCAL LAW FOR
VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA:
AC Form 8050-2 (01/12) (NSN 0052-00-629-0003)
EFTA00011611

=== Page 82 ===
EFTA00011612
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2020 DEC 22 AM 10: 53
OKLAHOMA CITY
OKLAHOMA

=== Page 83 ===
UNITED STATES OF AMERICA
OMB Control No. 2120-0042
Exp. 04/30/2017
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $ 1.00 + OVC THE
UNDERSIGNED OWNER(S) OF THE FULL
LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
N212JE
AIRCRAFT MANUFACTURER & MODEL
GULFSTREAM AEROSPACE, GV-SP (G550)
AIRCRAFT SERIAL No.
5173
DOES THIS 22nd
DAY OF December
, 2020
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
GC009139 Conveyance Recorded Feb/24/2021 04:20 PM FAA
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write In This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
Six G Aviation LLC
PURCHASER
DEALER CERTIFICATE NUMBER
AND TO ITS SUCCESSORS
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF:
I
IN TESTIMONY WHEREOF
MY
HAVE SET
HAND AND SEAL THIS 22nd DAY OF Dec., 2020
NAME(S) OF SELLER
SIGNATURE(S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED FOR
(TYPED OR PRINTED)
CO-OWNERSHIP, ALL MUSTSIGN
Plan D, LLC
Digitally signed by LAWRENCE VISOSKI
d.VMWHSt2egufPTNsiukc)0doo2ykX
Manager
SELLER
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED BY LOCAL LAW FOR
VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA:
AC Form 8050-2 (01/12) (NSN 0052-00-629-0003)
EFTA00011613

=== Page 84 ===
EFTA00011614
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2020 DEC 22 AM ID: 53
OKLAHOMA CITY
OKLAHOMA

=== Page 85 ===
DOCUMENT LEVEL ANNOTATIONS FOR DOCUMENT ARE012112330
Agency Tracking ID: 76060977022 $5.00 12-22-2020
EFTA00011615

=== Page 86 ===
EFTA00011616

=== Page 87 ===
DocuSign Envelope ID: 7E781336-7F28-41F4-9361-8263DC960592
PRINT PAGE 1
PRIVACY ACT STATEMENT
OMB Control Number 2120-0729
Expires 05/31/2014
Paperwork Reduction Act Statement: The information collected on this form is necessary to maintain aircraft registration. We estimate that it will take approximately 30 minutes
to complete the form. Please note that an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid
OMB control number. Form Approved, OMB No. 2120-0729 "Comments concerning the accuracy of this burden and suggestions for reducing the burden should be directed to
the FAA at: 800 Independence Avenue SW, Washington, DC 20591. ATTN: Information Collection Clearance Officer, AES-200
FAILURE TO RENEW REGISTRATION WILL
DEPARTMENT OF TRANSPORTATION - FEDERAL AVIATION ADMINISTRATION
RESULT IN CANCELLATION OF REGISTRATION
AIRCRAFT REGISTRATION RENEWAL APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
Accepted CW Feb/27/2020
(See 14 C.F.R. $5 47.15(i), 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 212JE
5173
MANUFACTURER
MODEL
Gulfstream Aerospace
GV-SP (G550)
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
3-31-2017
3-31-2020
LLC
ENTER REGISTERED OWNER(S) & ADDRESS FROM FAA FILE
HELPFUL INFORMATION
(Owner 1) Plan D LLC
Review Aircraft Registration File Information for this aircraft
(Owner 2)
at: http://registry.faa.gov/aircraftinquiry.
Note: Enter any additional owner names on page two.
Assistance may be obtained
(Address)
at our web page: http://registry. faa.gov/renewregistration.
by e-mail at:
or
(Address)
by telephone at:
toll free), or
City St. Thomas
State VI Zip 00802
When mailing fees, please use a check or money order made
Country Virgin Islands USA
payable to the Federal Aviation Administration.
Physical Address: Required when mailing address is a P.O. Box or mail drop.
Signature and Title Requirements for Common Registration Types:
Individual
(Address)
owner must sign. title would be "owner".
- Partnership
general partner signs showing "general partner" as title.
(Address)
- Corporation
corporate officer or manager signs, showing full title.
City
State
Zip
- Limited Liability Co
authorized member, manager, or officer identified in the
LLC organization document signs, showing full title.
Country
- Co-owner
each co-owner must sign; showing "co-owner" as title.
Government
authorized person must sign and show their full title.
TO RENEW REGISTRATION: REVIEW aircraft registration information,
Note: All signatures must be in Ink, or other permanent media.
SELECT the appropriate statement, ENTER any change in address in the
spaces below, SIGN. DATE. & SEND form with the $5 renewal fee to the:
To correct entries: Draw a single line through error. Make correct entry in
FAA Aircraft Registry. PO Box 25504, Oklahoma City OK 73125-0504, or
remaining space, or complete the form on-line. An application form will be
by courier to: 6425 S Denning Room 118, Oklahoma City OK 73169-6937
rejected if any entry is covered by correction tape or similarly obscured
I (WE) CERTIFY, THE NAME(S) AND ADDRESSES FROM THE FAA FILES
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CHECK all applicable blocks below, COMPLETE SIGN. DATE & MAIL this
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY.
form with any fees to the: FAA Aircraft Registry.
City, OK, 73125-0504, or by courier to:
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW.
Oklahoma City OK 73169-6937
1 (WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
THIS AIRCRAFT IS CORRECT, OWNERSHIP MEETS THE CITIZENSHIP
CANCELLATION OF REGISTRATION IS REQUESTED.
REQUIREMENTS OF 14 CFR $47.3. AIRCRAFT IS NOT REGISTERED
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
THE AIRCRAFT WAS SOLD TO:
(Show purchaser's name and address.)
NEW MAILING ADDRESS
St. Thomas USVI 00802
THE AIRCRAFT IS DESTROYED OR SCRAPPED.
NEW PHYSICAL ADDRESS: complete if physical address has changed, or
THE AIRCRAFT WAS EXPORTED TO:
the new mailing address is a PO Box or Mail Drop.
PLLC
St. Thomas USVI 00802
OTHER, Specify
PLEASE RESERVE N-NUMBER IN THE OWNER'S NAME
AND ADDRESS. The $10 reservation fee is enclosed.
SIGNATURE OF field)
PRINTED NAME OF SIGNER
(required field)
TITLE
(required field)
DATE
lawrence Visoski
Lawrence Visoski
Manager
2-21-2020
SIGNATURE OF OWNERGEB12002F44C9
PRINTED NAME OF SIGNER
TITLE
DATE
Use page 2 for additional signatures.
200521518371
Return Certificate of Registration (85.00 02/21/2020
AC Form 8050-1B (04/12)
I.A.T.S
EFTA00011617

=== Page 88 ===
EFT
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2020 FEB 21 PM 3: 12
OKLAHOMA CITY
OKLAHOMA

=== Page 89 ===
ASSIGNMENT OF SPECIAL
Special Registration Number
N212JE
REGISTRATION NUMBERS
U.S. Department
Aircraft Make and Model
Present Registration Number
of Transportation
GULFSTREAM AEROSPACE GV-SP (G550)
N415LM
Federal Aviation
Serial Number
Issue Date:
Accepted OT Jan/24/2018
Administration
5173
Aug 23, 2017
ICAO AIRCRAFT ADDRESS CODE FOR N212JE - 50340675
This is your authority to change
the United States registration
number on the above described
PLAN D LLC
aircraft to the special
registration number shown.
ST THOMAS VI VI 00802
Carry duplicate of this form in the
aircraft together with the
old registration certificate as
interim authority to operate the
aircraft pending receipt of revised
certificate of registration.
Obtain a revised certificate of
airworthiness from your near-
est Flight Standards District
Office.
The latest FAA Form 8130-6,
Application For Airworthiness
on file is dated:
Mar 07, 2008
The airworthiness classification
and category:
STD TRANSP
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, AFS-750, within 5 days after the special
registration number is placed on the aircraft. A revised certificate will then be issued.
The authority to use the special number expires: Aug 23, 2018
CERTIFICATION: I certify that the special registration number was placed
RETURN FORM TO:
on Signature the aircraft of Owner: described above. Visoski
Civil Aviation Registry, AFS-750
Oklahoma City, Oklahoma 73125-0504
Title of Owner: MANAGER PLAN D, we
Date Placed on Aircraft: JANUARY 2ND. 2018
AC FORM 8050-64 (5/2005) Supersedes Previous Edition
EFTA00011619

=== Page 90 ===
EFTA000116
FILED WITH FAA
AIRCRAFT REGISTRATION OR
2018 JAN 5 AM 11 45
OKLAHOMA CITY
OKLAHOMA

=== Page 91 ===
PLAN D, LLC Gulfstream G550 Serial #5173
Accepted oT Jan/24/2018
Thomas U.S.V.I. Quarters B3 00802
08/07/2017
To Whom it may concern / Ms Nancy,
FAA Registry,
At this time I'm requesting approval to apply N number N212JE to our Gulfstream G550 which is currently N415LM.
I have already pay the $10.00 Fee from past correspondence,.
Please mail the 8050-64 / Assignment of Special Registration Numbers to my airport address below if possible:
Plan D, LLC c/o Larry Visoski Atlantic Aviation
West Palm Beach, FL 33406
Thank you,
are Larry Visoski
Manager,
Plan D. LLC
EFTA00011621

=== Page 92 ===
EFTA00011622
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2017 AUG 9 AM 11 05
OKLAHOMA CITY
OKLAHOMA

=== Page 93 ===
DOCUMENT LEVEL ANNOTATIONS FOR DOCUMENT ARE008895928
Receipt # 171881203014 $10.00 07/07/2017
EFTA00011623

=== Page 94 ===
EFTA00011624

=== Page 95 ===
U.S. Department
Flight Standards Service
of Transportation
Aircraft Registration Branch,
Oklahoma City, Oklahoma 73125-0504
AFS-750
Federal Aviation
Toll Free:
Administration
WEB Address:
Date of Issue: March 31, 2017
PLAN D LLC
ST THOMAS, VI VI 00802
HAND DELIVERED TO IATS IN THE PD ROOM
T172058
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N415LM GULFSTREAM AEROSPACE GV-SP (G550) Serial 5173 and is valid until Apr
30, 2017.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
for
Manager, Aircraft Registration Branch, AFS-750
Federal Aviation Administration
AFS-750-FAX-4 (01/14)
EFTA00011625

=== Page 96 ===
EFTA00011626

=== Page 97 ===
PRIORITY
DECLARATION
Accepted CF Mar/31/2017
of
INTERNATIONAL OPERATIONS
The undersigned owner of aircraft N 415LM , Manufacturer GULFSTREAM Aerospace
Model GV.SP (G550)
Serial Number 5173
declares that this aircraft is scheduled to make an international flight* on APRIL 3 2017
(date)
as flight Number 41.5LM departing (KTEB) TETERBORO NJ
(City/State)
with a destination of (TIST) ST Thomas SVRGINISLANDS
(City/Country)
*[If required route between two points in the United States involves international navigation, explain under
Comments below. e.g. "partly over Canada" or "partly in international airspace".]
Expedited registration in support of this international flight is requested this
29th day of march
2017 with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of the
Government of the United States, knowingly and willfully makes or uses any
false writing or document knowing the same to contain any materially false,
fictitious or fraudulent statement of representation shall be fined under Title 18
United States Code or imprisoned not more than 5 years, or both. 18 U.S.C.
$1001(a).
Name of Owner
PLAN D LLC
Signature
NVC
Typed Name and Title of Signer LAWRENCE Visaski MANAGER
Phone:
Comments:
Please send the Fly Time Wire to IATS via fax number
Please return the Certificate of Registration to IATS via the PD Room at the FAA.
Return Certificate of Registration to
Return Certificate of Registration to
LA.T.S
I.A.T.S
AFS-750-DIO-1 (02/12)
CAR
COPY
can
EFTA00011627

=== Page 98 ===
EFTA00011628
ASRCRAFFREGISTRATION
BR
MAR 29 A 11: 04
OXLAHOMA CITY

=== Page 99 ===
UNITED STATES OF AMERICA- DEPARTMENT OF TRANSPORTATION
OMB Control No. 2120-0042
Federal Aviation Administration - Mike Monroney Aeronautical Center
Collection Expires 4/30/2017
U.S. Department
of Transportation
AIRCRAFT REGISTRATION APPLICATION
Federal Aviation
Administration
UNITED STATES
REGISTRATION
N
415LM
TYPE OF REGISTRATION (Check see box)
Accepted CF Mar/31/2017
NUMBER
1. Individual
AIRCRAFT
2. Partnership
MANUFACTURER Gulfstream Aerospace GV-SP (G550)
2
a. Corporation (includes LLC's)
AND MODEL
4. Co-Owner
AIRCRAFT
5. Government
SERIAL 5173
8. Non-Cilizen Corporation
NUMBER
9. Non-Cifizen Corporation Co-Owner
NAME(S) OF APPLICANT(S) (Person(s) shown on evidence of ownership. If individual, give last name, first name and middle Initial]
Plan D, LLC
TELEPHONE NUMBER: ( )
MAILING ADDRESS (Permapent mailing address for first applicant listed above.)
NUMBER AND STREET:
RURAL ROUTE:
P.O. BOX
CITY: St. Thomas
STATE: USVI
ZIP: 00802
PHYSICAL ADDRESS/LOCATION IF PO BOX OR RURAL ROUTE BOX USED FOR MAL NO ADDRESS
NUMBER AND STREET:
DESCRIPTION OF LOCATION:
CITY:
STATE:
ZIP:
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion must be completed.
A false or dishonest answer to any question in this application
may be grounds for punishment by fine and/or imprisonment.
(U.S. Code, Title 18, Section 1001)
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant who other is a citizen (including corporations) of the United States
OR meets the aircraft registration citizenship requirements of 14 CFR Part 47 BE (CHECK AND COMPLETE a. b, or c)
a. A resident elen with alon registration (Form 1-551) No.
b. A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States. Records of flight hours are available for
Inspection at
c. A corporation using a voting trust to quality Enter name of trustee
(2) That the aircraft is not registered under the lews of any foreign country; and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for -ownership, all applicants must sign. Use next page If necessary.
SIGNATURE:
TYPED/PRINTED
24C Lawrence Visoski
DATE: March 29, 2017
1
NAME:
TITLE: Manager
SIGNATURE:
DATE:
2
TYPED/PRINTED
NAME:
TITLE:
SIGNATURE:
DATE:
3
TYPED/PRINTED
NAME:
TITLE:
NOTE: When curried In the aircraft with an appropriate current airworthiness certificate or a special flight permit,
a copy of this completed application provides authority to operate the aircraft in the United States for up to 90 days.
AC Form 8050-1 (03/18)
1
EFTA00011629

=== Page 100 ===
EFTA00011630
AIRCRAFT REGISTRATION ER
FILED WITH FAA
2017 MAR 29 A & 09
OKLAHOMA OKLAHOMA CITY

=== Page 101 ===
UNITED STATES OF AMERICA
OMB Control No. 2120-0042
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
Exp. 04/30/2017
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $ 1.00 & OVC THE
UNDERSIGNED OWNER(S) OF THE FULL
LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
N415LM
AIRCRAFT MANUFACTURER & MODEL
Gulfstream Aerospace GV-SP (G550)
AIRCRAFT SERIAL No.
5173
DOES THIS
29
DAY OF March
, 2017
CF004381 Conveyance Recorded Mar/31/2017 08:26 AM FAA
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write in This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL)
Plan D. LLC
PURCHASER
St. Thomas, USVI 00802
DEALER CERTIFICATE NUMBER
AND TO its successors
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF:
IN TESTIMONY WHEREOF we
HAVE SET
our
HAND AND SEAL THIS 29 DAY OF March 2017
NAME(S) OF SELLER
SIGNATURE(S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED FOR
(TYPED OR PRINTED)
CO-OWNERSHIP, ALL MUSTSIGN.
Chevron U.S.A., Inc.
Attorney... Fact
SELLER
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED BY LOCAL LAW FOR
VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA:
AC Form 8050-2 (01/12) (NSN 0052-00-629-0003)
170880913227
$5.00 03/29/2017
EFTA00011631

=== Page 102 ===
EFTA00011632
AIRCRAFTREGISTRATION
BR
2017 MAR 29 A 9:09
OKLAHOMA CITY

=== Page 103 ===
ASSIGNMENT OF SPECIAL
Special Registration Number
N415LM
REGISTRATION NUMBERS
U.S. Department
Aircraft Make and Model
Present Registration Number
of Transportation
GULFSTREAM AEROSPACE GV-SP (G550)
N401HB
Accepted IR Mar/16/2017
Federal Aviation
Serial Number
Issue Date:
Administration
5173
Feb 01, 2017
ICAO AIRCRAFT ADDRESS CODE FOR N415LM - 51163671
This is your authority to change
the United States registration
number on the above described
CHEVRON U.S.A. INC.
aircraft to the special
registration number shown.
OAKLAND CA 94621-4543
Carry duplicate of this form in the
aircraft together with the
old registration certificate as
interim authority to operate the
aircraft pending receipt of revised
certificate of registration.
Obtain a revised certificate of
airworthiness from your near-
est Flight Standards District
Office.
The latest FAA Form 8130-6,
Application For Airworthiness
on file is dated:
Mar 07, 2008
The airworthiness classification
and category:
STD TRANSP
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, AFS-750, within 5 days after the special
registration number is placed on the aircraft. A revised certificate will then be issued.
The authority to use the special number expires: Feb 01, 2018
CERTIFICATION: I certify that the special registration number was placed
RETURN FORM TO:
on u
Civil Aviation Registry, AFS-750
Sign
Oklahoma City, Oklahoma 73125-0504
Title of Owner: Assistant Secretary
Date Placed on Aircraft: march7, 2017
AC FORM 8050-64 (5/2005) Supersedes Previous Edition
Please reserve N401HB Back to Chevron U.S.A. Inc.
#10.00 is attached
170661345326
$10.00 03/07/2017
EFTA00011633

=== Page 104 ===
EFTA00011634
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2017 MAR - 7 P 1: 17
OKLAHOMA CITY
OKLAHOMA

=== Page 105 ===
ACTION
2 / NCG
A
Insured Aircraft Title Service, Inc.
Accepted IR Mar/16/2017
T
S
FEDERAL AVIATION ADMINISTRATION
CENTRAL RECORDS DIVISION
OKLAHOMA CITY, OKLAHOMA
Date:
Jaunary 30, 2017
Dear Sir/Madam:
Please Reserve N
in NAME ONLY for:
D
N# Change Request
Please Reserve N 415LM
and assign for the following aircraft:
N 401HB Make Gulfstream Aerospace
Model GV-SP (G550) Serial #
5173
Which is (1) being purchased by
X
(2) registered to
:
Chevron US A Inc.
Oakland, CA 94621
Payment of the required $10.00 fee per number to reserve/assign is attached. If the preferred N number is not
available, please contact the undersigned for a selection of a new number. Please send the confirmation of
reservation/8050-64 form to Insured Aircraft title Service, Inc. in the Public Documents room of the FAA.
Additional Information: Please reserve and assign N415LM to N401HB
Requested by:
Fee:
$20.00
170300828499
$20.00 01/30/2017
EFTA00011635

=== Page 106 ===
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2017 JAN 30 1 A 8: 31
OKLAHOMA CITY
OKLAHOMA

=== Page 107 ===
OMB Control Number 2120-0729
Expires 04/30/17
Paperwork Reduction Act Statement: The information collected on this form is necessary to maintain aircraft registration. We estimate that it will take approximately 30
minutes to complete the form. Please note that an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a
valid OMB control number. Form Approved, OMB No. 2120-0729 "Comments concerning the accuracy of this burden and suggestions for reducing the burden should be
directed to the FAA at: 800 Independence Avenue SW, Washington, DC 20591. ATTN: Information Collection Clearance Officer, AES-200."
FAILURE TO RENEW REGISTRATION WILL
DEPARTMENT OF TRANSPORTATION - FEDERAL AVIATION ADMINISTRATION
RESULT IN CANCELLATION OF REGISTRATION
AIRCRAFT REGISTRATION RENEWAL APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
(See 14 C.F.R. §§ 47.15(i), 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 401HB
5173
MANUFACTURER
MODEL
GULFSTREAM AEROSPACE
GV-SP (G550)
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
04/02/2008
04/30/2020
CORPORATION
ENTER REGISTERED OWNER(S) & ADDRESS FROM FAA FILE
HELPFUL INFORMATION
(Owner 1) CHEVRON U S A INC
Review Aircraft Registration File Information for this aircraft
at: http://registry.faa.gov/aircraftinquiry.
(Owner 2)
Note: Enter any additional owner names on page two.
Assistance may be obtained
at our web page: http://registry.faa.gov/renewregistration,
(Address)
by e-mail at:
(Address)
by telephone at::
City OAKLAND
State CA Zip 94621-4543
When mailing fees, please use a check or money order made
Country UNITED STATES
payable to the Federal Aviation Administration
Physical Address: Required when mailing address is a P.O. Box or mail drop.
Signature and Title Requirements for Common Registration Types:
(Address)
Individual
owner must sign, title would be "owner".
- Partnership
general partner signs showing "general partner" as
(Address)
title.
City
State
Zip
- Corporation
corporate officer or manager signs, showing full title.
Country
- Limited Liability Co
authorized member, manager, or officer identified in
the LLC organization document signs, showing full title.
TO RENEW REGISTRATION: REVIEW aircraft registration information,
- Co-owner
each co-owner must sign; showing "co-owner" as title.
Government
SELECT the appropriate statement, ENTER any change in address in the
authorized person must sign and show their full title.
spaces below, SIGN. DATE, & SEND form with the $5 renewal fee to the:
Note: All signatures must be in ink, or other permanent media.
FAA Aircraft Registry, PO Box 25504, Oklahoma City OK 73125-0504, or
To correct entries: Draw a single line through error. Make correct entry in
by courier to: 6425 S Denning Rm 118, Oklahoma City OK 73169-6937
remaining space, or complete the form on-line. An application form will be
rejected if any entry is covered by correction tape or similarly obscured.
I (WE) CERTIFY, THE NAME(S) AND ADDRESSES FROM THE FAA FILES
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CHECK All applicable block(s) below, COMPLETE SIGN. DATE & MAIL
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY.
this form with any fees to the: FAA Aircraft Registry,
PO Box 25504, Oklahoma City, OK, 73125-0504, or by courier to:
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW.
6425 S Denning Rm. 118, Oklahoma City OK 73169-6937
I (WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
THIS AIRCRAFT IS CORRECT, OWNERSHIP MEETS THE CITIZENSHIP
CANCELLATION OF REGISTRATION IS REQUESTED.
REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS NOT REGISTERED
THE AIRCRAFT WAS SOLD TO:
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
(Show purchaser's name and address.)
NEW MAILING ADDRESS
THE AIRCRAFT IS DESTROYED OR SCRAPPED.
NEW PHYSICAL ADDRESS: complete if physical address has changed, or
THE AIRCRAFT WAS EXPORTED TO:
the new mailing address is a PO Box or Mail Drop.
OTHER, Specify
PLEASE RESERVE N-NUMBER IN THE OWNER'S NAME
AND ADDRESS. The $10 reservation fee is enclosed.
SIGNATURE OF OWNER 1 (required field)
PRINTED NAME OF SIGNER
(required field)
TITLE
(required field)
DATE
Electronically Certified by Registered Owners
12/2/2016
SIGNATURE OF OWNER 2
PRINTED NAME OF SIGNER
TITLE
DATE
Use page 2 for additional signatures.
Fee paid: $5 (201612021356474332NB)
AC Form 8050-1B (04/12)
EFTA00011637

=== Page 108 ===
EFTA00011638

=== Page 109 ===
OMB Control Number 2120-0729
Expires 04/30/17
Note: Twelve (12) owner names may be entered on this page. If you require more, enter the first 12 names and then print
this page by pressing the 'Print Page 2' button below. Next click the 'Reset' button to clear the data fields (from page 2
only) to add more names. Repeat action as needed.
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
AC Form 8050-1B (04/12)
REF N-NUM: 401HB
EFTA00011639

=== Page 110 ===
EFTA00011640

=== Page 111 ===
OMB Control Number 2120-0729
Expires 2/29/15
Paperwork Reduction Act Statement: The information collected on this form is necessary to maintain aircraft registration. We estimate that it will take approximately 30
minutes to complete the form. Please note that an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a
valid OMB control number. Form Approved, OMB No. 2120-0729 "Comments concerning the accuracy of this burden and suggestions for reducing the burden should be
directed to the FAA at: 800 Independence Avenue SW, Washington, DC 20591. ATTN: Information Collection Clearance Officer, AES-200."
FAILURE TO RENEW REGISTRATION WILL
DEPARTMENT OF TRANSPORTATION - FEDERAL AVIATION ADMINISTRATION
RESULT IN CANCELLATION OF REGISTRATION
AIRCRAFT REGISTRATION RENEWAL APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
(See 14 C.F.R. §§ 47.15(i), 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 401HB
5173
MANUFACTURER
MODEL
GULFSTREAM AEROSPACE
GV-SP (G550)
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
04/02/2008
04/30/2017
CORPORATION
ENTER REGISTERED OWNER(S) & ADDRESS FROM FAA FILE
HELPFUL INFORMATION
(Owner 1) CHEVRON U S A INC
Review Aircraft Registration File Information for this aircraft
at: http://registry.faa.gov/aircraftinquiry.
(Owner 2)
Note: Enter any additional owner names on page two.
Assistance may be obtained
at our web page: http://registry.faa.gov/renewregistration.
(Address)
by e-mail at:
(Address)
by telephone at::
City OAKLAND
State CA Zip 94621-4543
When mailing fees, please use a check or money order made
Country UNITED STATES
payable to the Federal Aviation Administration
Physical Address: Required when mailing address is a P.O. Box or mail drop.
Signature and Title Requirements for Common Registration Types:
(Address)
- Individual
owner must sign, title would be "owner".
- Partnership
general partner signs showing "general partner" as
(Address)
title.
City
State
Zip
- Corporation
corporate officer or manager signs, showing full title.
Country
- Limited Liability Co
authorized member, manager, or officer identified in
the LLC organization document signs, showing full title.
TO RENEW REGISTRATION: REVIEW aircraft registration information,
Co-owner
each co-owner must sign; showing "co-owner" as title.
Government
authorized person must sign and show their full title.
SELECT the appropriate statement, ENTER any change in address in the
spaces below, SIGN. DATE. & SEND form with the $5 renewal fee to the:
Note: All signatures must be in ink, or other permanent media.
FAA Aircraft Registry, PO Box 25504, Oklahoma City OK 73125-0504, or
To correct entries: Draw a single line through error. Make correct entry in
by courier to: 6425 S Denning Rm 118, Oklahoma City OK 73169-6937
remaining space, or complete the form on-line. An application form will be
rejected if any entry is covered by correction tape or similarly obscured.
I (WE) CERTIFY, THE NAME(S) AND ADDRESSES FROM THE FAA FILES
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CHECK All applicable block(s) below, COMPLETE SIGN. DATE & MAIL
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY.
this form with any fees to the: FAA Aircraft Registry,
PO Box 25504, Oklahoma City, OK, 73125-0504, or by courier to:
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW.
6425 S Denning Rm. 118, Oklahoma City OK 73169-6937
I (WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
THIS AIRCRAFT IS CORRECT, OWNERSHIP MEETS THE CITIZENSHIP
CANCELLATION OF REGISTRATION IS REQUESTED.
REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS NOT REGISTERED
THE AIRCRAFT WAS SOLD TO:
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
(Show purchaser's name and address.)
NEW MAILING ADDRESS
THE AIRCRAFT IS DESTROYED OR SCRAPPED.
NEW PHYSICAL ADDRESS: complete if physical address has changed, or
THE AIRCRAFT WAS EXPORTED TO:
the new mailing address is a PO Box or Mail Drop.
OTHER, Specify
PLEASE RESERVE N-NUMBER IN THE OWNER'S NAME
AND ADDRESS. The $10 reservation fee is enclosed.
SIGNATURE OF OWNER 1 (required field)
PRINTED NAME OF SIGNER
(required field)
TITLE
(required field)
DATE
Electronically Certified by Registered Owners
12/4/2013
SIGNATURE OF OWNER 2
PRINTED NAME OF SIGNER
TITLE
DATE
Use page 2 for additional signatures.
Fee paid: $5 (201312041628370511NB)
AC Form 8050-1B (04/12)
EFTA00011641

=== Page 112 ===
EFTA00011642

=== Page 113 ===
OMB Control Number 2120-0729
Expires 2/29/15
Note: Twelve (12) owner names may be entered on this page. If you require more, enter the first 12 names and then print
this page by pressing the 'Print Page 2' button below. Next click the 'Reset' button to clear the data fields (from page 2
only) to add more names. Repeat action as needed.
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
AC Form 8050-1B (04/12)
REF N-NUM: 401HB
EFTA00011643

=== Page 114 ===
EFTA00011644

=== Page 115 ===
PRINT PAGE 1
PRIVACY ACT STATEMENT
OMB Control Number 2120-0729
Expires 2/29/2012
Paperwork Reduction Act Statement: The information collected on this form is necessary to obtain aircraft re-registration. We estimate that it will take approximately 30
minutes to complete the form. Please note that any agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays
a valid OMB control number. Form Approved, OMB No. 2120-0729
"Comments concerning the accuracy of this burden and suggestions for reducing the burden should be directed to the FAA at: 800 Independence Avenue SW. Washington, DC
20591. ATTN: Information Collection Clearance Officer, AES-200
Accepted LT Apr/12/2011
DEPARTMENT OF TRANSPORTATION-FEDERAL AVIATION ADMINISTRATION
FAILURE TO RE-REGISTER WILL RESULT
IN CANCELLATION OF REGISTRATION
AIRCRAFT RE-REGISTRATION APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
(See 14 C.F.R. 95 47.15(i). 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 401HB
5173
MANUFACTURER
MODEL
GULFSTREAM AEROSPACE
GV-SP (G550)
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
APRIL 02, 2008
JUNE 30, 2011
CORPORATION
NAME AND MAILING ADDRESS OF REGISTERED OWNER
INFORMATION FOR COMPLETION
(If individual, give last name, first name and middle initial)
(Owner 1) CHEVRON USA INC
Additional information may be obtained at our web page
http://registry.faa.gov/renewregistration or by phone at 866-762-9434
(Owner 2)
Aircraft Registration Information may be reviewed at:
Note: Enter any additional owner names on page two of this document.
http://registry.faa.gov/aircraftinguiry
(Address)
Please pay fees with a check or money order payable to the
(Address)
Federal Aviation Administration
City SAN RAMON
State CA Zip 94583-2324
Signature Requirements for Listed Registration Types:
Country UNITED STATES
Individual
owner must sign.
PHYSICAL ADDRESS (REQUIRED WHEN MAILING ADDRESS IS A P.O. BOX
Partnership
a general partner must sign.
OR MAIL DROP)
Corporation
a corporate officer or managing official must sign.
Limited Liability Co.
a member, manager, or officer who is authorized to
(Address)
manage the LLC must sign.
(Address)
Co-owner
each co-owner must sign, continuing as necessary.
on page number two.
City
State
Zip
Government
any authorized person may sign.
Country
Note: All signatures must be In Ink.
TO RE-REGISTER AIRCRAFT: REVIEW REGISTRATION INFORMATION,
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
ENTER CORRECTIONS IN BLANKS PROVIDED, CHECK APPLICABLE
THE LAST REGISTERED OWNER MUST: MARK THE APPLICABLE
BLOCK BELOW. SIGN. DATE. & MAIL WITH THE $5 FEE. To: The FAA
BLOCK(S). COMPLETE. SIGN, DATE & Mail with any fees to: The
Aircraft Registration Branch, PO Box 25504. Oklahoma City. OK, 73125-0504.
FAA Aircraft Registration Branch, PO Box 25504, Oklahoma City, OK,
73125-0504.
I (WE) CERTIFY THE: NAME(S) AND MAILING ADDRESS SHOWN ABOVE
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CANCELLATION OF REGISTRATION IS REQUESTED FOR THE
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY
REASON MARKED BELOW,
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW. I
1. THE AIRCRAFT WAS SOLD TO:
(WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
(Show purchaser's name and address)
THIS AIRCRAFT IS CORRECT. OWNERSHIP MEETS THE CITIZENSHIP
REQUIREMENTS OF 14 CFR $47.3. AIRCRAFT IS NOT REGISTERED
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
MAILING ADDRESS 7799 EARHART ROAD
OAKLAND, CA 94621
2. THE AIRCRAFT IS DESTROYED OR SCRAPPED.
3. THE AIRCRAFT WAS EXPORTED TO:
PHYSICAL ADDRESS: COMPLETE IF PHYSICAL ADDRESS HAS
CHANGED. OR NEW MAILING ADDRESS IS A PO BOX OR MAIL
DROP.
4. OTHER, Specify
UPON CANCELLATION, PLEASE RESERVE THE N-NUMBER
IN OWNERS' NAME. The $10 check or money order for the N-
number reservation fee is enclosed.
TITLE
DATE
Assistant Secretary
2/8/2011
SIGNATURE OF OWNER 2
PRINTED NAME OF SIGNER
TITLE
DATE
110660826086
AC Form 8050-1A (10/10)
$5.00 03/07/2011
EFTA00011645

=== Page 116 ===
EFTA00011646
AIRCRAFT REGISTRATION
BR
2011 MAR 7 AM 8 34
OKLAHOMA CITY
OKLAHOMA

=== Page 117 ===
DOCUMENT LEVEL ANNOTATIONS FOR DOCUMENT ARE002412672
REV/DOI - 4/2/2008
EFTA00011647

=== Page 118 ===
EFTA00011648

=== Page 119 ===
U.S. Department
Flight Standards Service
of Transportation
Aircraft Registration Branch,
Oklahoma City, Oklahoma 73125-0504
AFS-750
Federal Aviation
Toll Free:
Administration
WEB Address:
Date of Issue: April 2, 2008
CHEVRON USAINC
SAN RAMON, CA 94583-2324
HAND DELIVERED TO ARTC IN THE PD ROOM
T082390
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N401HB GULFSTREAM AEROSPACE GV-SP (G550) Serial 5173 and is valid until May
02, 2008.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
for
Manager, FAA Aircraft Registry, AFS-750
Federal Aviation Administration
AFS-750-FAX-4 (10/05)
EFTA00011649

=== Page 120 ===
EFTA00011650

=== Page 121 ===
ASSIGNMENT OF SPECIAL REGISTRATION NUMBERS
Special Registration Number
N
Aircraft Make and Model
401HB
U.S. Department
GULFSTREAM AEROSPACE
GV-SP (6550)
of Transportation
Present Registration Number
Federal Aviation
Serial Number
Administration
5173
3960203
N
673GA
Issue Date:
ICAO AIRCRAFT ADDRESS CODE
NOVEMBER 14, 2007
FOR N401HB = 51130411
This is your authority to change the United States registra-
tion number on the above described aircraft to the special
GULFSTREAM AEROSPACE CORP
registration number shown.
SAVANNAH GA 31408-9643
Carry duplicate of this form in the aircraft together with the
old registration certificate as interim authority to operate the
aircraft pending receipt of revised certificate of registration.
Obtain a revised certificate of airworthiness from your near-
est Flight Standards District Office.
The latest FAA Form 8130-6, Application
NUMBER CHANGED TO
401HB
For Airworthiness on file is dated:
DATE
18 FEB 05 2008
The airworthiness classification and category:
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, AFS-750, within 5 days after the special registration number is
placed on the aircraft. A revised certificate will then be issued.
The authority to use the special number expires:
NOVEMBER 14, 2008
CERTIFICATION: I certify that the special registration number was placed on the
RETURN FORM TO:
aircraft described above:
Civil Aviation Registry, AFS-750
Signature of Owne
Oklahoma City, Oklahoma 73125-0504
Title of Owner:
Contract Administrator
Date Placed on Aircraft:
1/23/08
AC Form 8050-64
(5/2005) Supersedes Previous Edition
EFTA00011651

=== Page 122 ===
AMEILED WITH FAA
AIRCRAFT REGISTRATION BR
2008 JAN 23 . PM 3 19
OKLAHOMA CITY
OKLAHOMA

=== Page 123 ===
AIRCRAFT TITLE SEARCHES
Aero Records & Title Co./N
RECORDING SERVICES
4
AIRMEN RECORD INFORMATION
ARICO
Oklahoma City, OK 73144
October 25, 2007
Hand Delivered
To:
FAA
Oklahoma City, Oklahoma
401HB
Attention:
Central Records
-64 673GA
Gentlemen:
18 NOV 14 2007
On behalf of our client:
GULFSTREAM AEROSPACE CORP.
Savannah, GA 31407
Please initiate the following action:
1. Please RESERVE the following special registration number:
N401HB
PLEASE HAND THE CONFIRMATION OF RESERVATION LETTER TO
ARTC IN THE PUBLIC DOCUMENTS ROOM.
2. Please ASSIGN N401HB to the following described aircraft which
is registered to our client above:
GULFSTREAM AEROSPACE GV-SP (G550)
SERIAL NUMBER 5173
CURRENTLY N673GA
PLEASE HAND THE ORIGINAL FORM 8050-64 TO ARTC IN THE PUBLIC
DOCUMENTS ROOM.
Thank you.
072981539402
$10.00 10/25/2007
X
PLEASE HAND CONFIRMATION OF RESERVATION LETTER TO ARTC - PUBLIC DOCUMENTS ROOM.
X
PLEASE HAND ORIGINAL FORM 8050-64 TO ARTC - PUBLIC DOCUMENTS ROOM.
Thank you,
AERO
By:
strator, Special Services
/1g
Fee Attached: $ 10.00
CC:
Gulfstream Aerospace Corp.
EFTA00011653

=== Page 124 ===
EFTA00011654
FILED WITHFAA
AIR 27 7 RECISTR ATSH DR
'07 OCT 25 PM 3 28
OKLAHOMA CITY
CKLAHOMA

=== Page 125 ===
DECLARATION
OF
INTERNATIONAL OPERATIONS
Accepted PH Apr/02/2008
The undersigned owner of aircraft N401HB, Manufacturer Gulfstream Aerospace
Corporation Model No. GV-SP (G550) Serial No. 5173 declares that this aircraft is
scheduled to make an international flight on April 14, 2008 departing Oakland,
California, USA, with a destination of London, England, United Kingdom.
Expedited registration in support of this international flight is requested this 27th day of
March, 2008 with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of
the Government of the United States, knowingly and willfully makes or
uses any false writing or document knowing the same to contain any
materially false, fictitious or fraudulent statement or representation shall
be fined under Title 18 United States Code or imprisoned not more than 5
years, or both. 18 U.S.C. 1001(a).
Name of Owner:
Chevron U.S.A. Inc.
Typed Name a
nager Flight Operations
Signature:
Comments:
Filed by: AERO RECORDS & TITLE CO.
(telephone number)
EFTA00011655

=== Page 126 ===
EFTA0001165
FILED WITH FAA
AIRCRAFT T REGISTRATION BR
2008 MAR 27 PM 1 25
OKLAHOMA CITY
OKLAHOMA

=== Page 127 ===
FORM APPROVED
OMB No. 2120-0042
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION-MEKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
CERT. ISSUE DATE
UNITED STATES
REGISTRATION NUMBER
N
401
HB
AIRCRAFT MANUFACTURER & MODEL
GULFSTREAM AEROSPACE GV-SP (G550)
AIRCRAFT SERIAL No.
5173
FOR FAA USE ONLY
Accepted PH Apr/02/2008
TYPE OF REGISTRATION (Check one box)
1. Individual
2. Partnership
X
3. Corporation
4. Co-owner
5. Gov't.
8. Non-Citizen
Corporation
NAME OF APPLICANT (Person(s) shown on evidence of ownership. If individual, give last name, first name, and middle initial.)
CHEVRON U.S.A. INC.
TELEPHONE NUMBER: (510) 430-2935
ADDRESS (Permanent mailing address for first applicant listed.) (If P.O. BOX is used, physical address must also be shown.)
Number and street:
Rural Route:
P.O. Box:
CITY
STATE
ZIP CODE
SAN RAMON
CA
94583
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion MUST be completed.
A false or dishonest answer to any question in this application may be grounds for punishment by fine and / or imprisonment
(U.S. Code, Title 18, Sec. 1001).
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant, who is a citizen (including corporations)
of the United States.
(For voting trust, give name of trustee:
). or:
CHECK ONE AS APPROPRIATE:
a.
A resident alien, with alien registration (Form 1-151 or Form 1-551) No.
b.
A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States. Records or flight hours are available for
inspection at
(2) That the aircraft is not registered under the laws of any foreign country: and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
TYPE
DATE
ST. SECRETARY
3/19/2008
EACH PART OF THIS
APPLICATION MUST
BE SIGNED IN INK.
SIGNATURE
TITLE
DATE
3-27-08
SIGNATURE
TITLE
DATE
NOTE Pending receipt of the Certificate of Aircraft Registration, the aircraft may be operated for a period not in excess of 90
days, during which time the PINK copy of this application must be carried in the aircraft.
AC Form 8050-1 (5/03) (0052-00-628-9007)
EFTA00011657

=== Page 128 ===
EFTA00011658
AIRCRAFT REGISTRATION BR
FILED WITHFAA
2008 MAR 27 PM 1 25
OKLAHOMA.CITY

=== Page 129 ===
FORM APPROVED
OMB NO. 2120-0042
UNITED STATES OF AMERICA
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $1.00 & OVC THE
UNDERSIGNED OWNER(S) OF THE FULL LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER N 401HB
AIRCRAFT MANUFACTURER & MODEL
Gulfstream Aerospace GV-SP (G550)
AIRCRAFT SERIAL NO.
5173
DOES THIS 27th DAY OF march 2008,
PH000007 Conveyance Recorded Apr/02/2008 08:11 AM FAA
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write In This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL (S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
PURCHASER
Chevron U.S.A. Inc.
San Ramon, CA 94583
DEALER CERTIFICATE NUMBER
AND TO ITS SUCCESSORS, EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF.
IN TESTIMONY WHEREOF WE HAVE SET OUR HAND AND SEAL THIS 274h DAY OF march 2008.
NAME (S) OF SELLER
SIGNATURE (S)
TITLE
(TYPED OR PRINTED)
(TYPED OR PRINTED)
SELLER
Gulfstream Aerospace Corporation
Manager
ACKNOWLEDGEMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED
BY LOCAL LAW FOR VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA
AC Form 8050-2 (9/92) (NSN 0052-00-629-0003) Supersedes Previous Edition
080871324467
$5.00 03/27/2008
EFTA00011659

=== Page 130 ===
EFTA00011660
FILED
AIRCRAFT REGISTRATION BR
2008 MAR 27 PM 1 25
OKLAHOMA CITY

=== Page 131 ===
U.S. Department
Flight Standards Service
of Transportation
Aircraft Registration Branch, AFS-750
Oklahoma City, Oklahoma 73125-0504
Federal Aviation
Toll Free:
Administration
WEB Address:
March 1, 2007
GULFSTREAM AEROSPACE CORP
SAVANNAH GA 31408
Dear Sirs:
United States identification mark N673GA has been assigned to Gulfstream Aerospace GV-SP
(G550), serial number 5173, Mode S Transponder Code 52163564 as requested by you. This
manufacturer's assignment of special registration number cannot be used as an authorization for a
number change.
If we may be of further assistance, please contact the Aircraft Registration Branch at
or toll free
Sincerely,
Legal Instruments Examiner
Aircraft Registration Branch
AFS-750-SUPPORT-5 (04/06)
EFTA00011661

=== Page 132 ===

=== Page 133 ===
Gulfstream
AGENTRAL
A 6736A
O6 FEB 26 2007
February 15 ) 2007
Federal Aviation Administration
FAA Aircraft Registry
Oklahoma City, OK 73125
ATTENTION: CENTRAL RECORDS DIVISION
Dear Madam/Sir:
Please reserve and assign the enclosed special registration numbers for
Gulfstream Aerospace Corporation.
Once these numbers have been reserved and assigned in the name of
Gulfstream Aerospace Corporation, please hand confirmations to ARTC in the
PD Room. If the above requested numbers are not available, please contact
Lisa homas at ARTC immediately.
Thank you for your assistance with this request.
Very truly yours.
Enclosure
070471458332
$420.00 02/16/2007
EFTA00011663

=== Page 134 ===
EFTA00011664
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2007 FEB 16 PM 2 53
OKLAHOMA CITY
OKLAHOMA

=== Page 135 ===
Reserve:
Assign to:
TEBID#
1.
N
494
GA
Gulfstream Model GIV-X (G350)
S/N
4094
2.
N
495
GA
Gulfstream Model GIV-X (G450)
S/N
4095
3.
N
496 GA
Gulfstream Model GIV-X (G450)
S/N
4096
4.
N
397
GA
Gulfstream Model GIV-X (G450)
S/N
4097
5.
N
398
GA
Gulfstream Model GIV-X (G450)
S/N
4098
6.
N
199 GA
Gulfstream Model GIV-X (G450)
S/N
4199
7.
N
120 GA
Gulfstream Model GIV-X (G450)
S/N
4100
8.
N
401
GA
Gulfstream Model GIV-X (G450)
S/N
4101
9.
N
702
GA
Gulfstream Model GIV-X (G450)
S/N
4102
10.
N
603
GA
Gulfstream Model GIV-X (G450)
S/N
4103
11.
N
704
GA
Gulfstream Model GIV-X (G450)
S/N
4104
12.
N
405
GA
Gulfstream Model GIV-X (G450)
S/N
4105
13.
N
606
GA
Gulfstream Model GIV-X (G450)
S/N
4106
14.
N
607
GA
Gulfstream Model GIV-X (G450)
S/N
4107
15.
N
608
GA
Gulfstream Model GIV-X (G450)
S/N
4108
16.
N
609
GA
Gulfstream Model GIV-X (G450)
S/N
4109
17.
N
610
GA
Gulfstream Model GIV-X (G450)
S/N
4110
18.
N
131
GA
Gulfstream Model GIV-X (G350)
S/N
4111
19.
N
612
GA
Gulfstream Model GIV-X (G450)
S/N
4112
20.
N
913
GA
Gulfstream Model GIV-X (G450)
S/N
4113
21.
N
614 GA
Gulfstream Model GIV-X (G450)
S/N
4114
S/N
4115
22.
N
815 GA
Gulfstream Model GIV-X (G450)
23.
N
764
GA
Gulfstream Model GV-SP (G550)
S/N
5164
24.
N
965
GA
Gulfstream Model GV-SP (G550)
S/N
5165
25.
N
966
GA
Gulfstream Model GV-SP (G550)
S/N
5166
26.
N
967
GA
Gulfstream Model GV-SP (G550)
S/N
5167
668
GA
Gulfstream Model GV-SP (G550)
S/N
5168
27.
N
28.
N
569
GA
Gulfstream Model GV-SP (G550)
S/N
5169
29.
N
770
GA
Gulfstream Model GV-SP (G550)
S/N
5170
30.
N
GA
Gulfstream Model GV-SP (G550)
S/N
5171
971
31.
N
972
GA
Gulfstream Model GV-SP (G550)
S/N
5172
32.
N
673
GA
Gulfstream Model GV-SP (G550)
S/N
5173
33.
N
974
GA
Gulfstream Model GV-SP (G550)
S/N
5174
34.
N
975
GA
Gulfstream Model GV-SP (G550)
S/N
5175
35.
N
476
Gulfstream Model GV-SP (G550)
S/N
5176
GA
36.
N
977
GA
Gulfstream Model GV-SP (G550)
S/N
5177
37.
N
978
Gulfstream Model GV-SP (G550)
S/N
5178
GA
S/N
5179
38.
N
979
GA
Gulfstream Model GV-SP (G550)
39.
N
Gulfstream Model GV-SP (G550)
S/N
5180
980
GA
40.
N
181
GA
Gulfstream Model GV-SP (G550)
S/N
5181
41.
N
782
GA
Gulfstream Model GV-SP (G550)
S/N
5182
42.
N
983
GA
Gulfstream Model GV-SP (G550)
S/N
5183
EFTA00011665

=== Page 136 ===
EFTA00011666
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2007 FEB 16 PM 2 53
OKLAHOMA CITY
OKLAHOMA

=== Page 137 ===
Aero Records & Title Co.
799138
Post Office Box 19246. Oklahoma City, OK 73144
Phone (405) 685-4250
(800) 654-7202
Fax: (405) 681-2047
AR
Escrow Toll Free: (800) 500-7457
February 16, 2007
REQUEST
FOR
MANUFACTURER
N#
Aircraft Title Searches
ASSIGNMENTS
Professional Escrow and Closing
Services
Recording Services
Federal Aviation Administration
Reservation and Assignment of
Civil Aviation Registry
Special Registration Numbers
Aircraft Title Insurance
Aircraft Registration Branch
$1031 Like-Kind Exchange Services
Attention: Central Records
Reference: (42) Registration Number Assignments
Gentlemen/Ladies:
On behalf of our client:
GULFSTREAM AEROSPACE CORPORATION
Physical address for
courier deliveries:
3300 South Lakeside Drive
SAVANNAH, GA 31407
Oklahoma City, OK 73179
Please reserve & assign forty-two (42) special
registration numbers as listed on Gulfstream's
enclosed letter. Please issue 8050-7 forms to
Gulfstream at the address shown above. PLEASE
HAND COPIES OF THE ASSIGNMENT LETTERS
TO ARTC IN THE P.D. ROOM.
www.aerorecords.com
The necessary $420.00 fee for reservation of the
special registration numbers is enclosed.
Special Services Administrator
Aero Records & Title Co. is
a subsidiary of Fidelity National
/lg
Title Insurance Company
a member of the
Enclosures: letter by Gulfstream & check for $420.
Fidelity National Financial, Inc.
family of companies.
CC:
/Gulfstream
EFTA00011667

=== Page 138 ===
EFTA00011668
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2007 FEB 16 PM 2 53
OKLAHOMA CITY
OKLAHOMA


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=== Page 1 ===
From:
"
To:
Subject: Fwd: MCC Pros Memo
Date: Fri, 27 Sep 2019 14:55:06 +0000
Attachments: MCC_Pros_Memo_v10.doc; ATT00001.htm
Begin forwarded message:
From:
Date: September 27, 2019 at 10:42:34 AM EDT
To:
Cc:
Subject: MCC Pros Memo
All,
Please see attached for your review.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00013173


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=== Page 1 ===
From:
Subject: Read: Epstein -- Call with Roy Black
Date: Wed, 18 Jun 2008 17:59:25 +0000
Importance: Normal
EFTA00013838


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 351 Filed 10/15/21 Page 1 of 4
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
USDC SDNY
One Saint Andrew's Plaza
DOCUMENT
New York, New York 10007
ELECTRONICALLY FILED
DOC #:
DATE FILED: 10/15/21
October 15, 2021
For the reasons stated in this letter, the Court finds that
BY ECF
there is good cause for any motion under Federal Rule of
The Honorable Alison J. Nathan
Evidence 412 to be filed no later than October 27, 2021.
United States District Court
Any response will be due November 1, 2021. Any hearing
Southern District of New York
will tentatively be scheduled for November 5, 2021.
United States Courthouse
Additional details will be provided if and when any motions
40 Foley Square
are filed. SO ORDERED.
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Alia I. New
10/15/21
Dear Judge Nathan:
The Government respectfully submits this letter in response to the Court's Order dated
October 14, 2021 (Dkt. No. 347) ordering the Government to respond to the defendant's October
14, 2021 letter regarding the deadline for filing a motion under Federal Rule of Evidence 412 (Dkt.
No. 345). In particular, the defendant wrote the Court to "confirm that November 15, 2021 is the
deadline for [her] to file a motion under Federal Rule of Evidence 412." (Dkt. No. 345).
Federal Rule of Evidence 412(a)(1) provides that in a case involving allegations of sexual
misconduct, "evidence offered to prove that a victim engaged in other sexual behavior" is
inadmissible. The Rule "aims to safeguard the alleged victim against the invasion of privacy,
potential embarrassment and sexual stereotyping that is associated with public disclosure of
intimate sexual details." United States V. Rivera, 799 F.3d 180, 184 (2d Cir. 2015) (quoting Fed.
R. Evid. 412 advisory committee's note). "The exclusion, however, is not absolute" as Rule 412(b)
provides certain exceptions to this general prohibition in criminal cases. Id. Rule 412 provides
that "[i]f a party intends to offer evidence under Rule 412(b)," the party must file a motion
specifically describing the evidence and the purpose of the evidence, Fed. R. Evid. 412(c)(1)(A),
EFTA00011157

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 351 Filed 10/15/21 Page 2 of 4
Page 2
and must "do so at least 14 days before trial unless the court, for good cause, sets a different time."
Fed. R. Evid. 412(c)(1)(B) (emphasis added). This language plainly gives the Court authority to
set a "different" time, not necessarily a "later" time, to require the defense to file a Rule 412
motion. See, e.g., Order, United States V. Andrews, No. 19 Cr. 131 (PAE) (S.D.N.Y. Jan. 29, 2020)
(Dkt. No. 287) (setting a Rule 412 deadline of February 13, 2020, for a March 9, 2020 trial); Order,
United States V. Rivera, No. 19 Cr. 131 (PAE) (S.D.N.Y. Apr. 29, 2020) (Dkt. No. 384) (setting a
Rule 412 deadline of October 15, 2020, for a November 9, 2020 trial); United States V. Dupigny,
18 Cr. 528 (JMF) (S.D.N.Y. Oct. 23, 2019) (Dkt. No. 202) (requiring a "finalized proffer of
evidence" the defense sought to admit under Rule 412 by December 6, 2019, in advance of a
January 13, 2020 trial); United States V. Backman, 817 F.3d 662, 669-70 (9th Cir. 2016)
(concluding that district court did not abuse its discretion when setting Rule 412 deadline more
than 14 days before trial and denying request to amend the motion less than 14 days before trial);
United States V. Valenzuela, No. Cr. 07-11, 2008 WL 2824958, at *4 n.12 (C.D. Cal. July 21,
2008) ("Good cause exists to advance the deadline for filing a Rule 412(c) motion by eleven days
given the complex nature of the action and the volume of evidence that will likely be presented at
trial."); see also Charles Alan Wright & Arthur R. Miller, 23 Fed. Prac. & Proc. Evid. § 5377 (2d
ed. 2020) (explaining that the text of Rule 412(c)(1)(B) "suggests that the court might require that
the motion be filed earlier than 14 days before trial or might permit the motion to be brought later,
including during trial."). Accordingly, the Government respectfully submits that the express terms
of Rule 412 contemplate that the Court can set an earlier briefing schedule.
A deadline more than two weeks in advance of trial is consistent with the Rule's procedural
requirements. Before admitting evidence under Rule 412, the Court "must conduct an in camera
hearing and give the victim and parties a right to attend and be heard." Fed. R. Evid. 412(c)(2).
EFTA00011158

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 351 Filed 10/15/21 Page 3 of 4
Page 3
"Given that the hearing provides an opportunity for the Rule 412 movant to detail the evidence he
seeks to admit and for the parties to discuss the propriety of its admission, the notice requirement
should be seen as serving two purposes: 1) aiding the Court in determining the threshold matter of
whether a hearing is necessary; and 2) providing sufficient notice to the nonmovant and victim
alike to prepare for and argue against the necessity of any in camera hearing." United States V.
Smith, 19 Cr. 324 (BAH), 2020 WL 5995100, at 19 (D.D.C. Oct. 9, 2020).
Here, the Government produced to the defense a witness list, Giglio material, Jencks Act
material, and notice pursuant to Federal Rule of Evidence 404(b) by October 11, 2021, or 7 weeks
in advance of trial. The Government understands that the Court's schedule for early disclosure of
Jencks Act material and early motions in limine was designed, in part, to ensure that any significant
issues are resolved substantially in advance of trial. The Government respectfully submits that the
Court has "good cause" to set an earlier deadline in order to ensure that any issues stemming from
Rule 412 litigation are resolved in a timely fashion in advance of trial, including the need for the
Government to investigate and meaningfully respond to such sensitive and important issues. See
Smith, 2020 WL 5995100, at *19.
Additionally, a deadline of 14 days before trial for the defense's Rule 412 motion is not
practical in light of the trial schedule. Under the defense schedule, the defense will file their Rule
412 motion on November 15, 2021, and give notice to both the Government and victims. See Fed.
R. Evid. 412(c)(1)(D). At some point over the following two weeks-during jury selection and
the Thanksgiving holiday-the Government will respond to the motion, and the Court "must
conduct an in camera hearing" that gives the parties and the victims the right to be heard. See Fed.
R. Evid. 412(c)(2). Given that there are multiple victim witnesses and the defense has not yet
notified the Government whether it intends to make a Rule 412 motion as to one or more than one
EFTA00011159

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 351 Filed 10/15/21 Page 4 of 4
Page 4
of them, there may be a need for multiple such hearings. The Court must then adjudicate the
motion before trial starts or during trial. There is no reason to impose the defense's cramped
schedule on the Court or the parties, particularly where the motion concerns such sensitive issues.
For these reasons, the Government respectfully submits that the Court should maintain the
October 18, 2021 in limine deadline as the deadline for the defense to file a motion under Rule
412, or order that any Rule 412 motion be made, at the latest, by October 25, 2021.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By:
s/
Assistant United States Attorneys
Southern District of New York
Cc: Defense counsel (By ECF)
EFTA00011160


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=== Page 1 ===
From: "Acosta, Alex (USAFLS)"
To:
(USAFLS)"
Subject: FW: Epstein - On behalf of Jay Lefkowitz and Ken Star
Date: Fri, 20 Jun 2008 20:58:58 +0000
Importance: Normal
Attachments:Letter_to_J_Roth_from_S._Thacker.pdf,Response_to_FAUSA
Letter.pdf;
Summary_Of_Misconduct.pdf; Principal_Submission.pdf
Pls print
From:
If
(USAFLS)
Sent: Friday, June 20, 2008 2:44 PM
To: Acosta, Alex (USAFLS)
Subject: FW: Epstein - On behalf of Jay Lefkowitz and Ken Star
fyi
From: Roth, John (ODAG) (SMO)
Sent: Friday, June 20, 2008 1:56 PM
To:
(USAFLS);
(USAFLS)
Subject: FW: Epstein - On behalf of Jay Lefkowitz and Ken Star
This was just dropped on me. Given the volume of material, I think it will be best to wait until Monday to call Lefkowitz. Let
me know if that upsets your plans too much.
From: Ami Sheth [mailto:
Sent: Friday, June 20, 2008 12:26 PM
To: Roth, John (ODAG)
Cc: Jay Lefkowitz; Kenneth Starr; Ken Starr
Subject: Epstein - On behalf of Jay Lefkowitz and Ken Star
Dear Mr. Roth,
As promised in yesterday's letter to you, we have attached the following documents to this email: (1) Principal Submission,
(2) Summary of Misconduct, (3) Response to FAUSA
Letter and (4) Response to CEOS's Letter by Stephanie
Thacker.
We respectfully request and would greatly appreciate the opportunity to speak with you in person about this matter.
Kind Regards,
Kenneth W. Starr and Jay P. Lefkowitz
Kirkland & Ellis LLP
The information contained in this communication is
confidential, may be attorney-client privileged, may
EFTA00013602

=== Page 2 ===
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013603


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=== Page 1 ===
From:
(USANH)"
To:
)"
(USANH)"
Subject: Fwd: SDNY Premises Search Warrant Bundle (second revised) copy
Date: Thu, 02 Jul 2020 12:14:18 +0000
Attachments: SDNY_Premises_Search_Warrant_Bundle_(second_revised)_copy.pdf; ATT00001.htm
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 8:09:59 AM EDT
To:
i
,
(USANH)"
Subject: SDNY Premises Search Warrant Bundle (second revised) copy
EFTA00010376


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=== Page 1 ===
From:
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To:
Subject: Re: Epstein
Date: Mon, 22 Oct 2007 21:23:30 +0000
Importance: Normal
I have not spoken to him but it was our intention to assign the decision to select a lawyer to Judge Davis not for him to
represent the girls. We do not want to select the lawyer who represents the girls. I don't know who said he'd do it but it
wasn't us.
Sent from my BlackBerry Wireless Handheld
Original Message
From: Jay Lefkowitz
To:
(USAFLS)
Cc: Acosta, Alex (USAFLS);
(USAFLS)
Sent: Mon Oct 22 17:10:00 2007
Subject: Re: Epstein
-- I will review these materials this evening and be in touch with you tomorrow with the expectation of wrapping this up
by the end of the day. One question I have, however, is why you say that Judge Davis is a non-starter. I understood that
he was ready, willing and able to serve as the attorney representative. If you have had conversations with him and that is
not the case, please let me know.
I will go over the other issues you raise in your email and will look forward to speaking tomorrow.
Thanks -- Jay
(USAFLS)"
10/22/2007 04:40 PM
To
"Jay Lefkowitz"
CC
"Acosta, Alex (USAFLS)"
(USAFLS)"
Subject
Epstein
Jay,
The Judge Davis issue is a non-starter. We've beaten that horse to death. Regarding your contention that "the attorney
representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or she spends
working to effectuate settlements for the identified women," Alex and I agree that paragraph 7C is sufficient, Regarding the
other points, we have made the following concessions:
1.
Regarding the language concerning a lawyer whose firm is sizeable enough to litigate multiple trials
simultaneously, I have removed paragraph 4 on page 3 of the letter.
2.
Regarding the 150k statutory limit language, I have included a footnote which should satisfy your concern.
EFTA00013515

=== Page 2 ===
3.
Regarding language there may be discovery to test the claims of alleged "victims", please see new paragraph
4 on page 3 which now states as criteria that the firm should have "Experience litigating against large law firms and high
profile attorneys who may test the veracity of the victims' claims."
I have attached the Addendum and the revised letter to Judge Davis. Jay, this needs to be concluded. Alex and I believe
that this is as far as we can go. Therefore, please advise me whether we have a deal no later than COB tomorrow,
Tuesday, October 23, 2007. Thanks,
Original Message
From: Jay Lefkowitz [mailto:
Sent: Friday, October 19, 2007 4:05 PM
To:
(USAFLS)
Subject: Re:
-
I have reviewed your proposed language and wanted to raise a few areas of concern.
First, I am not sure why we are not just asking Judge Davis to represent these women. If he is available, that would save
us a whole additional layer of process. I had thought that was initially the idea. I am not sure why you seem to be moving
in another direction.
I also cannot understand why the draft affirmatively requests that J Davis select a lawyer whose firm is sizeable enough to
litigate multiple trials simultaneously. That seems to be directly at odds with the purpose of the agreement, which is to
facilitate out of court settlements. Indeed, to the extent any woman were to elect to bring an action against Mr. Epstein,
she would not only be free to select any lawyer of her choice, but would be restricted from using the lawyer representative
in this capacity due to the conflicts of interests that would cause. This part of your proposed language is of signficiant
concern to me.
Your letter also indicates the 150k statutory limit without reference to the pre-existing 50G limit. To be sure, any of the
women are free to seek whatever settlement they want, but given the question that exists about the statutory amount, the
letter should not state definitely that it will be 150k.
In addition, you have omitted a few important items from your proposal. Given that Judge Davis or any other potential
attorney representative should understand the scope of the work, the language should make clear that there may be
discovery to test the claims of alleged "victims."
Finally, I think it is important that the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's
hourly rate only for the time he or she spends working to effectuate settlements for the identified women.
Jay
Original Message
From:
(USAFLS)"
Sent: 10/17/2007 01:58 PM AST
To: Jay Lefkowitz
Subject: RE:
<<071015 Special Master Letter2.wpd>> Jay,
Here's our proposed letter to the special master.
Original Message
From: Jay Lefkowitz [mailto:
Sent: Tuesday, October 16, 2007 9:26 AM
To:
(USAFLS)
EFTA00013516

=== Page 3 ===
Subject:
- is there a time today we can speak?
How about 430 pm?
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013517


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=== Page 1 ===
From:
(FBI)"
To:
(USAFLS)"
Subject: Epstein
Date: Fri, 13 Jun 2008 17:05:14 +0000
Importance: Normal
How did the conf call go! Sorry couldn't wait longer!
EFTA00013967


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE:
Date: Thu, 03 Oct 2019 20:13:54 +0000
I take that back. In one of the initial emails FBI sent over, they included a draft agenda. We have since had discussions
indicating we don't believe significant aspects of that draft agenda are appropriate, so what they sent over is not current.
But this is what they sent:
AGENDA
Welcome & Introductions by Executive Management
Investigative team: Explanation of dismissal process after Epstein's suicide; explanation of the judicial process;
importance of interviewing all pertinent victims; all victims entitled to services but not all may be pertinent to the ongoing
investigation
FBI NYO: Safety concerns; media interaction
VSD: Victim rights and services; State Crime Compensation/EVAF
Open Q&A and Closing
From:
USANYS)
Sent: Thursday, October 3, 2019 3:49 PM
To:
(USANYS)
Cc:
USANYS)
Subject:
Didn't we get a rough outline from FBI of what they want to do at these two victim sessions? I can't seem to find. If you
have, can you forward to
?
EFTA00013174


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: CBP Testimony
Date: Wed, 17 Nov 2021 23:45:00 +0000
Attachments: SDNY_GM_00000799-SDNY_GM_00000805.pdf;SDNY_GM_00000806-
SDNY_GM_00000811.pdf; SDNY_GM_00000812-SDNY_GM_00000814pdf,
SDNY_GM_00000815-SDNY_GM_00000819.pdf;SDNY_GM_00000820-
SDNY_GM_0000083.pdf;SDNY_GM_02753139-SDNY_GM_02753141.pdf
SDNY_GM_02753142-SDNY_GM_02753143.pdf
- See attached.
Thanks very much,
From:
Sent: Wednesday, November 17, 2021 4:46 PM
To:
Cc:
i
Subject: [EXTERNAL] CBP Testimony
AUSA
,
I hope that this email finds you well. I understand that you are in need of CBP assistance - specifically testimony regarding
our travel records prior to 2004. We have located an appropriate individual to testify and I would like to facilitate. If you
have a moment to discuss please feel free to reach out to my cell number below.
Best,
Senior Attorney
Office of the Associate Chief Counsel, New York
U.S. Customs and Border Protection
OCC NE Homepage
I am currently teleworking. You may reach me by email or cell
EFTA00010061


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Fwd: Ghislaine Maxwell update
Date: Tue, 20 Jul 2021 19:29:56 +0000
FYI
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: July 20, 2021 at 3:23:36 PM EDT
To:
)"
)"
Cc:
Subject: Fwd: Ghislaine Maxwell update
I know all of the answers except #6. Defer to you on how to handle that one, unless you think that's a better
question for
Thanks.
Sent from my iPhone
Begin forwarded message:
From: "Gadher, Dipesh"
Date: July 20, 2021 at 3:17:20 PM EDT
To:
(USANYS)"
Subject: Ghislaine Maxwell update
Dear Nick
I hope this email finds you well. Since we last spoke, I've been juggling work with the arrival of a lockdown
baby boy - our firstborn - who has left me totally sleep-deprived (and thrilled, of course)!
I wanted to check a few things with you if I may on the Ghislaine Maxwell case:
1) Is it correct to say that there will now be TWO trials - the first on the child sex trafficking charges
(covering the period 1994-2004) and the second on the 2016 perjury charges?
2) Is the main trial still scheduled to start in November?
3) Is there any date set aside for the perjury trial?
4) What does this mean for the maximum sentence that Maxwell can now receive? I think we previously
talked settled on up to 80 years behind bars.
5) Is the investigation into Maxwell and Epstein's network still ongoing?
6) If so, does Prince Andrew remain a person of interest? Have US prosecutors managed to get a statement
from him yet or are there any arrangements in the pipeline to do so?
I'd be grateful if you could drop me line with some responses within the next 48 hours if at possible please.
Many thanks
EFTA00010139

=== Page 2 ===
All the best
Dipesh
The Sunday Times
Tel:
Mob:
"Please consider the environment before printing this e-mail"
This e-mail and any attachments are confidential, may be
legally privileged and are the property of News Corp UK & Ireland
Limited on whose systems they were generated. News Corp UK
& Ireland Limited is the holding company for the News UK group,
is registered in England & Wales under number 81701, has its
registered office at
and
is registered with VAT number GB 243 8054 69. If you have received
this e-mail in error, please notify the sender immediately and
do not
use, distribute, store or copy it in any way. Statements or
opinions in
this e-mail or any attachment are those of the author and are
not
necessarily agreed or authorised by News Corp UK & Ireland Limited
or any member of its group. News Corp UK & Ireland Limited may
monitor outgoing or incoming emails as permitted by law. It
accepts
no liability for viruses introduced by this e-mail or attachments.
News Corp UK & Ireland Limited and its titles
are committed to abiding by
IPSO's regulations and the Editors' Code of Practice that IPSO enforces.
EFTA00010140


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=== Page 1 ===
Event: Accepted: Call with Geoff on Epstein
Start Date: 2019-03-05 21:00:00 +0000
End Date: 2019-03-05 21:30:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-03-05 18:34:06 +0000
Date Modified: 2019-03-05 18:34:06 +0000
Priority: 5
DTSTAMP: 2019-03-05 18:18:03 +0000
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=== Page 1 ===
From:
To:
Subject: FW: Mark Epstein
Date: Mon, 28 Oct 2019 22:29:08 +0000
Doesn't work for me
From:
Sent: Monday, October 28, 2019 6:00 PM
To:
Cc:
Subject: Re: Mark Epstein
I am sorry I would not have confirmed for today. I had a 4 pm doctors appointment scheduled for months. I had told mark
10/31 as well. My apologies. Can we still do 10/31?
Sent from my iPhone
On Oct 28, 2019, at 5:51 PM,
wrote:
Hi
Per my email on October 24 below, we were confirmed for Monday (which was today, October 28).
From:
Sent: Monday, October 28, 2019 5:27 PM
To:
Cc:
Subject: Re: Mark Epstein
Greetings. We are set for 10/31 at three per your direction. Did I miss an update?
Sent from my iPhone
On Oct 28, 2019, at 3:12 PM,
wrote:
Hi
Are you en route? Thanks.
On Oct 24, 2019, at 10:55 AM,
wrote:
EFTA00009856

=== Page 2 ===
We are confirmed for a meeting at 3:00 p.m. on Monday at
See you then. Thanks.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00009857


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=== Page 1 ===
OF
U.S. Department of Justice
UNITED STATES
United States Marshals Service
Office of General Counsel
CG-3, 15th Floor
Washington, DC 20530-0001
September 6, 2019
T. McElwee
78799-06306786@requests.muckrock.com
Re: Freedom of Information Act Request No. 2019USMS34199
Subject: Jeffrey Epstein
Dear Requester:
The United States Marshals Service (USMS) is responding to your Freedom of
Information Act (FOIA) request for agency records pertaining to Jeffrey Epstein.
Pursuant to your request, the USMS conducted a search of its automated files and the
District Office in the Southern District of New York and located 73 responsive pages. Of these
73 pages, 3 pages were found to have originated or contained information which originated from
the Federal Bureau of Prisons. Those documents have been forwarded to that agency for their
review and direct response to you. The remaining 70 pages are being released to you and are
attached hereto. Portions of the pages are being withheld pursuant to FOIA Exemptions (b)(6),
(b)(7)(C), (b)(7)(E), and (b)(7)(F).
FOIA Exemption (b)(6) allows an agency to withhold personnel, medical, and similar
files, the disclosure of which would constitute a clearly unwarranted invasion of personal
privacy. Records that apply to or describe a particular individual, including investigative
records, qualify as "personnel," "medical," or "similar files" under Exemption 6. FOIA
Exemption (b)(7)(C) protects records or information compiled for law enforcement purposes to
the extent that the production of such records or information could reasonably be expected to
constitute an unwarranted invasion of personal privacy. A discretionary release of such records
is not appropriate. See United States Department of Justice (DOJ) V. Reporters Committee for
Freedom of the Press, 489 U.S. 749 (1989).
FOIA Exemption (b)(7)(F) protects law enforcement information that "could reasonably
be expected to endanger the life or physical safety of any individual." 5 U.S.C. § 552(b)(7)(F)
(2006), amended by OPEN Government Act of 2007, Pub. L. No. 110175, 121 Stat. 2524.
Courts have routinely upheld the use of Exemption (b)(7)(F) to protect the identities of law
enforcement agents, as well as protect the names and identifying information of non-law
enforcement federal employees, local law enforcement personnel, and other third persons in
connection with particular law enforcement matters. See Rugiero V. DOJ, 257 F.3d 534, 552
(6th Cir. 2001); Johnston V. DOJ, No. 97-2173, 1998 WL 518529, *1 (8th Cir. Aug. 10, 1998).
EFTA00009972

=== Page 2 ===
Accordingly, the personally identifiable information of law enforcement officers and
government employees was withheld from the responsive documentation. The disclosure of
such sensitive information contained in records compiled for law enforcement purposes to the
public could subject law enforcement officers and other government personnel to harassment and
unwelcome contact. This could disrupt and impede official agency activity, as well as endanger
the safety of law enforcement officials. Additionally, the personally identifiable information of
third parties named in the records was withheld. The disclosure of third party information could
constitute an unwarranted invasion of personal privacy and subject the individuals to
embarrassment, harassment, and undue public attention. Individuals have a recognized privacy
interest in not being publicly associated with law enforcement investigations, not being
associated unwarrantedly with alleged criminal activity, and controlling how communications
about them are disseminated.
FOIA Exemption (b)(7)(E) exempts from release information that would disclose law
enforcement techniques or procedures, the disclosure of which could reasonably be expected to
risk circumvention of the law. Public disclosure of information such as internal URLs, codes,
and internal identifying numbers could assist unauthorized parties in deciphering the meaning of
the codes and numbers, aid in gaining improper access to law enforcement databases, and assist
in the unauthorized party's navigation of these databases. This disclosure of techniques for
navigating the databases could permit people seeking to violate the law to gain sensitive
knowledge and take preemptive steps to counter actions taken by USMS during investigatory
operations. The disclosure of this information serves no public benefit and would not assist the
public in understanding how the agency is carrying out its statutory responsibilities.
For your information, Congress excluded three discrete categories of law enforcement
and national security records from the requirements of the FOIA. See 5 U.S.C. 552(c) (2006 &
Supp. IV (2010)). This response is limited to those records that are subject to the requirements
of the FOIA. This is a standard notification that is given to all our requesters and should not be
taken as an indication that excluded records do, or do not, exist.
If you are not satisfied with the response to this request, you may administratively appeal
by writing to the Director, Office of Information Policy (OIP), United States Department of
Justice, Suite 11050, 1425 New York Avenue, NW, Washington, DC 20530-0001, or you may
submit an appeal through OIP's FOIAonline portal by creating an account on the following web
site: https://foiaonline.regulations.gov/foia/action/public/home Your appeal must be
postmarked or electronically transmitted within 90 days of the date of my response to your
request. If you submit your appeal by mail, both the letter and the envelope should be clearly
marked "Freedom of Information Act Appeal."
You may also contact the USMS FOIA Officer or our FOIA Public Liaison at (703) 740-
3943 for any further assistance and to discuss any aspect of your request. Additionally, you may
contact the Office of Government Information Services (OGIS) at the National Archives and
Records Administration to inquire about the FOIA mediation services they offer. The contact
information for OGIS is as follows: Office of Government Information Services, National
Archives and Records Administration, Room 2510, 8601 Adelphi Road, College Park, Maryland
20740-6001; e-mail at ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448;
or facsimile at 202-741-5769.
EFTA00009973

=== Page 3 ===
Sincerely,
Associate General Counsel
FOIA/PA Officer
Office of General Counsel
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=== Page 1 ===
From:
To: "Roy BLACK"
Cc:
Subject: Notification of Possible Compelled Disclosure of the Non-Prosecution Agreement
Date: Thu, 07 Aug 2008 19:57:52 +0000
Importance: Normal
Attachments: DE19_080801_Victims'_Resp_to_Notice.pdf
Dear Roy:
In accordance with paragraph 13 of the Non-Prosecution Agreement, I am providing notice of possible
compulsory process commanding the disclosure of the Agreement. As I'm sure you know, two of Mr. Epstein's
victims have filed suit against the United States alleging that the government violated their rights as victims by
not consulting them prior to entering into the Non-Prosecution Agreement.
As part of their response to one of the government's filings, the victims asked the Court to order the production
of the Non-Prosecution Agreement. The deadline for the government to respond is August 15th and we intend to
oppose the motion based upon the confidentiality provision. I have attached a copy of the victims' pleading for
your review.
In connection with this, we want to make certain that we are making consistent representations to the judiciary
regarding the contents of the Agreement. I know that Jack Goldberger filed the Agreement under seal in the state
court in accordance with the state judge's order. Can you provide us with a copy of what Jack filed, so that, if
we are ordered by the federal court to disclose the agreement, it is exactly the same as what has been filed in the
state court?
Thank you again for your assistance.
Regards,
Assistant U.S. Attorney
Phone
Fax
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=== Page 1 ===
From:
To:
Subject: Read: Letter re Epstein
Date: Wed, 29 Oct 2008 20:18:30 +0000
Importance: Normal
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Video Interview?
Date: Wed, 13 Oct 2021 00:24:56 +0000
Sorry, looks like this isn't available in our media monitoring system either. If you'd like, I can ask our contacts at NBC if
they'd be willing to give us a copy if it's for internal use only.
From:
Sent: Tuesday, October 12, 2021 8:11 PM
To:
Cc:
Subject: Video Interview?
Hi
I'm trying to find a recorded interview at the below link, but it says it has expired. Do you happen to have this or know
how I would get access? Thanks!
https://www.nbcnews.com/news/us-news/how-british-teen-model-was-lured-jeffrey-epstein-s-web-n105690]
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
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=== Page 1 ===
From:
)"
To:
Subject: Fwd: doc 001 Doe VS Epstein estate complaint.pdf
Date: Mon, 23 Mar 2020 18:17:46 +0000
Attachments: doc_001_Doe_vs_Epstein_estate_complaint.pdf; ATT00001.htm
Sent from my iPhone
Begin forwarded message:
From: Brad Edwards
Date: March 23, 2020 at 13:59:45 EDT
To:
Subject: doc 001 Doe VS Epstein estate complaint.pdf
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=== Page 1 ===
From:
To:
Subject: News Brief
Date: Fri, 22 Feb 2019 22:20:56 +0000
Importance: Normal
Coast Guard Officer Ordered to Jail, Accused of Being 'Domestic Terrorist' [Fox News]
Lt. Christopher Paul Hasson will remain in jail without bail for at least two weeks, a judge ruled Thursday
(02/21/2019).
Federal agents recovered 15 guns and more than 1,000 rounds of ammunition from Hasson's Maryland
apartment.
Investigators say Hasson repeatedly studied a manifesto authored by Anders Behring Breivik, the
Norwegian right-wing extremist who killed 77 people in a 2011 bomb-and-shooting rampage. Prosecutor
Jennifer Sykes claimed Thursday that Hasson would also log onto his government computer during work
and spend hours searching for information on such people as the Unabomber, the Virginia Tech gunman
and anti-abortion bomber Eric Rudolph.
Related Article: Prosecutors Haven't Proved 'Hit List' Coast Guardsman is a Terrorist: Judge [NY Post]
US Citizen Charged in Kidnapping of Journalist in Somalia [Fox News]
According to a criminal complaint unsealed Thursday (02/21/2019) in New York, Abdi Yusuf Hassan was
part of a conspiracy to kidnap a journalist in January 2012 in Galkayo, Somalia, and demand $20 million in
ransom.
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While the journalist is not named in the complaint or in a superseding indictment, the dates of his
capture and release, and several details outlined in the court documents, match the experiences of
author Michael Scott Moore, a German-American. In November, Moore confirmed to the New York Times
that another man indicted in the case, Mohamed Tahlil Mohamed, was one of his captors. Mohamed and
Hassan are listed as co-defendants.
According to court documents, Hassan, 51, was born in Mogadishu and is a naturalized U.S. citizen. He
faces six counts, including kidnapping conspiracy, hostage-taking conspiracy and unlawful use of firearms.
He was arrested in Minneapolis on Friday and will be returned to New York to face charges.
[Analyst's note: Abdi Yusuf Hassan and Mohamed Tahlil Mohamed positive for FBI holdings.]
Global Terrorism
United States (Social Media)
A U.S. citizen suspect was arrested in Minneapolis, Minnesota, and charged with participating in the
kidnapping of a freelance journalist in Somalia, where he was held for nearly three years over a $20
million ransom, media reported Thursday Twitter [Star Tribune].
The suspect was charged in federal court in New York with six felony counts ranging from
kidnapping to hostage-taking to illegal use of firearms
According to the criminal complaint, the suspect and other heavily armed captors abducted the
journalist on Jan. 21, 2012, from a vehicle in the northern Somali city of Galkayo in the Mudug
region
11 American Women Who Left the US to Become ISIS Brides and Fighters [Business Insider]
The State Department announced on Wednesday (02/20/2019) that a US-born woman who left Alabama
to join the Islamic State would not be welcomed home. Secretary of State Mike Pompeo said that Hoda
Muthana "does not have any legal basis, no valid US passport, no right to a passport, nor any visa to
travel to the United States."
According to a report from the George Washington University's Program on Extremism, 72 Americans
have successfully traveled to Syria or Iraq and joined ISIS and other Jihadist groups since 2011. Just 12% of
the travelers have been women.
Trump Calls For More Biometric Scans, Data Sharing To Stop Terrorism [NextGov]
President Donald Trump on Wednesday (02/20/2019) signed the National Strategy to Combat Terrorist
Travel, a new policy document that calls for increased use of biometric technologies and sharing of the
data being collected in order to prevent the travel of known or suspected terrorists.
"Vetting includes automated biographic and/or biometric matching against watchlists and threat
information," the strategy states. The process referenced in the strategy "does not include the physical
screening or inspection of people or goods that may occur at the border, United States Secret Service
venues, or transportation checkpoints."
American Who Joined al-Qaeda, then Turned Informant, Speaks in First TV Interview [CBS]
Bryant Viñas tells 60 Minutes about the time he spent with al-Qaeda before providing key information to
U.S. intelligence.
The lure of fighting for oppressed Muslims in the Middle East pitched in online videos drove troubled
American Muslim-convert Bryant Viñas into the arms of al-Qaeda in Afghanistan, where he spent eight
months training with al-Qaeda. After he was caught in Pakistan and shipped back to the U.S., Viñas
provided key information about his experience.
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Viñas spent eight years talking to the FBI while he was locked up and provided what former FBI acting
director Andrew McCabe termed "incredibly valuable" information including identities of terrorists and
how he made his way from Long Island, New York, into al-Qaeda.
Canadian Who Tried to Join Terror Group in Syria Released from Prison Despite Being 'High Risk to Public
Safety' [Global News]
An Ontario man who travelled to Syria to join an al-Qaida faction is being released from prison less than
two years after pleading guilty, even though the Parole Board of Canada is concerned he might continue
to engage in terrorism.
The Parole Board said Kevin Omar Mohamed had not participated in any de-radicalization efforts and
there was no evidence he was committed to changing his "extremist ideological beliefs."
Although the former University of Waterloo student was sentenced to 4.5 years imprisonment as recently
as October 2017, he is already eligible for statutory release, when the time he had served awaiting trial is
taken into consideration.
German Police Detain 2 in Alleged Islamic Extremist Plot [Star Tribune]
A German-Moroccan couple was arrested Thursday in central Germany on charges they were planning an
Islamic extremist attack. A series of raids included searches of the homes of 12 other suspects, Frankfurt
prosecutors said.
The couple, both 26 and German-Moroccan dual nationals, tried to travel with their two young children
to Syria in 2016 to join the Islamic State extremist group, but were captured in Turkey and deported back
to Germany, Niesen said. They were arrested at their home in the Raunheim area, southwest of Frankfurt
in the state of Hesse.
Overall, some 200 police officers raided 15 homes in Ruesselsheim, Biebesheim, and Raunheim in Hesse
as well as one in Kerpen in North Rhine-Westphalia.
Germany
German authorities arrested two German-Moroccan suspects and charged a dozen others Thursday after a
series of police raids near Frankfurt aimed at disrupting a planned terrorist attack Associated Press
Authorities believe the suspects were in the early stages of planning an attack in Germany, though
officials said they were not aware of an attack target
The suspects, both 26 and German-Moroccan dual nationals, tried to travel to Syria in 2016 to
join ISIS, but were captured in Turkey and deported back to Germany
Overall, some 200 police officers raided 15 homes in the Frankfurt area, resulting in charges against
12 suspects for accessory to planning an attack in Germany
Fabien Clain, French Jihadist and 'Voice of Paris Attacks', Reported Killed [BBC]
Security sources told French media an air strike on Wednesday killed Clain in Baghuz, the last pocket held
by IS.
The US-led coalition fighting IS said it was trying to verify the reports.
Clain became known as the French voice of IS after the 2015 attacks that left 130 people dead.
Afghanistan: Members of a Prominent Terror Gang of Taliban Arrested in Kabul [India Blooms]
Afghanistan security forces have arrested at least four members of a prominent terror gang of Taliban
group during an operation in Kabul city, media reports said on Friday (02/22/2019).
The Taliban group members who belonged to one of the most destructive networks of the group were
arrested during an operation of the Special Forces of Afghan Intelligence which was conducted in the
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vicinity of the 5th police district of Kabul city, the National Directorate of Security, the intelligence
directorate of Afghanistan said in a statement, reported Khaama Press.
The arrested people were identified as Abdullah son of Gul Rasool who is the leader of the network,
Humayoun son of Majnoon, Maiwand son of Sharbat, and Faridullah alias AhmadZia son of Redi Gul.
The detained individuals have confessed that they were recruited in Taliban ranks by one of the Taliban
group leaders Asadullah Nasrat in Paghman district of Kabul and were busy in bombings, armed
robberies, assassinations, harassments, and lootings in Kabul city, according to the National Directorate of
Security.
The U.S. Sent Its Most Advanced Fighter Jets to Blow Up Cheap Opium Labs. Now It's Canceling the Program
[Time]
After hundreds of airstrikes failed to curtail the Taliban's $200 million-a-year opium trade, the U.S.
military quietly ended a yearlong campaign that targeted drug labs and networks laced around the
Afghan countryside.
The U.S. military first began targeting Taliban narcotics facilities with airstrikes and Special Operations
raids in November 2017 when opium production jumped to record highs in Afghanistan. At the time, U.S.
commanders estimated the Taliban operated up to 500 drug labs, which helped fuel their nearly two-
decade long insurgency.
The military's strategy became the latest high-priced failure to slow endemic poppy cultivation and drug
trafficking in Afghanistan. The U.S. has spent $8.9 billion in U.S. counter-narcotics efforts since 2001, yet
the war-torn country has consistently produced about 85% of the world's illicit opium supply.
United Kingdom: Only One in 10 Jihadis Returning from Syria Prosecuted, Figures Reveal [Independent UK]
Amid calls for the government to repatriate Shamima Begum for criminal investigation rather than
remove her British citizenship, police have warned it is "no easy task" to evidence a suspect's activities
abroad.
Ben Wallace, the security minister, said around 40 people "have been successfully prosecuted so far -
either because of direct action they have carried out in Syria or, subsequent to coming back, linked to that
foreign fighting".
But more than 400 people "of national security concern" are believed to have returned from conflicts in
Syria and Iraq.
Amid Loss of Leaders, Unknown Militant Rises in Philippines [Washington Post]
Not much is known about Hatib Hajan Sawadjaan, but the attacks attributed to him heralding his rise are
distinctly savage: A deadly bombing, which authorities say was a suicide attack by a foreign militant
couple, blasted through a packed Roman Catholic cathedral in the middle of a Mass.
The Jan. 27 attack, which killed 23 people and wounded about 100 others on southern Jolo Island, and
another suspected suicide bombing on nearby Basilan Island last July that officials said he masterminded,
put Sawadjaan in the crosshairs of the U.S.-led global campaign against terrorism.
A recent U.S. Department of Defense report to Congress said without elaborating that it believed
Sawadjaan was the "acting emir," or leader, in the Philippines of the Islamic State group, also known by its
acronym ISIS.
Venezuela's Ex-Spy Chief Rejects Maduro, Accusing Leader's Inner Circle of Corruption - By Ana Vanessa
Herrero and Nicholas Casey Feb. 21, 2019 CARACAS, Venezuela - A former intelligence chief in Venezuela who is one
of the government's most prominent figures turned against President Nicolás Maduro on Thursday, calling him a dictator
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with a corrupt inner circle that has engaged in drug trafficking and courted the militant group Hezbollah. In interviews
with The New York Times, the former intelligence chief, Hugo Carvajal, 58, who is a congressman in the governing Socialist
Party, urged the military to break with the president ahead of a showdown with the opposition on Saturday over Mr.
Maduro's blockade of aid shipments on the country's borders. "It has been more than enough," Mr. Carvajal said in a
statement, which was also released in a video online on Thursday and addressed to Mr. Maduro. "You have killed
hundreds of young people in the streets for trying to claim the rights you stole. This without even counting the dead for
lack of medicines and security." "To the generals," he added, "how is it that having the power to allow the entry of
international humanitarian aid to our country to save lives, you would decide not to? Would you be so inhuman? So
hypnotized?" The strong words come amid a wave of other defections by government officials, including a top air force
official, diplomats, military attachés and members of the national guard. This break with the regime, by a man who once
guarded its secrets as intelligence chief, adds a dose of unexpected pressure on the president just three days before the
confrontation over aid at the border with Colombia.
Mr. Carvajal's accusations also added a new twist to the unfolding drama: a willingness to provide evidence that
could be used against Mr. Maduro's government should it fall. Mr. Carvajal - who in 2017 criticized Mr. Maduro for
setting up a second legislature - now provided a valuable weapon to the opposition, which for years has contended that
the president's inner circle has ties to drug runners and militants. President Trump warned Venezuelan military officials
on Monday to abandon Mr. Maduro by the weekend or "lose everything." This was an escalation of American support for
Juan Guaidó, the leader of the opposition, who claims the presidency and has staked his bid on pushing shipments of
humanitarian aid into Venezuela, against Mr. Maduro's wishes. Many of Mr. Guaidó's supporters said they are preparing to
storm a border bridge to force open the blockade on Saturday. In his interview, Mr. Carvajal - who retired from the
intelligence service in 2012, after having served almost 10 years - offered a rare account of the internal workings of a
government in which he said drug trafficking and corruption were commonplace, managed by top figures such as Néstor
Reverol, the interior minister; Tareck El Aissami, a minister who served as vice president; and Mr. Maduro himself. Those
who were combating drugs "were the ones trafficking it, too," he said of Venezuelan officials who face indictments or
sanctions in the United States. Mr. Carvajal is among those accused of drug trafficking by American investigators: He
escaped extradition on drug charges in Aruba in 2014 and was sanctioned by the Treasury Department for having helped
Colombian guerrilla groups smuggle cocaine. In the interviews, Mr. Carvajal admitted to dealings in both worlds.
https://www.nytimes.com/2019/02/21/world/americas/hugo-carvajal-maduro-venezuela.html?
action=click&module=RelatedCoverage&pgtype=Article&region=Footer
Venezuela's former chief of military intelligence declared his support for Guaidó, telling Maduro, "It's been more than
enough." The Wall Street Journal's Ryan Dube and Kejal Vyas report: "Hugo Carvajal, a retired general and current
congressman for the ruling Socialist Party, called for authorities to allow into Venezuela the humanitarian aid that the U.S.
is stockpiling on the Colombian border. Mr. Carvajal, who spent more than three decades in Venezuela's military, also
had a sobering message for active troops, many of whom have been appearing in propaganda videos meant to rile up
nationalist sentiment against what the Maduro regime says is an imminent U.S. invasion."
Sunni Jihad is Going Local - For decades, Sunni jihadism has been characterized by transnational terrorism, suicide
bombing, and excommunication. These three pillars not only attracted the ire of American and European governments,
but turned off many of the jihadists' target constituents, namely Sunnis living in the Muslim world. Yet there are signs that
Sunni extremists are changing their ways, drifting away from the global agenda that reached its apotheosis in al-Qaeda's
attack on the World Trade Center, and toward a hyperlocal one. The transformation is happening in various countries,
including Afghanistan, Yemen, and Mali. Jabhat al-Nusra, al-Qaeda's offshoot in Syria, provides an illustrative example of
how the jihadist threat is changing across the region. In 2016, Jabhat al-Nusra put together a lengthy training manual for
its new recruits. In the roughly 200-page book, obtained by me, the group argues the merits of country-focused jihad over
global jihad. It advises followers that al-Qaeda's stated strategy of going after the "far enemy" was not set in stone, and
that, in the current moment, a focus on anything other than the local fight would be an "unacceptable distraction." (The
Atlantic 2/15)
Iran says Suicide Bomber who hit Revolutionary Guards was Pakistani Iran said Tuesday that at least three Pakistani
citizens were among the assailants responsible for killing 27 members of the Islamic Revolutionary Guards Corps on a bus
last week, including the driver of the explosives-laden car that rammed the vehicle. The February 13 bombing in the
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=== Page 6 ===
southeast region along the Pakistan border was one of the deadliest attacks in years to strike Iran. Iran has often criticized
Pakistan for harboring Sunni Muslim militants from the province, Sistan and Baluchistan. The accusation, reported by
Iran's Tasnim news agency, was made by a commander of the Revolutionary Guards, Brig. Gen. Mohammad Pakpur, at a
ceremony held Tuesday to honor victims of the attack. (New York Times - 2/19)
ISIS Maintains Online Activity despite Significant Territorial Losses - According to a report from Dublin City University,
ISIS continued to maintain an active online presence despite significant territorial losses and a decrease in attacks in the
West. ISIS also continued to rely on the use of cryptocurrency and the dark web for the relative anonymity they both
provide. ISIS continued to regularly disseminate press releases, claims of responsibility for attacks, infographics, and
audio/video messages. These releases were most accessible through the messaging app Telegram. Since its loss of
Raqqa, Syria, ISIS has not published a non-Arabic language magazine-once a key feature of the group's online media
strategy. The last issue of ISIS's Rumiyah Magazine appeared in September 2017. Other violent extremist groups like Boko
Haram have mimicked ISIS's online strategy, posting the same type of propaganda and even used similar branding and
templates in their online claims. (VOX POL - 2/11)
Amazon Drive is hosting Terrorist Content - Terrorist groups usually find ways to exploit the ever expanding services
offered by major online platforms and tech companies, and Amazon Drive is no exception. Designed for storing and
sharing photos, videos, PDFs and other forms of content, it has been adopted by the Islamic State, al-Qaeda and other
organizations as a stable and reliable platform for disseminating their content. They upload it and then share the links to it
with followers and sympathizers, primarily using the encrypted messaging app Telegram - terrorists' "app of choice."
Amazon Drive, established in 2011 and previously known as Amazon Cloud Drive, can store subscribers' photos,
videos and other files for access from mobile devices, desktops or Amazon Fire devices. According to the Amazon website,
"All photos, videos and other files you upload to Amazon Drive are securely and privately stored in your Files and your
Amazon Photos library." While Amazon has guidelines for its many platforms, including specific bans on terrorism,
"bigotry, hatred, or illegal discrimination," or the use of its services by anyone who is "the subject of U.S. sanctions or of
sanctions consistent with U.S. law imposed by the governments of the country where you are using Amazon Services," it
has not been proactive in removing terrorist content. Terrorist activity and content on Amazon Drive is the subject of a
new report by my organization, the Middle East Media Research Institute and its Cyber & Jihad Lab, documenting how
ISIS and other groups like it have been using this free service. The examples in the report include Amazon Drive links to
content such as videos by ISIS, audio messages by its leaders, and official newsletters and other content created by the
group, its secondary media organizations and its supporters. (USA Today - 2/20)
Global Terrorism
Saudi Arabia
The U.S. Department of State issued a Level 2 Travel Advisory for Saudi Arabia on Thursday due to
"terrorism and the threat of missile and drone attacks on civilian targets" U.S. Department of State
The advisory says to exercise increased caution and warns against travel within 50 miles of the
border with Yemen due to terrorism and armed conflict, areas where the U.S. government has
limited ability to provide assistance
Rebel groups operating in Yemen have fired missiles and rockets into Saudi Arabia,
specifically targeting populated areas and civilian infrastructure, including: the cities of
Riyadh and Jeddah, Riyadh's international airport, Saudi Aramco facilities, and vessels in Red
Sea shipping lanes
These groups are also in possession of unmanned aerial systems, or drones, which they have
used to target similar areas and facilities
Sons of El Chapo Ovidio and Joaquin unsealed indictment for arrest and extradition preparation - Borderland Beat View
article. and NY Times https://www.nytimes.com/2019/02/21/nyregion/el-chapo-sons-indictment.html?
action=click&module=Latest&pgtype=Homepage
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"El Chapo" might be getting a new trial after Vice News reported that at least six jurors ignored the judge's orders of
avoiding social media and any discussion of the case. The drug kingpin's attorneys said they're already planning on filing
a motion requesting the judge question the jury. (Deanna Paul)
Mexican Meth Fuels an American Crisis - The opioid crisis grabs the headlines, but what about the meth crisis?
Methamphetamine, produced by Mexican cartels and smuggled over the southwestern border, killed 10,333 Americans in
2017, more than in any previous year. Worse, preliminary statistics show an increase to more than 12,000 in the year
ending last July. President Trump says there's a "crisis" at the border, and he's right-its result is the meth-overdose
epidemic. (Wall Street Journal - 2/20)
Prosecutors Broke Law in Agreement Not to Prosecute Jeffrey Epstein, Judge Rules -
https://www.nytimes.com/2019/02/21/us/jeffrey-epstein-judge-prosecution-agreement.html?
action=click&module=Latest&pgtype=Homepage
Yahoo News, "The Soviets wanted to infiltrate the Reagan camp. So, the CIA recruited a businessman to bait them," by
Zach Dorfman: "Beginning in 1975, a big black limousine with diplomatic plates would pull up once a month to the no-
parking zone outside John Greenagel's office in the handsome Merchants Exchange Building in downtown San Francisco.
A man would exit the car, paper bag in hand, and ascend the stairs to Greenagel's public relations firm. The man would
hand Greenagel, then in his mid-30s, the paper bag, which always contained stale Cuban cigars and a bottle of Stolichnaya
without a tax stamp. 'Compliments of Mr. Pavlov,' the man would say, and walk out. Yuri Pavlov was a diplomat based at
the Soviet Consulate in San Francisco and an undercover KGB officer after the Soviet bag man left, Greenagel would call
his CIA handler, who would pop over to his office; and they'd laugh and drink the Stoly, smoke the old Cubans and talk
about Greenagel's deepening friendship with Pavlov, which was entirely manufactured. Greenagel was acting as an
'access agent' - providing the CIA with key insights about Pavlov's psychological and personality profile."
West Point CTC Sentinel: February 2019 issue:
A HOLLOW VICTORY OVER THE ISLAMIC STATE IN SYRIA? THE HIGH RISK OF JIHADI
REVIVAL IN DEIR EZ-ZOR'S EUPHRATES RIVER VALLEY
Hassan Hassan
A VIEW FROM THE CT FOXHOLE: SHAUN GREENOUGH, CASE STRATEGY AND MENTOR
SUPERVISOR, THE UNITY INITIATIVE
Paul Cruickshank
PROFIT-MINDED SUPPLIERS: CONVERGENCE OF IED FACILITATION AND WMD
PROLIFERATION NETWORKS FOR NON-STATE ACTORS
Stephen Hummel, F. John Burpo, and James Bonner
THE ELN'S ATTACK ON THE NATIONAL POLICE ACADEMY IN BOGOTÁ AND ITS
IMPLICATIONS
Ross Dayton
MTA Daily:
Significant Dates in History
February 22, 2005
Washington, D.C.
Man Charged in Alleged Plot to Kill President Bush
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Brief Description: (NY Times) - A Virginia man has been charged with plotting with Middle East terrorists to
assassinate President Bush, either by shooting him on the street or by detonating a car bomb, the Justice
Department said today.
The department said that the suspect, Ahmed Omar Abu Ali, had conspired with terrorists in Saudi Arabia,
with whom he lived there from September 2002 to June 2003, and that he had obtained a religious blessing
from a co-conspirator to carry out the killing.
Mr. Ali, 23, described in recent news reports as a Houston-born American citizen and the valedictorian of his
high school class in suburban Virginia, appeared in federal district court in Alexandria, Va., today. He did not
enter a plea, but scores of his supporters laughed when the charges were read.
Mr. Ali's attorney, Ashraf Nubani, told Magistrate Liam O'Grady that his client was tortured while in Saudi
custody, before he was returned to the United States, The A.P. said. "He has the evidence on his back," the
lawyer said. "He was whipped. He was handcuffed for days at a time."
Magistrate O'Grady assured Mr. Nubani that his client would not be mistreated in American custody.
A federal indictment, setting forth charges that could lead to decades of imprisonment upon conviction,
described the defendant as eager to be a partner in terrorism with Al Qaeda.
"It was defendant Abu Ali's intent to become a planner of terrorist operations like Mohamed Atta and Khalid
Sheikh Mohammed," the document says, referring to the man who piloted the first airliner that struck the
World Trade Center on Sept. 11, 2001, and to one of the masterminds of the plot. (Mr. Mohammed was
captured in Pakistan in March 2003.)
Mr. Ali was arrested by Saudi authorities in Medina on June 9, 2003, on suspicion of being associated with
bombings in Riyadh four weeks earlier that killed more than 30 people, including 9 Americans.
A week after his arrest, the indictment says, a search of Mr. Ali's home in Falls Church turned up documents
praising the Sept. 11 attacks, audio tapes in Arabic promoting the killing of Jews and a battle by Muslims
against Christians and Jews and other incendiary writings.
The indictment says that Mr. Ali traveled between Virginia and Saudi Arabia between 2000 and 2002, and that
from September 2002 on he received lodging from Al Qaeda members who taught him such skills as using
hand grenades and forging documents.
At some time between September 2002 and June 2003 Mr. Ali tried to travel to Afghanistan
through Iran to attack American soldiers, the indictment says, but he could not get the necessary travel
documents.
The accusation that Mr. Ali plotted to kill President Bush was included in a count charging him with
conspiracy to provide material support and resources to foreign terrorists. Between September 2002 and June
2003, the indictment says, Mr. Ali and another conspirator discussed two possibilities: that Mr. Ali would get
close enough to the president "to shoot him on the street," or that he would detonate a car bomb to kill the
president.
Traffic is routinely blocked off when a president travels in an armored limousine with an armed escort. It has
been decades since presidents strolled along city streets, and they are heavily protected by Secret Service
agents wherever they go. But John W. Hinckley Jr. proved that a close-range shooting is not impossible, when
he wounded President Ronald Reagan on March 30, 1981.
The defendant's lawyer, Mr. Nubani, represented some of the 11 Muslim men in the Washington area and
Pennsylvania who were accused in 2003 of conspiring with foreign terrorists and training for terrorist
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=== Page 9 ===
missions at firearms ranges in Northern Virginia.
The men insisted they were engaging in harmless paintball games, not mock military missions. But three
defendants were convicted of conspiracy in a non-jury trial last March and sentenced to long prison terms.
While Mr. Ali was imprisoned in Saudi Arabia, his case became a cause célèbre among Washington-area
Muslims, who complained that he should not be held so long without being charged with a crime. About three
weeks ago, the State Department asked Saudi Arabia to either indict Mr. Ali or allow the Justice Department
to return him to the United States. Until Mr. Ali's appearance in court today the United States government had
not disclosed that he had in fact left Saudi Arabia.
The Washington Post reported in 2003 that Mr. Ali was valedictorian of his 1999 high school class at the
Islamic Saudi Academy in Alexandria, where school officials described him as "an exceptional student," with
special talent in mathematics and science.
Bending to the wishes of his parents, Omar and Faten Abu Ali, Mr. Ali entered the University of Maryland in
the fall of 1999 to study engineering on a scholarship, The Post reported. But he was unhappy and left the
next year to further his Islamic studies, first in Fairfax County, Va., and later in Medina.
Regards,
Senior Intelligence Specialist
U.S. Attorney's Office-SDNY
Terrorism & International Narcotics Unit
One St. Andrew's Plaza
New York, NY 10007
EFTA00010964


c1: EFTA00010145
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00010145.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Discovery
Date: Tue, 13 Jul 2021 21:14:32 +0000
Attachments: 2021.07.13_MDC - Maxwell_PASSWORD.docx; 2021.07.13_MDC_-
Maxwell_MAIN.docx
Cover letters for this drive are attached, let me know if they're okay to go out. The drive is being loaded now with the
materials
inked below (thank you!) and will go out with FedEx either this evening or tomorrow morning, depending
on when the drive finishes loading.
From
Sent: Tuesday, July 13, 2021 3:30 PM
To:
Cc:
Subject: RE: Discovery
Thanks very much to you both!
From:
Sent: Tuesday, July 13, 2021 1:16 PM
To:
Cc:
Subject: RE: Discovery
The most recent productions that have gone to Maxwell at MDC - and that we have not already reproduced on a hard
drive - are:
2021.05.21 (disc) - the Seventeenth Production, saved here (includes subpoena returns, native carved images, and
images)
2021.06.10 (disc) - reproduction of the Seventeenth Production, above ^, after original disc was sent back to us.
The original disc worked on my end, so maybe it is a problem with the larger 8GB discs we had to use?
Nevertheless, the materials to be loaded are the Seventeenth Production. Thanks, team!!
From:
Sent: Tuesday. July 13. 2021 12:35 PM
To:
Cc:
Subject: Re: Discovery
EFTA00010145

=== Page 2 ===
I can handle, currently unpacking some stuff from trial but will look for the drive and try and load it later this afternoon.
Could one of you please just let me know what discovery needs to be loaded onto it (or since which date) since I've been
out of the loop for a bit?
Sent from my iPhone
On Jul 13, 2021, at 12:29 PM
wrote:
Hi team,
Any chance one of you would be able to track down a drive that Maxwell's lawyers dropped off yesterday for
please? Or if not, any chance you could point us to someone who would be able to help find the drive?
We need to get it loaded with the most recent productions that went to Maxwell on CDs.
Thanks,
From
Sent: Monday, July 12, 2021 10:57 PM
To:
Cc:
Subject: RE: Discovery
Hi
We dropped off the drive this afternoon. It should be addressed to
Let me know if you have trouble finding it.
Thanks,
From:
Sent: Monday, July 12, 2021 9:55 PM
To:
Cc:
Subject: RE: Discovery
Hope you are well, too, thanks.
We should have a production of additional non-testifying witness materials prepared to produce to you by the end of
next week.
Did you drop off a hard drive today? If so, would you please let me know to whom it was addressed?
and I are
both traveling this week, and our paralegals are currently either out of the office or on trial, so we'll need to get
someone else to pick up and load the drive.
Thanks,
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=== Page 3 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NV 10007
From
Sent: Friday, July 9, 2021 4:52 PM
To:
Cc:
Subject: Discovery
I hope you are all well. I wanted to circle back with you about two discovery issues. First, a little while back you said
that you would be producing to us additional non-testifying 3500 material. When can we expect to receive that?
Second, you produced the last few productions to Ms. Maxwell on disk. Those disks are now not working. We will drop
off a hard drive to you on Monday. Please reload those productions onto the hard drive and send it to Ms. Maxwell in
MDC. If the additional non-testifying 3500 material is ready to be produced, please include that on the drive.
Regards,
<image001.jpg>
New York
Paris
Washington DC
London
<image002.jpg>
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EFTA00010147


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 77 Filed 12/01/20 Page 1 of 1
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 12/1/20
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-V-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On November 25, 2020, the Defendant filed a letter request under seal. On November
30, 2020, she filed a second letter request in which she proposed redactions on both letters. The
Government is hereby ORDERED to respond to the Defendant's November 25, 2020 letter
request and to the request for proposed redactions by no later than December 2, 2020. The
letters shall be temporarily sealed while the Court resolves the redaction request.
so ORDERED.
Alim D. Netto
Dated: December 1, 2020
New York, New York
ALISON J. NATHAN
United States District Judge
1
EFTA00010194


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=== Page 1 ===
From:
"
(USAFLS)"
To:
(USAFLS)"
(USAFLS)"
Cc:
"
(USAFLS)"
(USAFLS)"
Subject: Epstein
Date: Sun, 23 Mar 2008 00:51:02 +0000
Importance: Normal
Hi all - So sorry to bother you on a Saturday, but I am hoping that I can persuade you to reach out to
about
Epstein's investigators harassing the girls.
received a frantic call today about Epstein's investigators
bothering the parents of one of the victims. According to the victim, he demanded to see the victim and when he
saw her, he told the victim that they had video of the girl and were planning to put it on the internet. We don't
believe that Epstein actually has video of any of the girls, and
has calmed the girl down, but this activity
seems to be getting more aggressive. Remember also that Epstein is using the state criminal case to subpoena
depositions of victims in the federal case (who are not part of the state indictment) to get information about our
investigation. These actions do not seem consistent with what Epstein's attorneys are supposed to be trying to
work out with
in DC. Any chance
will ask Epstein's people to call off their dogs until he makes his
decision?
Assistant U.S. Attorney
Fax 561 820-8777
EFTA00013726


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: documents for Relativity
Date: Wed, 24 Apr 2019 15:35:36 +0000
Importance: Normal
We've received some additional documents in this same production we'd like to include in the same general subfolder on
Relativity ("BSF second production" under "BSF returns"), please. I'm sending them in a separate folder link so that they
don't mess up your process with the initial results; they're here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation)Subpoena
Returns\ Boies Schiller\2019-04-23, Boies Schiller second subpoena response (follow-up)
Please note there are a few things from that folder that do NOT need to be uploaded - the folder titled "!Original Zips"
and the two PDF documents (in the main folder) don't need to go onto Relativity. And I think I neglected to give similar
info for the original folder linked to below ("2019-04-18, Boies Schiller second subpoena response") - in that folder, we do
not need the "!Original Zips" folder or its contents, and do not need the three PDF documents in the main folder to be
uploaded.
As always, please let me know if any questions or issues, and thanks very much.
From:
Sent: Monday, April 22, 2019 15:55
To:
Cc:
is
is
is
Subject: RE: documents for Relativity
We can keep the folder structure that currently exists. If I have any questions regarding the documents I will let you
know.
Thank you.
From:
Sent: Monday, April 22, 2019 3:51 PM
To:
Cc:
is
is
Subject: RE: documents for Relativity
EFTA00010252

=== Page 2 ===
Following up on the below, and for the same case - US V. Epstein (USAO # 2018R01618) - could we please load the
documents in the following folder into Relativity:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation\Subpoena
Returns\ Boies Schiller\2019-04-18, Boies Schiller second subpoena response
In terms of structure, they can go under the "BSF returns" subfolder (under the folder "Subpoena Returns") under a new
subfolder identified as "BSF second production". And under that, we'd like to keep the same folder structure as exists at
the link. Does that work?
And I don't believe there is DVD information (as in the "BSF first production" documents), but if there is, please let us
know. Please also let me know if any questions or if any other information would be helpful, and if you could let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Thursday, March 28, 2019 11:16
To:
Cc:
is
is
is
Subject: RE: documents for Relativity
Perfect, thanks very much.
From:
Sent: Thursday, March 28, 2019 09:02
To:
Cc:
i
is
is
Subject: RE: documents for Relativity
Hello
The documents would need to be converted to a different format. I will talk to someone about getting the documents
converted to a different format.
Thank you.
From:
Sent: Wednesday, March 27, 2019 7:15 PM
To:
Cc:
is
is
is
Subject: RE: documents for Relativity
EFTA00010253

=== Page 3 ===
That's no problem, we don't need those on Relativity. Separately, though will we be able to play those video files *not*
on a DVD? That is, we only have them in electronic format (in the file folders) - I haven't tried to play them, so maybe it's
just as easy as that, but wanted to check if we need to get them processed in some other fashion to be able to view
independently of a DVD player.
thanks,
From:
Sent: Tuesday, March 26, 2019 09:32
To:
Cc:
i
is
Subject: RE: documents for Relativity
Good Morning
I have noticed that some of these documents contain data that appears to be from a DVD. A DVD contains a bunch of
separate files to make everything play on a DVD, but it will not make sense to load DVD information into Relativity. The
following should not be loaded to Relativity:
1.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q*3\FS09L*P\_AMUFM*3\S90B8H*H\B3KTU3*S\2MQV991
I\G6WHHA~F\7EJDCF~7\Interview H. R\VIDEO_TS
2.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q~3\IFS09L*P\_AMUFM^3\S90B8H*H\B3KTU3*5\2MQV99-
\GWR892~P\60AFYC*X\Interview J. H\VIDEO_TS
3.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q^3\FS09L*P\_AMUFM*3\S90B8H*H\B3KTU35\2MQV99~
I\GWR892~P\60AFYC*X\Interview S. V\VIDEO_TS
4.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q^3\FS09LP\L_AMUFM*3\S90B8H*H\B3KTU3*5\2MQV99
I\GYCEJBB\53V7CE*B\Interview A. D\VIDEO_TS
5.
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\UUUV4Q^3\FS09LP\_AMUFM*3\S90B8H*H\B3KTU3*5\2MQV99
I\GYCEJB~B\53V7CE*B\Interview A. T\VIDEO_TS
6. \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\Subpoena Returns\ Boies hiller\2019-03-04, Boies Schiller first subpoena response\GJ SUBPOENA
RESPONSE 004582 (State Disc 1)\2. Walkthrough Video
Please let me know if there are any questions.
Thank you.
From:
Sent: Monday, March 25, 2019 7:00 PM
To:
Cc:
i
is
EFTA00010254

=== Page 4 ===
is
Subject: RE: documents for Relativity
Could we please load the documents in the following folder into Relativity for US V. Epstein (USAO # 2018R01618):
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNYinvestigation\Subpoena
Returns\Boies Schiller\2019-03-04, Boies Schiller first subpoena response
In terms of structure, we'd like to create a folder identified as "Subpoena Returns" (at the same level as "FBI Case File" is
currently), and in a subfolder within Subpoena Returns, a folder titled "BSF returns," and within that a subfolder identified
as "BSF first production" that the docs in the above link can be deposited into (including any additional subfolders). Does
that work?
Please let me know if any questions or if any other information would be helpful, and if you could please let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: FW: Transition Team Request for Significant, Publicly Filed Cases
Date: Mon, 04 Jan 2021 16:21:18 +0000
Embedded: FW_Transition_Team_Request_for_Significant_Publicly_Filed_Cases.msg
Sender:
Subject: FW: Transition Team Request for Significant, Publicly Filed Cases
Message-Id:
<CY1P110MB0375358762B7FBF7E519E6D19FD20@CY1P110MB0375.NAMP110.PROD.OUTLOOK.COM
>
To:
Cc:
EFTA00013347


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=== Page 1 ===
Case 1:18-cr-00454-KPF Document 306 Filed 12/29/20 Page 1 of 2
MEMO ENDORSED
The Honorable Katherine Polk Failla
United States District Judge
Southern District of New York
40 Foley Square
NY, NY 10007
December 29, 2020
Re: Unites States V. Efrain Reyes
18-cr-454
Dear Judge Failla:
I respectfully write as a member of the public and reporter for the New York Daily News
covering the case of US V. Reyes, 18-cr-454.
I write in regard to Reyes's change of plea hearing on 8/26/19 and sentencing on 4/13/20.
I'm told the transcripts of both proceedings are under seal. There are also no sentencing
submissions from the government or Reyes's attorney posted on the docket.
Reyes died last month at his mother's apartment in the Bronx. He is the subject of public
interest because he was the last person to share a cell with Jeffrey Epstein.
As you are aware, there exists a presumption of access to court proceedings and judicial
documents under both the common law and our Constitution. This presumption is overcome
solely when Your Honor makes a specific finding on the record that a compelling interest in
secrecy overrides this interest. Any restrictions of access must be narrowly tailored.
"The public and press have a qualified First Amendment right of access to plea and sentencing
proceedings." United States V. Alcantara, 396 F.3d 189, 191-2 (2d Cir. 2005).
The presumption of access is based on the view that secrecy erodes trust in courts and judges,
and access enhances trust. To keep these materials sealed would create the appearance that
the presumption is designed to avoid -- that the Court is keeping a matter of public concern
under wraps.
I respectfully request that your Honor unseal the proceedings mentioned above and order the
docketing of sentencing submissions for Reyes. Alternatively, I ask you make a finding on the
record explaining why they should remain under wraps.
Thank you for your attention.
Stephen Rex Brown
NY DAILY NEWS
1
EFTA00013287

=== Page 2 ===
Case 1:18-cr-00454-KPF Document 306 Filed 12/29/20 Page 2 of 2
The Clerk of Court is directed to file this letter to the docket in
case number 18-cr-454-12, United States V. Efrain Reyes. The parties
shall file a response, if any, to this letter seeking to unseal
certain filings on or by January 22, 2021.
Dated:
December 29, 2020
SO ORDERED.
New York, New York
Katherin Pall Faila
HON. KATHERINE POLK FAILLA
UNITED STATES DISTRICT JUDGE
EFTA00013288


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=== Page 1 ===
From:
"
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To:
Cc:
(USAFLS)"
Subject: RE: Epstein settlement agreement
Date: Tue, 30 Oct 2007 13:53:41 +0000
Importance: Normal
Thank-you
From:
Sent: Monday, October 29, 2007 9:22 PM
To:
(USAFLS)
Subject: Epstein settlement agreement
Good evening. I am the ASA with the Epstein case in Palm Beach County. The negotiated settlement is a
definite go. A difficulty arose last week at a conference with the judge on the case. She wants the plea and
sentence to occur concurrently; not a plea with a sentencing at a later date. Therefore, the case was set for the
first week of January, but the plea and sentence will definitely occur before the January 4th date that was agreed
on by all for the sentencing.
If you have any questions, please contact me at
EFTA00013520


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=== Page 1 ===
From:
To:
Subject: RE: Working on a story on deadline re: Jeffrey Epstein
Date: Fri, 19 Sep 2008 20:13:49 +0000
Importance: Normal
I gave her a no comment
From:
Sent: Friday. September 19. 2008 4:06 PM
To:
Subject: RE: Working on a story on deadline re: Jeffrey Epstein
I certainly don't want to talk to her.
I am just finishing a press release for you on another case. You should have it soon.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach EL 33401
Phone
Fax 561 820-8777
From:
Sent: Friday, September 19, 2008 2:33 PM
To:
Subject: FW: Working on a story on deadline re: Jeffrey Epstein
I am going to be calling her back with a big no comment, unless I get different instructions from you about
what's in the public record.
From:
news.com]
Sent: Friday, September 19, 2008 2:31 PM
To:
Subject: Working on a story on deadline re: Jeffrey Epstein
I'm working on a story about the federal non-prosecution agreement that is part and parcel of the state plea
agreement with Jeffrey Epstein.
I'd like to know why the U.S. Attorney's Office decided not to prosecute Epstein - because I do know, according to
court records, that if he violates any portion of his state agreement that he can be federally prosecuted.
I wanted to know if I could speak with AUSA
for an answer to this question, since she was the AUSA
on the case.
I am on deadline for today.
Thank you,
Michele
Michele Dargan, staff writer
EFTA00013952

=== Page 2 ===
Palm Beach Daily News
(561) 820-3863 phone
(561) 655-4594 fax
EFTA00013953


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
86 Chambers Street
New York, New York 10007
April 21, 2020
By Electronic Mail
Roberta A. Kaplan
Kaplan Hecker & Fink LLP
New York, NY 10118
Re:
Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan:
I write in response to the your letter dated February 25, 2020, seeking documents from
the Department of Justice ("DOJ") related to Jeffrey Epstein and plaintiff Jane Doe in Doe V.
Estate of Jeffrey E. Epstein, No. 19-cv-8673 (S.D.N.Y.). As noted in my previous letter dated
January 6, 2020, DOJ's response to your request is governed by federal regulations, referred to
as "Touhy regulations." See United States ex rel. Touhy V. Ragen, 340 U.S. 462 (1951). Pursuant
to these regulations, the United States Attorney has authorized DOJ to provide certain documents
responsive to your request. Please find electronic versions of these documents enclosed. The
password for these documents will be sent to you by separate cover.
The enclosed documents are as follows:
Pages numbered DOJ_001-005 are a report of service of a grand jury subpoena on
Jane Doe.
Pages numbered DOJ_006-007 are a report of service of a grand jury subpoena on
Jane Doe.
Pages numbered DOJ_008-009 are a report of service of a grand jury subpoena on
Jane Doe.
Pages numbered DOJ_010-076 are a biographical report of Jane Doe. Pages have
been redacted to exclude non-responsive material and references to third parties.
Pages numbered DOJ_077-078 are a report of contact between Jane Doe and
agents of the Federal Bureau of Investigation.
Pages numbered DOJ_079-080 are a report of contact between Jane Doe and
agents of the Federal Bureau of Investigation.
Pages numbered DOJ_081-087 are a document retrieved from an electronic
search of a device in Epstein's New York residence in 2019.
Pages numbered DOJ_088-091 are pages from a document obtained in
approximately April 2005 from discarded trash located outside the Palm Beach
residence occupied by Jeffrey Epstein.
Please contact me once you have had a chance to review this letter if you would like to
discuss the issues herein further.
EFTA00010435

=== Page 2 ===
Page 2
Sincerely,
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
B
Assistant United States Attorney
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=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
US Passport (P)
04/26/2019 12:36 EDT
Generated By:
Page 1 of 1
Passenger Information
Last Name
First Name
DOB
Gender
EPSTEIN
JEFFREY EDWARD
M - Male
US Passport Information
Passport #
Passport Status
Document Type
I - - ISSUED
P - - PASSPORT
Issue Country
Issue Date
Expiration Date
USA UNITED STATES
03/08/2019
03/07/2029
Personal Information
Last Name
First Name
DOB
EPSTEIN
JEFFREY EDWARD
Gender
Place of Birth
Nationality
M - Male
USA UNITED STATES
For Official Use Only / Law Enforcement Sensitive
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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
(USANYS)"
(USANYS) [Contractor]"
Cc:
(USANYS)"
Subject: RE: SDFL Epstein-related documents
Date: Tue, 25 Aug 2020 14:48:32 +0000
That works for me as well, thanks.
From:
Sent: Tuesday, August 25, 2020 10:46 AM
To:
(USANYS)
is
(USANYS)
[Contractor]
Cc:
SANYS)
Subject: RE: SDFL Epstein-related documents
I'm available from 2pm to 3:30pm today for a call, thanks.
From:
(USANYS)
Sent: Tuesday, August 25, 2020 9:54 AM
To:
is
V.
(USANYS)
is
Cc:
$)
Subject: FW: SDFL Epstein-related documents
I think
and I can be relatively flexible either afternoon, but since you guys are obviously far more important to this
project going forward, please let us know what works best for you.
From:
Sent: Tuesday, August 25, 2020 9:31 AM
To:
(USANYS)
Cd
USANYS)
is
)
is
is
(USANYS)
[Contractor]
Subject: RE: SDFL Epstein-related documents
Hello
I can do a call this afternoon. Any time between 2:00 p.m. and 4:00 p.m. is best. Alternatively, I am available tomorrow
during the same time period. Let me know which time is more convenient for you and your team. If these times don't
work, let me know and we will work out an alternate time.
In the meantime, we have all the materials in a secure room on our second floor in West Palm Beach. There are the case
files and also boxes of files that were gathered for the OPR inquiry. We have an inventory of our materials and also OPR
has their own inventory of the materials.
When OPR was here earlier, we had a scanner on that floor dedicated for their exclusive use. They were able to scan the
documents that they wanted and have those documents sent directly to their own DOJ accounts. I was overseas at the
time on detail, but I was told that this worked rather well.
EFTA00011503

=== Page 2 ===
A copy of our inventory is attached.
I look forward to assisting you in this matter.
Best regards,
Managing Assistant United States Attorney
West Palm Beach Regional Office - SDFL
From:
(USANYS)
Sent: Tuesday, August 25, 2020 9:00 AM
To:
Co
is
V.
is
(USANYS)
(USANYS)
[Contractor]
Subject: SDFL Epstein-related documents
We supervise the team in New York that is currently prosecuting Ghislaine Maxwell, and
suggested
we reach out to you. As discussed briefly with
we are hoping to locate the boxes of documents and other records
regarding the prior SDFL investigation into Jeffrey Epstein and his co-conspirators that we understand are currently being
stored in the West Palm Beach office. In particular, we would like to make arrangements to review and scan those
materials in connection with our own case, and
suggested that we touch base with you on how best to do so.
I've copied the trial team here. Please let us know if you have time for a call in the near future to discuss further.
Alternatively, if there is a more appropriate point of contact on this issue, please feel free to point us in that direction.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: Revised MILs
Date: Mon, 18 Oct 2021 18:29:19 +0000
Attachments: Government_MIL_v6_to_v7_redline.docx; Government_MIL_v7.docx
Attached is a clean version and a redline.
FYSA, the paras can't help with citechecking after all.
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=== Page 1 ===
From:
Subject: Accepted: Meeting re MCC/Epstein
Date: Tue, 13 Aug 2019 12:05:36 +0000
Importance: Normal
Attachments: unnamed
EFTA00013190


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=== Page 1 ===
From:
To:
)"
Subject: FW: GM remarks - electronic copy
Date: Tue, 01 Sep 2020 16:44:32 +0000
Attachments: Ghislaine_Maxwell_Press_Remarks_v14_(Clean_Copy)_(ig_edits)_(002).ebd.docx
This is, I think, the last version of the GM remarks (or at least the last one I have).
From:
Sent: Wednesday, July 1, 2020 6:00 PM
To:
is
;
(USANYS)
Subject: RE: GM remarks - electronic copy
I think this looks great, Audrey. Much tighter and less repetitive. I think I added one small suggestion on top of
comments.
From:
Sent: Wednesday, July 1, 2020 5:30 PM
To: Strauss, Audrey (USANYS)
i
Subject: RE: GM remarks - electronic copy
A few minor suggestions from me are in the attached. Thanks.
From: Strauss, Audrey (USANYS)
Sent: Wednesday, July 1, 2020 4:36 PM
To:
Subject: FW: GM remarks - electronic copy
I have been editing this down-it was too long, and also getting the language to be more natural.
I went back and tried to make sure that it was still comported with the indictment (even if not in the exact wording) but
let know if it does not.
EFTA00009863


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=== Page 1 ===
Event: Epstein
Start Date: 2009-06-05 15:00:00 +0000
End Date: 2009-06-05 15:30:00 +0000
Organizer:
Location: Jeff's Office
Class: X-PERSONAL
Date Created: 2015-03-27 13:43:56 +0000
Date Modified: 2015-07-22 20:34:51 +0000
Priority: 5
DTSTAMP: 2009-06-03 20:37:29 +0000
Attendee:
EFTA00013478


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=== Page 1 ===
From:
To:
Subject: Priorities
Date: Thu, 31 Oct 2019 15:09:26 +0000
Attachments: SDNY_PRIORITIES_DRAFT_[Revised_10.31.19_nvb].docx
With revisions/additions/fixed formatting issues and updated hyperlinks.
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
EFTA00010267


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=== Page 1 ===
From:
To: "sam@samgregory.com" <sam@samgregory.com>, Lloyd Epstein
<lepstein@epsteinweil.com>
Cc:
Subject: U.S. V. Robert Adams, 20 Cr. 494 (PGG) -- Discovery Production 2
Date: Sat, 14 Nov 2020 01:13:54 +0000
Attachments: 2020.11.12_Adams_Discovery_Letter_-_Production_2pdf
Counsel,
Please find attached a letter regarding the Government's second discovery production in this case. The materials are
available on our secure file-sharing website, USAfx, and there is no password on the production itself. Please let us know if
you have any questions. Thank you.
Regards,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00013372


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=== Page 1 ===
From:
To:
Bee:
Subject: SDNY NEWS CLIPS, MONDAY, JANUARY 25, 2021
Date: Mon, 25 Jan 2021 17:41:11 +0000
Inline-Images: image001 png
OF
SDNY PRESS CLIPPINGS
JUSTITIA
Wall Street Journal: Trump pressured DOJ to file case with Supreme Court to overturn election results CNNPolitics
How Ghislaine Maxwell was nabbed by the FBI via her phone (nypost.com)
Matt Schlapp and His Firm Got $750k for Failing at His Job 1. Vanity Fair
Capitol riot: Updated list of arrests in New York State (photos) - syracuse.com
Returning to a bipartisan approach to end human trafficking I TheHill
U.S. Supreme Court ends anti-corruption lawsuits against Trump I Reuters
True Crime: Did sex fiend who killed NYC woman commit Boston Strangler slayings? - New York Daily News(nydailynews.com)
Republicans pan media coverage of Hunter Biden bagel run I Fox News
NYPD releases video of attackers who beat and stripped man (nypost
Are banks overburdened with responsibility for money lost to online scams? (computerweekly.com)
SPAC Boom Propels Electric Carmakers to Public Markets - Bloomberg
The Justice System Is Going Too Easy on the White Insurrectionists I The Nation
Casanova's gang sign at Miami strip club sparked shooting: feds New York Daily News (nydailynews.com)
EFTA00011046

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Nicholas Blase
Spokesman
United States Department of Justice
U.S. Attorney's Office [Southern District of New York
EFTA00011047


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=== Page 1 ===
From:
To:
Subject: Re: Epstein
Date: Fri, 07 Dec 2007 18:29:02 +0000
Importance: Normal
It's better that I send it and not you.
Sent from my BlackBerry Wireless Handheld
Original Message
From:
To:
Sent: Fri Dec 07 13:23:59 2007
Subject: FW: Epstein
Jeff - This is the e-mail chain with
The only sources of the information are our Office and the FBI.
is
requesting the information, and I am responding accordingly.
Please let me know how you want to proceed. I find this very demoralizing.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From:
Sent: Thursday, December 06, 2007 4:47 PM
To
Subject: RE: Epstein
Yep, something short and sweet with no names. The date is Dec. 21.
From:
Sent: Thursday, December 06, 2007 3:36 PM
To:
Subject: RE: Epstein
EFTA00013713

=== Page 2 ===
Hi Lanna -
I can put something together. I assume something short and sweet? And has a date been set?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From:
Sent: Thursday, December 06, 2007 3:05 PM
To:
Subject: Epstein
Could you please outline what factual basis you think fits the procuring statute for the plea conference. I am trying to
finalize the paperwork.
EFTA00013714


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From:
To:
Cc:
Subject: RE: Letter re Epstein
Date: Wed, 29 Oct 2008 18:14:12 +0000
Importance: Normal
I would construe the request as one under the FOIA, and route it to
As to the letter, I have
not sent it out, since I was on military leave on Oct 22-26. I will get it out this week.
From:
Sent: Wednesday, October 29, 2008 2:08 PM
To:
Cc:
Subject: Letter re Epstein
Hi
I received a letter addressed to the "Records Custodian" for the U.S. Attorney's Office making a
"public records request for the entire file." FOIA is not referenced in the letter. Should I do anything with this
letter or respond in any way?
Also, have you heard anything back from Mr. Edwards regarding your latest correspondence?
Thank you.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00013876


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=== Page 1 ===
From: LEGALREQUIREMENTS
To:
Cc: LEGALREQUIREMENTS
Subject: RE: FB Case #19353 Jeffrey Epstein-Federal Grand Jury Subpoena
Date: Tue, 10 Mar 2020 19:59:56 +0000
Inline-Images: image003.jpg; image004.png; image005.jpg; image006.png
Good afternoon AUSA
We have just sent a secured message. Please register to access the information.
Kindly,
1 First Bank
Records & Legal Requirements #244
T
F
1firstbank.com
f
in
Piensa en el ambiente antes de imprimir este correo.
Please consider the environment before printing this email.
CONFIDENTIALITY NOTICE: This electronic transmission contains information belonging to First BanCorp or any of its subsidiaries, which might be
related to criminal, civil or administrative actions. Such information is strictly confidential or legally privileged. If you are not the intended recipient, please
immediately advise the sender by reply e-mail or telephone that this message has been inadvertently transmitted to you and delete this e-mail from your
system. You are hereby notified that any disclosure, copying, distribution or the taking of any action in reliance on the contents of the information is strictly
prohibited by law.
AVISO DE CONFIDENCIALIDAD: Esta transmisión electrónica contiene información de First BanCorp 0 alguna de sus subsidiarias, que pudiera estar
relacionado a una investigación criminal, civil o administrativa. Esta información es estrictamente confidencial 0 privilegiada. Si usted recibe este mensaje
por error, favor de indicarlo al remitente a través de correo electrónico 0 vía telefónica y elimine el mismo de su sistema. Divulgar, copiar, distribuir 0
tomar alguna acción sobre la información contenida en esta comunicación está prohibido por ley.----
From: LEGALREQUIREMENTS
Sent: Tuesday, March 10, 2020 12:55 PM
To:
Cc: VERONICA MARTINEZ
>; LEGALREQUIREMENTS
>; LAWRENCE ODELL
Subject: FB Case #19353 Jeffrey Epstein-Federal Grand Jury Subpoena
Sensitivity: Confidential
Good afternoon AUSA
Attached please find the list of accounts as requested. We are working on the production for this case.
Regards,
EFTA00011351

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1 First Bank
Records & Legal Requirements
Records & Legal Requirements #244
T
1firstbank.com
f
C
in
Piensa en el ambiente antes de imprimir este correo.
Please consider the environment before printing this email.
<p><span style="color: #999999;">DISCLAIMER: The information contained in this e-mail may be privileged, confidential, and protected from disclosure. If
you are not the intended recipient, you are hereby notified that any dissemination, distribution or duplication of this communication is strictly prohibited. If you
have received this communication in error, please notify the sender immediately and delete all copies. This message was sent by the FirstBank Secure Mail
Gateway.</span> </p>
EFTA00011352


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: Fw: Draft Response to Edwards' Oct 15, 2008 letter
Date: Wed, 05 Nov 2008 19:19:30 +0000
Importance: Normal
What do you all think?
From:
To:
Sent: Wed Nov 05 14:08:17 2008
Subject: RE: Draft Response to Edwards' Oct 15, 2008 letter
I am not averse to completely ignoring Edwards' October 15, 2008 letter, if that is what you would prefer.
From:
Sent: Wednesday, November 05, 2008 10:38 AM
To:
Cc:
Subject: Re: Draft Response to
Oct 15, 2008 letter
Hi
I am out of the office today so I can't edit the letter from my Blackberry. I hate the idea of writing yet another
letter that will be attached to a pleading or quoted in the paper.
I would feel more comfortable with something that says:
Thank you for your letter. The Office is involved in the criminal investigation of Mr. Epstein and is neither a party to nor
involved in any civil suits against him. If you have any documentary evidence that you believe establishes a breach of the
Non-Prosecution Agreement, you can forward that evidence to AUSA
The Office will then conduct its
own review in accordance with the terms of the Non-Prosecution Agreement.
And leave it at that. What do you all think?
From:
To:
Cc:
Sent: Tue Nov 04 10:56:20 2008
Subject: Draft Response to Edwards' Oct 15, 2008 letter
Attached please find my draft response to Edwards' Oct 15, 2008 letter. Please ensure that it is factually
correct, particularly with regard to what Epstein agreed to during the negotiations. Thanks.
EFTA00014131

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<<edwards_resp_ltr_101508.wpd>>
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=== Page 1 ===
From:
To:
Subject: Subpoena Ghislaine Maxwell
Date: Wed, 10 Jun 2020 21:38:34 +0000
Attachments: Nothing_Found_Letter.pdf
Please see response regarding subpoena for Ghislaine Maxwell. Please let me know if you have any questions. Thank
you.
Legal Process Specialist
Judicial Compliance
UMB Bank | 1010 Grand Ave
Kansas City, MO 64106
(816) 860-1409 Office
Count on more.
NOTICE: This electronic mail message and any attached files are confidential. The information is exclusively
for the use of the individual or entity intended as the recipient. If you are not the intended recipient, any use,
copying, printing, reviewing, retention, disclosure, distribution or forwarding of the message or any attached file
is not authorized and is strictly prohibited. If you have received this electronic mail message in error, please
advise the sender by reply electronic mail immediately and permanently delete the original transmission, any
attachments and any copies of this message from your computer system. Thank you.
EFTA00010338


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=== Page 1 ===
Event: Accepted: US V. Epstein (civil forfeiture matter)
Start Date: 2019-10-17 19:30:00 +0000
End Date: 2019-10-17 20:00:00 +0000
Location: Skype Meeting; Conference ID: 598 437 033;
Class: X-PERSONAL
Comment:
Date Created: 2019-10-17 15:22:03 +0000
Date Modified: 2019-10-17 15:22:03 +0000
Priority: 5
DTSTAMP: 2019-10-17 15:08:16 +0000
Attendee: Weinstein, Marc A.
EFTA00010260


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=== Page 1 ===
From:
(USAFLS)"
To:
(FBI)"
Bcc:
(USAFLS)"
Subject: RE: Jeff Epstein
Date: Thu, 19 Jun 2008 17:59:13 +0000
Importance: Normal
I doubt that Roy will call again. He didn't really call me last time, he called
and
asked me to call him back.
Tomorrow at 10:30 sounds fine. I just spoke to
and he said that he spoke with the DAG's chief of staff on Tuesday and made very
clear that we need an answer by Friday. Nothing more since then.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
Original Message
From:
(FBI)
Sent: Thursday, June 19, 2008 1:55 PM
To:
(USAFLS)
Subject: Re:
Epstein
How about I come over tomorrow after I get
report - say 10:30. I also plan to send u SW today or bring it tomorrow. I guess we
should be hearing from DC anytime for the green light. (They said Wed, right?) Sounds like u had a interesting call with Roy Black. I
would have luvd to have been a fly. Do u think u will hear from him again?
Original Message
From:
(USAFLS)
To:
; Richards, Jason R.
Sent: Thu Jun 19 13:23:07 2008
Subject: FW:
Epstein
Hi Guys - This is
attorney. He seems like a very good guy - much better than the others, but I am concerned about allegations
of misconduct. What do you think? Maybe we could meet with him and with
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00013871

=== Page 2 ===
From: Brad Edwards
Sent: Thursday, June 19, 2008 11:34 AM
To:
(USAFLS)
Subject: Jeff Epstein
Hi
I have information and concerns that I would like to share. While I understand that you are limited in what you can discuss, I would like to
meet with you and discuss my plans. This would be beneficial to you and me. Let me know if you are interested in meeting and talking.
My schedule is free next Monday, Tuesday, and Wednesday, July 23-25. If any of those days are open for you, then I will go to you and
can meet you at any time convenient for you. I am scheduling to meet with my client again next week in your area anyway, so it would be
no problem for me to meet you on the same day. I look forward to hearing back from you.
Sincerely,
Brad Edwards, Esquire
Law Office of Brad Edwards & Associates
Suite 202
Hollywood, Florida 33020
Telephone:
(Broward)
(Miami-Dade)
Facsimile:
(Broward)
(Miami-Dade)
e-mail:
PRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the use of the individual or
entity to which it is
addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If
the reader of this
EFTA00013872

=== Page 3 ===
message is not the intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified
that any use, printing,
reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction.
EFTA00013873


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=== Page 1 ===
Event: Questions re: Epstein ESI
Start Date: 2020-03-11 14:30:00 +0000
End Date: 2020-03-11 14:45:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2020-03-10 22:41:24 +0000
Date Modified: 2020-03-10 22:41:24 +0000
Priority: 5
DTSTAMP: 2020-03-10 22:31:08 +0000
Attendee
Alarm: Display the following message 15m before start
Reminder
EFTA00011356


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Herman &Mermelstein, P
10:48:06 a.m.
16-09-2008
1/3
ERMAN & MERMELSTEIN PA
Ai TORNEYS AT LAW
Jeffrey M. Herman
Tel
Fax
Miami, Florida 33160
www.hermanlaw.com
FAX TRANSMITTAL
FROM
DATE
NO. OF PAGES
Jeffrey M. Herman
September 16, 2008
3
TO
COMPANY
FAX NUMBER
U.S. Attorney's Office
MESSAGE
RE: Jane Does 2-5 V. Jeffrey Epstein
Please see enclosed correspondence.
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY
CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE
LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE
FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION,
DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED IF YOU HAVE RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, AND RETURN THE ORIGINAL MESSAGE
TO US AT THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE THANK YOU.
EFTA00013955

=== Page 2 ===
305-9312200
Herman &Mermelstein, P
10:48:28 a.m.
16-09-2008
2/3
HERMAN & MERMELSTEIN PA
ATTORNEYS AT LAW
Jeffrey M. Herman
Tel
Fax
Miami, Florida 33160
www.hermanlaw.com
September 16, 2008
Via Fax and Regular Mail
Assistant U.S. Attorney
West Palm Beach, FL 33401
Re:
Jeffrey Epstein
Dear Ms. Villafaña:
This concerns your letters to us and to sexual assault victims of Mr. Epstein dated September
2, 2008. Please be advised that we strenuously object to your letters on various grounds, and believe
that they are in violation of the Florida Bar Rules.
First, your letters attempt to steer the victims to a particular attorney, Mr. Josefsberg, and
advise them that Mr. Josefsberg will be making an unsolicited contact to them in the next two weeks.
This contact with prospective clients and solicitation reflected in your letters is contrary to Fla. Bar.
Rule 4-7.4. Additionally, your letters are misleading in the following respects: (1) the action
advocated to the victims in paragraph 2 refers generally to the victims' waiver of any other claim for
damages", failing to advise them that this waiver may include a valuable claim to punitive damages
against an alleged billionaire; and (2) the letters imply in paragraph 3 that Mr. Epstein's agreement to
pay attorney fees is a significant concession, when in fact a victim is entitled to reasonable attorneys'
fees under the Statute upon proof of a violation, irrespective of Mr. Epstein's agreement.
We accordingly demand that the U.S. Attorneys' office immediately cease and desist from
directing unrepresented victims into unsolicited attorney contacts and misleading them about their
rights in claims against Mr. Epstein. We demand that you instruct Mr. Josefsberg not to solicit
victims, and to send letters to unrepresented victims correcting the misleading statements contained
in your September 2, 2008 letters.
EFTA00013956

=== Page 3 ===
305-9312200
Herman &Mermelstein, P
10:48:58 a.m. 16-09-2008
3/3
Esq.
September 16, 2008
Page 2
Finally, we demand that you make no contact with our clients directly, and contact them only
through our office. Our clients includ
Sincerely,
for
JMH/lr
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=== Page 1 ===
From:
=
(USAFLS)"
To:
(USAFLS)"
Cc:
(USAFLS)"
Subject: Revised Epstein Letter
Date: Tue, 13 Nov 2007 18:32:28 +0000
Importance: Normal
Attachments: 071113_Sloman_Ltr_to_Lefkowitz_v2.wpd
Hi
- I have incorporated the change regarding the naming of counsel. Let me know what you hear back.
Thanks.
Assistant U.S. Attorney
561
Fax 561 820-8777
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=== Page 1 ===
From:
(USANYS)"
To: "Kate L. Doniger"
Cc:
)"
"Alexandra Conlon"
, Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Date: Wed, 15 Apr 2020 04:10:00 +0000
Kate,
Thank you for checking in. I hope you are keeping well also. I do not think we need any additional information from you at
this time. I hope to be able to provide an update early next week.
Thanks,
From: Kate L. Doniger
Sent: Tuesday, April 14, 2020 3:01 PM
To:
(USANYS)
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
We hope that you are keeping well in this very challenging time.
We completely understand that all things are in flux these days, but we just wanted to check in with you about our
request and whether there is any other information you need from us. If it would be helpful to set up a call to discuss, we
are available at your convenience.
Best,
Kate
Kate L. Doniger Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Thursday, February 27, 2020 7:23 PM
To: Alexandra Conlon
>; Roberta Kaplan
Cc: Kate L. Doniger
is
Subject: RE: Request for Information Relating to Jeffrey Epstein
Alexandra and Robbie,
Thank you for this. I will contact you regarding the request.
EFTA00010432

=== Page 2 ===
Thanks,
From: Alexandra Conlon
Sent: Tuesday, February 25, 2020 7:54 PM
To:
(USANYS)
>; Roberta Kaplan
Cc: Kate L. Doniger
is
)
Subject: RE: Request for Information Relating to Jeffrey Epstein
SENT ON BEHALF OF ROBERTA KAPLAN
AUSA
Thank you for contacting us. Attached please find a Touhy letter and supporting exhibit requesting documents from the
Department of Justice in connection with our pending litigation against Jeffrey
estate.
We are happy to schedule a time to talk if it would be helpful to discuss our request.
Best Regards,
Robbie
Alexandra Conlon Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Monday, January 6, 2020 6:59 PM
To: Roberta Kaplan
Cc: Kate L. Doniger
>; Alex Conlon
Subject: Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan,
Please find attached a letter regarding the request you discussed with AUSA
for certain information
relating to Jeffrey Epstein. As stated in the letter, please contact me once you have had a chance to review the letter if you
would like to discuss the issues therein further.
Thanks,
Assistant United States Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
EFTA00010433

=== Page 3 ===
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein Travel
Date: Thu, 25 Apr 2019 22:37:15 +0000
Attachments: Epstein_Travel_1.12015_to_4.21.2019.pdf
Attached is a summary of Epstein's travel from 1.1.2015 to 4.21.19.
Special Agent
FBI New York
VCAC/Human Trafficking
C:
O:
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=== Page 1 ===
From:
To:
)"
)"
(USANYS)"
Subject: FW: RE: privilege review contact information Epstein
Date: Mon, 12 Oct 2020 17:11:37 +0000
FYI
From:
Sent: Thursday, August 15, 2019 1:25 PM
To:
Cc:
)
is
Subject: RE: RE: privilege review contact information
Sounds good, thanks again.
From:
Sent: Thursday, August 15, 2019 12:19
To:
Cc:
is
Subject: RE: RE: privilege review contact information
Thanks
I made that clarification (which was implicit but better to be clear).
From:
Sent: Wednesday, August 14, 2019 6:04 PM
To:
Cc:
is
)
Subject: RE: RE: privilege review contact information
I might just say that we intend to implement a privilege review of materials for which that would be appropriate-for
example, I believe that the FBI takes the view that photos do not need to be reviewed for privilege in the first instance.
But otherwise sounds fine, and happy to discuss that further if useful.
thanks,
From:
Sent: Wednesday, August 14, 2019 15:59
To:
is
V.
;
Subject: FW: RE: privilege review contact information
Marty just reached out to me and wants to provide me with Epstein's list of counsel as long as I agree not to share it with
the case team without his consent and that we implement a privilege review of the materials seized from Epstein. So
unless you want to discuss, I plan to agree to the former and confirm the latter. I ran it by
just to be safe.
EFTA00013251

=== Page 2 ===
Thanks,
From:
Sent: Tuesday, August 13, 2019 4:58 PM
To: 'Marty Weinberg' <marty@martinweinberglaw.com>; Miller, Michael
Cc:
>; Weingarten, Reid
is
)
i
;
)
Subject: RE: privilege review contact information
Marty, Mike,
Following up on our conversation this afternoon via phone, I wanted to put you in touch directly with
who
is the Office's Privilege Review Logistic Coordinator. I know you have been interested in providing us with privilege-related
information in connection with our review process; please feel free to contact Ms.
directly to facilitate that.
She is available at the email address copied here.
thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Bec: "USAHUB-USAJournal111"
Subject: RE: Call re Maxwell Staffing
Date: Wed, 28 Oct 2020 17:33:01 +0000
Embedded: RE:_Call_re_Maxwell_Staffing.msg
Sender:
Subject: RE: Call re Maxwell Staffing
Message-Id:
<SN1P110MB019038B5DBEFE4C81EBFA5DC8B170@SN1P110MB0190.NAMP110.PROD.OUTLOOK.CO
M>
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20A
THE PALM BEACH POST
FRIDAY, NOVEMBER 16, 2007
The Palm Beach Post
ToM GIUFFRIDA, Publisher
JOHN BARTOSEK, Editor
CHARLES GERARDI, General Manager
BILL ROSE, Managing Editor
RANDY SCHULTZ, Editor of the Editorial Page
JAN TUCKWOOD, Associate Editor
BARRY BERG, VP Circulation LARRY SIEDLIK, VP & Treasurer
JOHN KELLY, VP Advertising GALE HOWDEN, VP Community Relations and Marketing
LINDA MURPHY, VP Human Resources BOB BALFE, VP Operations
LAURA DECK CUNNINGHAM, Director, Marketing Services
DAN SHORTER, General Manager, PalmBeachPost.com
How will system judge
Palm Beach predator?
We soon will find out whether
Jeffrey Epstein case
big money can buy from the crimi-
nal justice system what everyone
comes to turning point.
assumes that big money can buy.
The penalty news reports say
part-time Palm Beach resident
the public understanding that
Jeffrey Epstein is expected to face
the more money the accused has,
suggests that he will plead guilty
the bigger the break he gets. Mr.
to something more than one felony
Epstein's legal team includes West
count for solicitation of prostitution.
Palm Beach defense attorney Jack
A Palm Beach County grand jury
Goldberger, Harvard Law School
indicted the Manhattan money
Professor Alan Dershowitz, who
manager on that charge in July
worked on the O.J. Simpson murder
2006. But a guilty plea that does not
case, and Kenneth Starr, who once
recognize the age of the girls whom
pursued a president based on his
police say the billionaire paid for
lies about sex with young women.
sex would be a disservice to the
Federal authorities also stepped
girls, an insult to the investigators
in, which stalled the state's case
who pressed the case and, for good
for another year. On Nov. 9, citing
measure, a general outrage.
an unnamed source close to Jeffrey
Palm Beach police have said that
Epstein, Jose Lambiet of The Post
Jeffrey Epstein, 54, paid underage
wrote that the federal investigation
girls, one as young as 14, to come to
is over, and Mr. Epstein is expected
his 7,200-square-foot waterfront home
to serve up to 18 months and could
for "massage" sessions. Police said
be labeled a sex offender in crimi-
interviews with five alleged victims
nal records. The charge the grand
and 17 witnesses under oath, phone
jury returned more than a year ago
messages, a high school transcript
carries a maximum five-year prison
and other items they found in Mr.
term and no "sex offender" label.
Epstein's trash and home show that
"This case," Mr. Goldberger told
he knew how young the girls were.
Mr. Lambiet, "is absolutely going to
But after Mr. Epstein's attorneys told
end without a trial within the next
prosecutors about the girls' MySpace
two months." State attorney spokes-
pages, which mentioned marijuana
man Michael Edmondson would
and alcohol use, State Attorney Barry
not confirm any plea deal. But, he
Krischer sent the case to a grand jury,
noted: "The state attorney's hands
instead of filing charges himself.
are not tied by there being a single
Blaming these victims, however,
grand jury charge. That does not
does not make them any more de-
preclude additional charges."
serving of what happened. And Mr.
Jeffrey Epstein, like too many
Krischer's unnecessary handoff to a
men in Florida, preyed on teenaged
grand jury, after an 11-month police
girls. The system should not let him
investigation, more than reinforced
buy his way out of that reality.
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=== Page 1 ===
From:
Subject: RE: Tartaglione document request
Date: Mon, 14 Dec 2020 17:55:02 +0000
Hey
was looking into who in Central Office keeps these. I just followed up with him.
>>>
)"
> 12/14/2020 12:52 PM>>>
Hi
- following up on the below. Thanks.
From:
Sent: Wednesday, December 9, 2020 1:34 PM
To:
Cc:
Subject: Tartaglione document request
Hi
A while back, we spoke about obtaining a final copy of the BOP's Psychological Reconstruction of Inmate Jeffrey Epstein and
the MCC's response so that we can evaluate what discovery obligations we have with respect to the document for purposes
of the capital phase of Tartaglione's trial. Have you been able to locate the document, and if so, can you please email to us
when you have a chance?
Many thanks,
Deputy Chief, White Plains Division
United States Attorney's Office
Southern District of New York
300 Quarropas Street
White Plains, New York 10601
Tel: (914) 993-1963
Cell: (917) 992-6989
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=== Page 1 ===
TOWN OF PALM BEACH
SEAL OF THE INCORPORATED liman BEACH TOWN OF PALM
OF
POLICE DEPARTMENT
FLORIDA
A NATIONAL AND STATE ACCREDITED LAW ENFORCEMENT AGENCY
POLICE
May 1, 2006
PERSONAL AND CONFIDENTIAL
Mr. Barry E. Krischer, State Attorney
Office of the State Attorney
Fifteenth Judicial Circuit
401 North Dixie Highway
West Palm Beach, FL 33401
Dear Mr. Krischer,
Please find enclosed the probable cause affidavits and case filing packages thus far
resulting from the Palm Beach Police Department's investigation of Jeffrey Epstein,
and
The submission of these documents are both in response to
Assistant State Attorney Lanna Belohlavek's request for them and to serve as the Palm
Beach Police Department's presentation for prosecution.
I know that you agree that it is our shared responsibility to seek justice and to serve the
public interest by discharging our duties with fairness and accountability. I must renew my
prior observation to you that I continue to find your office's treatment of these cases highly
unusual. It is regrettable that I am forced to communicate in this manner but my most
recent telephone calls to you and those of the lead detective to your assigned attorneys
have been unanswered and messages remain unreturned.
After giving this much thought and consideration, I must urge you to examine the unusual
course that your office's handling of this matter has taken and consider if good and
sufficient reason exists to require your disqualification from the prosecution of these
cases.
Sincerely,
Nicharl..Reites
Michael S. Reiter
Chief of Police
MSR:nt
345 South County Road
Palm Beach, Florida 33480-4443
Fax (561) 835-4700 www.palmbeachpolice.com
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=== Page 1 ===
From:
To:
Subject: Press Coverage
Date: Mon, 14 May 2007 22:13:17 +0000
Importance: Normal
Hi
|
This is not meant as pestering. I just know that the Miami paper hasn't covered Epstein like
they have up here. This is a link to a site that, for some unknown reason, has compiled most of the "legitimate"
newspaper stories about Epstein. It does not contain the recent story in the London newspapers about Epstein's
link to Prince Andrew. If you want a link to that story, let me know. [As an aside about the London article/leak
issue, the day after we put a key witness in the grand jury, a London reporter called the witness' attorney to ask
whether his client had appeared before the grand jury yet. So wherever the leak is, it is of international
proportions.]
http://www.theawarenesscenter.org/Epstein_Jeffrey.html
Assistant U.S. Attorney
Phone
Fax
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=== Page 1 ===
From: Chris Dilorio
@msn.com>
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Date: Wed, 15 Apr 2020 14:41:23 +0000
Attachments: IMG_7021.jpg
Inline-Images: image.png
I am so FUCKING good I even impress myself
So, WHO has "green lighted" the Milken Degenerate Fat Leon Black/APO and the degenerate Steve
Schwarzman/BX take over of the Insurance industry?
Individual States Regulators, sure but there seems to be a monumental disagreement between the Trump white
House and States today. More to it? ABSOFUCKINGLUTELY
Recall Fat Leon/APO raiding Athene and investing policy holder money in bankrupt Harrahs and Caesars
https://www.evanslaw.com/practice-areas/annuities-fraud/annuities-fraud-company/athene-life-insurance-
and-annuity-company/
San Francisco Annuity Fraud Attorneys, Aviva USA,
Annuity Fraud - Evans Law Firm
Annuity holders who purchased policies from ATHENE, Aviva USA and other
affiliates may be at risk for fraud. Contact the Evans Law Firm to learn more.
www.evanslaw.com
EFTA00010786

=== Page 2 ===
Trump Junk.
Today, because of "Coronavirus" Trump and another Milken Degenerate: Treasury Sec Mnuchin are bailing out
High Yield: JUNK
Milken degenerate flunkies:
Fat Leon: #1 CLO Mgr
Handler/Jefferies: #2 CLO Mgr
CLO's: Junk on Steroids
Remember the S&L crisis?
Same Milken degenerates (incl Trump banker Moelis): Drexel
stuffed S&L's with JUNK
Shit hit the fan when forced to Mark to market
CLO's: not required to mark to market. NO SHIT?
The "Repo virus" preceded the "Corona virus" by months
ANOTHER Milken Degenerate flunkies taxpayer bailout
And, yes because of the APO/Athene/Harrahs/Caesars SHELL GAME, Athene is grossly insolvent but for Milken
esque parking and moving "assets" on and off the balance sheet.
Who is on the hook? per SEC reviewed filings: NOT APO. Just Athene
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0000837332&owner=exclude&count=40&hidefilings=0
What have I been wrong about?
NOT ONE SINGLE FUCKING THING
Cheers!
Christopher J Dilorio
Blowing the Whistle on GROSSLY Corrupt Scumbags Extraordinaire
From: Chris Dilorio
Sent: Wednesday, October 23, 2019 10:11 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Wednesday, October 23, 2019 7:55 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00010787

=== Page 3 ===
From: Chris Dilorio
Sent: Thursday, July 18, 2019 11:54 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Healthcare fraud is pretty serious shit.
What SECURITIES LAWS should be
https://www.law.cornell.edu/uscode/text/18/1347
18 U.S. Code § 1347 - Health care fraud | U.S.
Code | US Law | LII / Legal Information
Institute
to obtain, by means of false or fraudulent pretenses,
representations, or promises, any of the money or property
owned by, or under the custody or control of, any health care
benefit program,
www.law.cornell.edu
Colleran got off pretty easy, eh?
Certainly LOOKS like CRIMINAL fraud and
NOT
CIVIL fraud
Trump:
'acting' Asst DOJ Readler becomes JUDGE Readler just like that
https://en.wikipedia.org/wiki/Chad_Readler
EFTA00010788

=== Page 4 ===
Chad Readler - Wikipedia
August 23, 1972 (age 46) Pontiac, Michigan, U.S.: Education:
University of Michigan (BA, JD): Chad Andrew Readler (born
August 23, 1972) is a United States Circuit Judge of the United
States Court of Appeals for the Sixth Circuit and former Principal
Deputy and former Acting Assistant Attorney General for the
en.wikipedia.org
The criminality associated with this White House is off the charts.
Calk: Lorber
Lorber/Elliman/Icahn: Frost/Honig/Stetson
AND
Alpha Capital: Martin Schlaff: MY CLAIMS
Ladenburg/Gruntal: Refco/Bawag
Also Schlaff AND: Englander/Nordlicht/Kushners
abusive naked shorting to facilitate $$ laundering: Sedona/ Scan Graphics
My claims: NITE/VIRT: Refco on steroids
also CDEL
Frost brings down the WH
Frost/Honig/Stetson: Therapix/FSDDF
Urban: FSDDF/NITE/VIRT
Blackstone: Luckiest fuckers on the Street: Here glitchy glitchy
Epstein: Schwarzman
Epstein: Black
Black/Schwarzman: Kushner (my BX SEC TCR)
SEC: dropped Apollo charges: Avakian/Heiss
SEC NITE/VIRT obstruction: Jay/Sull Crom/Fishman
1MDB: PHUN/Nordlicht/AIPAC: Greek shippers
Economou/EKONOMOU
Bistricers
Feinberg: Danaos
Trump attorney: EKONOMOU
Barr 1MDB waiver: AQR
Cheers!
Follow me on Twitter
I'll follow back
lololol
From: Chris Dilorio
Sent: Saturday, July 13, 2019 7:31 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00010789

=== Page 5 ===
More
Trump Ohio fundraiser
Brian Colleran
https://www.cleveland.com/politics/2019/07/donald-trump-coming-to-cleveland-friday-for-fundraiser-at-
nursing-home-magnates-house.html
Donald Trump coming to Cleveland Friday for
fundraiser at nursing home magnate's house -
cleveland.com
CLEVELAND, Ohio - Republican President Donald Trump is
visiting Cleveland on Friday for a private fundraiser at the home
of nursing home executive Brian Colleran, sources with
knowledge of the
www.cleveland.com
https://www.justice.gov/opa/pr/three-companies-and-their-executives-pay-195-million-resolve-false-claims-act-
allegations
Three Companies and Their Executives Pay $19.5
Million to Resolve False Claims Act Allegations
Pertaining to Rehabilitation Therapy and Hospice
Services | OPA | Department of Justice
Ohio based Foundations Health Solutions Inc. (FHS), Olympia Therapy Inc.
(Olympia), and Tridia Hospice Care Inc. (Tridia), and their executives, Brian
Colleran (Colleran) and Daniel Parker (Parker), have agreed to pay
approximately $19.5 million to resolve allegations pertaining to the submission
of false claims for medically unnecessary rehabilitation therapy and hospice
www.justice.gov
Another Honig $$$ laundering shell
Intergetics
Millenium
NMC
Regent
take your pick
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=== Page 6 ===
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0
https://www.sec.gov/Archives/edgar/data/72170/000114420410011488/0001144204-10-011488-index.htm
Colleran
https://www.sec.gov/Archives/edgar/data/72170/000114420408023159/0001144204-08-023159-index.htm
Cheers!
Christopher Dilorio
and
From: Chris Dilorio
Sent: Thursday, July 11, 2019 8:07 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Mr Berman,
Thanks for the shout out, but I'm not a journalist
lololol
Just a very long list of credible information I have provided to the grossly corrupt SEC et al scumbags
Janey, update my various TCR's and derivatives. Separate but related Janey. Separate but related.
Hey, is Jay still working on his NITE/VIRT/Sull Crom disclosures?
https://www.nytimes.com/2019/07/10/business/jeffrey-epstein-net-worth.html
Jeffrey Epstein's Infinite Means' May Be a Mirage
Mr. Epstein, facing sex-trafficking charges, has long been hailed as a financial
wizard. He got rich with the help of two wealthy connections, but there is little
evidence he's a billionaire.
www.nytimes.com
EFTA00010791

=== Page 7 ===
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Monday, July 8, 2019 6:25 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings Grossly corrupt SEC scumbags et al
IMDS: S Florida $$$ laundering shell facilitated by the SEC
Highlighted in my 2013 TCR filed with prestigious Berger Montague
More AML flags than be counted
MASSIVE naked short position
MY claims
SEC cover up. Now, re started so it can be unleashed on the investing public yet again.
Martin Schlaff/Balmore/Alpha Cap
https://www.haaretz.com/israel-news/business/martin-schlaffis-behind-5-million-investment-in-collplant-
1.5457018
Martin Schlaff: Bag Man
But it gets MUCH better
Graftech
SEC reporting
pronounced "Graft etc"
https://www.sec.gov/Archives/edgar/data/931148/000119312516427770/0001193125-16-427770-index.htm
EDGAR Filing Documents for 0001193125-16-427770
GrafTech Global Enterprises Inc. (Filer) CIK: 0000940404 (see all company filings) IRS No.: 061415602 I State
of Incorp.:[ DE | Fiscal Year End: 1231 Type: 15-15D I Act
www.sec.gov
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=== Page 8 ===
https://www.haaretz.com/israel-news/elections/premium-the-netanyahu-milikowsky-ties-could-be-on-the-
way-to-an-fbi-investigation-1.7090960
The FBI may be about to probe Netanyahu's
ties to cousin Milikowsky
***
www.haaretz.com
Wall Street / CNBC Wiz Karen Finerman
"Save Graft etc"
https://www.sec.gov/Archives/edgar/data/931148/000119312515018174/d857124dex991.htm
EX-99.1 - sec.gov
Exhibit 1 "SAVE GRAFTECH" GROUP NOMINATES FULL SLATE OF SEVEN DIRECTORS TO GRAFTECH BOARD
NEW YORK, January 23, 2015 - Save GrafTech, an investor group led by Nathan Milikowsky, a holder of
over 15 million shares, or over 11.2%, of the common stock of GrafTech International Ltd. (NYSE: GTI), today
sent a letter to the GrafTech Board of Directors disclosing that it has submitted a
www.sec.gov
pg 57 of this SEC reviewed public offering
https://www.sec.gov/Archives/edgar/data/931148/000104746919000874/a2237872zs-1.htm
www.sec.gov
(1) Includes 2,625,000 shares of common stock that the underwriters have the option to purchase from the
selling stockholder. (2) Estimated solely for the purpose of calculating the amount of registration fee in
accordance with Rule 457(c) under the Securities Act of 1933, as amended, based upon the average of the
high and low sales prices of the registrant's common stock as reported by the
www.sec.gov
2018 revenue up 244% vs 2017 due to sharp increase in graphite electrode pricing
BUT, graphite electrode prices rose significantly in 2017
and
FELL in 2018
https://agmetalminer.com/tag/graphite-electrodes/
graphite electrodes Archives - Steel, Aluminum, Copper, Stainless, Rare
Earth, Metal Prices, Forecasting |
MetalMiner
EFTA00010793

=== Page 9 ===
Needle coke, a crude oil derivative, accounts for 40-44% (depending on the year) of the cost to produce
one metric ton of electrodes. Graftech, one of the leaders in graphite electrode production
agmetalminer.com
the Graftech/Graft etc balance sheet is complete fraud as well
insolvent
JP Morgan strikes again
Grossly corrupt SEC "protecting Main Street as usual"
Fraud certainly not limited to the OTCM
Mr Teotia,
congrats on taking Wes Bricker's job
no doubt you're working hard on those KCG 2Q 2017 financials not "published" by Mr Transparency Dougie
Cifu.
Where would a $4 billion+ write down of naked short fails put the NITE/VIRT fraud on the list of egregious
SEC accounting fraud failures?
Top 5?
Let me know if I can help
In furtherance of the conspiracy
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Wednesday, June 26, 2019 6:07 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Tuesday, June 25, 2019 2:31 PM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Friday, May 24, 2019 7:27 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Friday, May 24, 2019 7:23 AM
To:
EFTA00010794

=== Page 10 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
Getting warmer Ms Strauss
https://www.justice.gov/usao-sdny/pr/bank-ceo-stephen-m-calk-charged-corruptly-soliciting-presidential-
administration
Bank CEO Stephen M. Calk Charged With Corruptly
Soliciting A Presidential Administration Position In
Exchange For Approving $16 Million In Loans | USAO-
SDNY | Department of Justice
Audrey Strauss, the Attorney for the United States, Acting Under Authority
Conferred by 28 U.S.C. § 515, William F. Sweeney Jr., the Assistant Director-in-
Charge of the New York Field Office of the Federal Bureau of Investigation
("FBI"), and Patricia Tarasca, the Special Agent-in-Charge of the New York
Region for the Federal Deposit Insurance Corporation Office of Inspector
www.justice.gov
But, this is the beginning of the story
not the end
Calk/Lorber/Elliman: Trump
Lorber: New Valley Corp
https://www.sec.gov/Archives/edgar/data/106374/000095014405003084/g93826e10vk.htm
Apollo Moscow/Kremlin development
AND
Ladenburg Thalman
I asked in previous correspondence:
Does ANYONE believe Frost risked BILLIONS to "MAKE" a few million?
Frost was laundering a few millions.
https://www.barrons.com/articles/sec-charges-phillip-frost-1536608366
EFTA00010795

=== Page 11 ===
SEC Charges Against Phillip Frost Might Just
Be the Tip of the Iceberg
The U.S. Securities and Exchange Commission filed stock fraud
charges late last week against billionaire drug entrepreneur Phillip
Frost and a group of associates, accusing them of making $27
million in pump-and-dump stock schemes
www.barrons.com
Alpha Capital Anstalt Liechtenstein
in my 2013 TCR: Money laundering/Miami based Imaging Diagnostics (see my IMDS e mails)
Bag Men
Also: "Greek Shipping company" FreeSeas (See my FreeSeas TCR)
Despite overwhelming evidence of money laundering, you will find no reference to it in SEC complaints.
https://www.sec.gov/news/press-release/2018-182
SEC.gov | SEC Charges Microcap Fraudsters for Roles in Lucrative Market
Manipulation Schemes
The Securities and Exchange Commission today charged a group of 10 individuals and 10 associated
entities for their participation in long-running fraudulent schemes that generated over $27 million from
unlawful stock sales and caused significant harm to retail investors who were left holding virtually worthless
stock.
www.sec.gov
No mention of AML despite glaring red flags
No mention of executing Broker Dealers: Penny stock trading fairies
The SEC has kept Alpha Capital Anstalt up and running so the activity detailed in my complaints can continue.
And it does
https://whalewisdom.com/filer/alpha-capital-anstalt
ALPHA CAPITAL ANSTALT Top Holdings - WhaleWisdom
Alpha Capital Anstalt is based out of Vaduz Liechtenstein. Whalewisdom has at least 6 13D filings, 158 13G
filings, and 5 Form 4 filings The firm has no submitted 13F filings and does not appear to be an investment
advisor.
whalewisdom.com
Now: Lorber/Calk/Elliman: New Valley: shell
EFTA00010796

=== Page 12 ===
Ladenburg/Frost/Alpha Cap Anstalt $$$ laundering shells
Apollo/Lorber: Moscow/Kremlin "development"
"Tip of the Iceberg" indeed
In furtherance of the conspiracy.
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 23, 2019 5:59 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
So:
Leon Black/ Apollo/Schwarzman: Trump Kushner
Black/Apollo/Schwarzman: Epstein
Black/Apollo/Schwarzman: Putin/RU
https://www.reuters.com/article/russia-putin-fund-idUSL5E7KG0SI20110916
UPDATE 2-Putin gets SWF, PE backing for
Russia fund
* Apollo's Black shares platform with Putin
www.reuters.com
https://www.swfinstitute.org/news/33645/u-s-treasury-sanctions-russian-direct-investment-fund/amp
Black/Apollo/Schwarzman: money laundering shells
https://www.businessinsider.com/blackstone-dodged-a-bullet-with-knight-capital-2012-8
EFTA00010797

=== Page 13 ===
Blackstone Dodged A Bullet With Knight
Capital - Business Insider
A trader consulted by Business Insider said that Blackstone envied
Knight Capital's market-making team, which executed an average
of more than $20 billion trades last year and is designated market
www.businessinsider.com
https://www.sec.gov/Archives/edgar/data/1082278/000092242313000183/0000922423-13-000183-index.htm
Knight/Trimark/Optimark born out of "worthless paper"/ Russian/US Mafia/ money laundering shell: Ashton
Technologies
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001003740&owner=exclude&count=40&hidefilings=0
https://ag.ny.gov/press-release/us-atorney-lynch-and-nys-atorney-general-spitzer-announce-20-defendants-
indicted-50
U.s. Attorney Lynch And N.y.s. Attorney General Spitzer Announce 20
Defendants Indicted In $50 Million Boiler Room Stock Fraud Scheme | New
York State Attorney General
LORETTA E. LYNCH, United States Attorney for the Eastern District of New York, ELIOT SPITZER, New York
State Attorney General, BARRY W. MAWN, Assistant Director-in-Charge of the Federal Bureau of
Investigation in New York, and RICHARD H. WALKER, Director of the Division of Enforcement of the
Securities and Exchange Commission, today announced the unsealing of an indictment charging 20
ag.ny.gov
Spitzer taken down by RUSSIAN hooker
https://nypost.com/2016/02/16/spizter-accuser-a-young-jobless-ex-hooker-who-lives-a-life-of-luxury/
Spitzer accuser was a $5K-a-night hooker
who lives life of luxury - New York Post
The Russian vixen who accused Eliot Spitzer of choking her at The
Plaza hotel is a divorced, globe-trotting beauty who once bared
all the dirty details of her life as a $5,000-a-night hooker, The
nypost.com
Any questions?
Cheers traitorous scumbags!
EFTA00010798

=== Page 14 ===
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, May 19, 2019 8:03 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
I reiterate:
The SEC is a grossly corrupt criminal organization bought and paid for by criminals who threaten the integrity of
our markets to the clear and very egregious detriment of the investing public it is sworn to protect.
http://www.marketrap.com/article/view_article/9152/bernard-madoff-the-mafia-and-the-friends-of-michael-
milken
Bernard Madoff, the Mafia, and the Friends of Michael Milken - Market Rap
- The Investor Empowerment Community
In 2005, Patrick Byrne, the CEO of Overstock.com and future Deep Capture investigative reporter, began a
public crusade against illegal naked short selling (hedge funds and brokers creating phantom stock to
manipulate stock prices down). He said, over and over, that the crime was destroying public companies and
had the potential to trigger a systemic meltdown of our financial markets.
www.marketrap.com
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Friday, May 17, 2019 6:22 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00010799

=== Page 15 ===
From: Chris Dilorio
Sent: Wednesday, May 15, 2019 11:27 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Today (5/15/19) the grossly corrupt scumbags at the SEC approved ANOTHER massive fraud on the investing
public:
https://www.sec.gov/Archives/edgar/data/1665300/999999999519001111/xslEFFECTX01/primary_doc.xml
The "genius f'n quant" AQR/Greek shipping
/Economou/DRYS/ORIG/Astra/Nautilus/Navios/Gerber/AIPAC/Nordlicht/Glass/1MDB/Knitowski/Caneum/Trym
etris/Liquid etc etc etc money laundering shell.
Well done!
BTW, HOW is the George Economou/ Georgios EKONOMOU SEC "investigation" coming along anyway?
https://en.wikipedia.org/wiki/George_Economou_(shipbuilder)
George Economou (shipbuilder) - Wikipedia
George Economou or Georgios Ekonomou (Гешруюс Oikovójiou, born 1953) is a Greek billionaire
shipowner, CEO of DryShips Inc. and Ocean Rig, and the owner of Cardiff Marine.Economou owns oil
tankers as well as dry bulk ships and manages them through Cardiff Marine. He was on the Forbes
Magazines list of the world's billionaires on place 707.
en.wikipedia.org
What a coincidence:
https://www.vanityfair.com/news/2018/03/andrew-ekonomou-donald-trump-legal-team/amp
EFTA00010800

=== Page 16 ===
Trump's Last Line of Defense Against Mueller
Is an Obscure Medieval Historian
Andrew Ekonomou had a "mid-life crisis" and became an expert
on Byzantium. Now he's helping lead the president's legal team in
the Russia investigation.
www.vanityfair.com
Dude is DEFINITELY not getting the attention he deserves
Then again,
WHO actually believes Marc Bistricer of Toronto Canada was INVESTING in the $$$ laundering Ekonomou
shell known as DryShips?
https://seekingalpha.com/article/4096781-strong-court-case-dryships-kalani
Very Strong Court Case Against DryShips And
Kalani - DryShips Inc. (NASDAQ:DRYS)
|
Seeking Alpha - Stock Market Insights
I
Seeking Alpha
Source: rgrdlaw.com (court document) In 2012, DRYS generated
$1.23 billion in total revenue, yet posted a $246 million loss. In
fact, the company has been posting losses every year for the last
seekingalpha.com
"Charity not the motive"
https://www.tradewindsnews.com/legal/1738610/kalani-claims-charity-not-a-motive-for-dryships-aid
Kalani claims charity not a motive for DryShips
aid | TradeWinds
Kalani claims charity not a motive for DryShips aid Marc Bistricer-
led investment house says it had risk and profit in mind lending
to George Economou's struggling public company, not attempt to
www.tradewindsnews.com
The Toronto connection runs MUCH deeper though
The overlap with AQR blank check shells and Polar Asset Mgmt Toronto
The Toronto based Bistricer and EKONOMOU
Bistricers in New Jersey TOO!
EFTA00010801

=== Page 17 ===
AND
DAVID Bistricer happens to be a real estate developer
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001649096&owner=exclude&count=40&hidefilings=0
1 Bistricer/Clipper "investor"
Toronto based C I Investments
https://www.sec.gov/Archives/edgar/data/1649096/000116364819000009/0001163648-19-000009-index.htm
Check out this Reg D offering Bistricer/ Clipper did in Jan 2016
https://www.sec.gov/Archives/edgar/data/1649096/000161577416004014/xslFormDX01/primary_doc.xml
$130,000 Reg D offering for this Bistricer/Clipper publicly traded "real estate" company was done with an
Atlanta based firm called H&L Equities
Atlanta is home of the obscure Trump Russia Counsel Andrew EKONOMOU
Nothing to see here.
Of Course, then there's the Hail Mary pass Kushner threw on his Toronto based Brookfield deal for 666 5th
Avenue
https://www.thestar.com/news/world/2019/03/12/toronto-based-brookfield-faces-scrutiny-from-democrats-
over-deal-with-kushner-company.html
Toronto-based Brookfield faces scrutiny from
Democrats over deal with Kushner company
|
The Star
The real estate giant says politics were not at all involved in its
decision to acquire a New York office tower from the family of
Jared Kushner, President Donald Trump's son-in-law and senior
aide.
www.thestar.com
which was brokered by Apollo/Epstein Degenerate Black/Harris/Rowan
https://therealdeal.com/2018/11/15/brookfield-turns-to-apollo-for-666-fifth-financing/
666 Fifth I Brookfield I Apollo Global
Management
Private equity company Apollo Global Management is funding
Brookfield Property Partners' redevelopment of 666 Fifth Avenue
with a $300 million-plus mezzanine loan, sources told The Real
Deal
therealdeal.com
EFTA00010802

=== Page 18 ===
Apollo and other Kushner financing pal Blackstone just happen to be BOTH granted free reign on the US
insurance/annuity industry.
Crazy shit huh?
Greek shipping Bag man Georgios Ekonomou meets Jared Kushner
But it gets better still:
Stephen Feinberg: Cerberus
https://www.bloomberg.com/news/articles/2018-05-11/trump-chooses-cerberus-sfeinberg-to-lead-spy
advisory-panel
Trump Chooses Cerberus's Stephen Feinberg
to Lead Spy Advisory Panel - Bloomberg
President Donald Trump has chosen billionaire investor Stephen
Feinberg to lead his intelligence advisory board, the White House
said Friday. Trump intends to appoint Feinberg, the co-founder
and
www.bloomberg.com
Bawag/Refco
Virtu first bid for Knight post "glitch"
and now: Money Laundering Bank HSH
Stephen Feinberg: Scum of the Earth meet Georgio EKONOMOU
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&ClK=0001369241&owner=exclude&count=40&hidefilings=0
Janey, IG update my various pending TCR's and complaints
Yours VERY TRULY
And INFINITELY smarter than anyone on this e mail list
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Monday, May 13, 2019 5:41 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00010803

=== Page 19 ===
From: Chris Dilorio
Sent: Saturday, May 11, 2019 8:00 AM
To
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Monday, May 6, 2019 6:38 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings grossly corrupt SEC et al scumbags
As with ALL of my allegations: beyond a shadow of a doubt, 100% accurate
https://www.sec.gov/litigation/complaints/comp17673.htm
Complaint: SEC V.
COMPLAINT. Plaintiff United States Securities and Exchange Commission ("Commission") alleges as
follows: SUMMARY. 1. This case involves a $15 million "pump and dump" scheme involving the securities
of Environmental Solutions Worldwide, Inc. ("Environmental"), a public company whose common stock is
registered with the Commission under the Securities Exchange Act of 1934 ("Exchange Act"), and is
www.sec.gov
ESWW was a money laundering shell.
The SEC knows it. The degenerate Epstein knows it. The Degenerate Leon Black/Kushner BFF/ Milken
proteges/Marc Rowan/Apollo knows it.
The DOJ/IRS knows it.
EFTA00010804

=== Page 20 ===
IG, I have repeatedly offered to come to SEC DC HQ to have the brightest minds at the SEC totally humiliate me
by refuting my allegations 1 by 1. The grossly corrupt SEC scumbags have never taken me up on my generous
offer. For the very simple reason that ALL of my allegations are accurate and true.
So, I again put the offer out there:
refute my claims OR go to jail for the criminal obstruction ACTIVELY being facilitated by your office and the SEC.
So, let's give these scumbags the insurance/annuities market.
This will NOT end well for tens of thousands of Americans.
Who "green lighted" this take over of the insurance industry by PE/Hedge funds?
https://www.forbes.com/sites/antoinegara/2018/02/01/apollo-and-blackstone-pick-insurance-as-their-next-
bet-to-disrupt-wall-street/#5d647dbe7689
Apollo And Blackstone Pick Insurance As Their
Next Bet To Disrupt Wall Street - Forbes
For decades, Wall Street's gambit in insurance was to write
policies and use the float as a source of capital for new
investments. It's a staple of Berkshire Hathaway and copycats like
Markel and
www.forbes.com
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 2, 2019 3:35 PM
To:
EFTA00010805

=== Page 21 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
IG,
This was a blatant attempt to intimidate a whistleblower. "HE" (I think a male although very effeminate voice)
was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that.
This is a VERY serious matter. Felony. I intend to see "him" prosecuted to the fullest extent of the law. Within
weeks of filing a complaint against the SEC and you.
I obviously have hit a nerve.
https://www.nbcnews.com/politics/white-house/white-house-tells-official-who-gave-kushner-security-
clearance-don-n997476
White House whistleblower speaks out on
security clearance controversy
Carl Kline was supposed to appear before House committee staff
Tuesday to face questions related to his handling of White House
security clearances.
www.nbcnews.com
Cheers!
Christopher Diiorio (no L's scumbag)
From: Chris Dilorio
Sent: Thursday, April 25, 2019 6:27 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
EFTA00010806

=== Page 22 ===
ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein
The SEC has known for years that Epstein is running a extortion/Ponzi/Slush Fund
My Claims AGAIN
https://seekingalpha.com/article/3715526-environmental-solutions-worldwide-revisiting-holding-gone-dark-
can-sleep-better-night?mod=mw_quote_news
Environmental Solutions Worldwide: Revisiting
A Holding That's Gone Dark, So I Can Sleep
Better At Night - Environmental Solutions
Worldwide, Inc. (OTCMKTS:ESWW) | Seeking
Alpha - Stock Market Insights | Seeking Alpha
New CEO and recent trading activity warranted a review of a
holding that no longer files. Based on the environment, difficult
y/y comparisons and results from competitors, 2015 is likely a
down year.
seekingalpha.com
"Not credible"???
How about the SEC's OWN words?
https://www.bloomberg.com/news/articles/2018-10-01/sec-spots-a-way-to-starve-the-most-suspicious-penny-
stocks
SEC Spots a Way to Starve the Most
Suspicious Penny Stocks - Bloomberg
"If a company is a dark company and listed in the OTC market
and hasn't put out financials for six months, maybe it shouldn't
be quoted or offered to retail investors," Redfearn said
www.bloomberg.com
EFTA00010807

=== Page 23 ===
See my comment letters on this subject.
The SEC INTENTIONALLY puts the investing public at risk of frauds like this and thousands others like it.
The core biz at NITE/VIRT,CDEL etc and the reason WHY the OTCM exists: Abusive naked shorting publicly
traded shells to facilitate money laundering.
Shells go dark only AFTER a massive fraud has been perpetrated on the investing public: Main Street
ANOTHER "genius" degenerate: Apollo
the grossly corrupt SEC: Bought and paid for by common criminals and degenerates
IG, I have time for that REQUIRED 3rd party cc today
Call me
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, April 14, 2019 1:04 PM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
A little Steffie Avakian//Heiss/O'Melveny/Wilmer Hale/ Apollo/Kushner Home Cooking!
https://www.omm.com/professionals/howard-e-heiss/
Howard E. Heiss - O'Melveny & Myers
Howard Heiss has an extensive litigation practice focused on
government regulatory investigations and enforcement actions,
grand-jury investigations, and the defense of clients in criminal
cases, with a particular emphasis on securities matters.
www.omm.com
https://www.sec.gov/Archives/edgar/data/1411494/000119312508077312/ds1.htm
EFTA00010808

=== Page 24 ===
Form S-1 - SEC.gov
Table of Contents. The information in this prospectus is not complete and may be changed. The securities
may not be sold until the registration statement filed with the Securities and Exchange Commission is
effective.
www.sec.gov
https://www.wilmerhale.com/en/people/jamie-gorelick
Jamie Gorelick | WilmerHale
Jamie Gorelick's career has spanned the legal, policy and corporate landscapes. As one of Washington's
best-known litigators, Ms. Gorelick has represented corporations and individuals in a wide array of matters,
particularly in the regulatory and enforcement arenas, involving issues as diverse as antitrust,
environmental regulation, securities enforcement, national security regulation, etc.
www.wilmerhale.com
https://www.wilmerhale.com/en/insights/news/former-director-of-the-fbi-robert-mueller-ii-joins-wilmerhale
Former Director of the FBI Robert Mueller III
Joins WilmerHale
WilmerHale is pleased to announce that Robert S. Mueller III is
joining the firm as a partner after serving as the sixth Director of
the Federal Bureau of Investigation (FBI), a position he took one
week prior to the September 11 attacks and held for 12 years
under two presidents.
www.wilmerhale.com
https://www.sec.gov/biography/avakian-stephanie
SEC.gov | Stephanie Avakian
Stephanie Avakian was named Co-Director of the U.S. Securities and Exchange Commission's Division of
Enforcement in June 2017, after serving as Acting Director since December 2016.
www.sec.gov
SEC drops Apollo investigation after Kush Jr met with Harris at the WH
and Apollo gives Kush's some $$$$
And, Apollo gets $60 bil+ in inflows in 2018
Did I miss something?
Cheers!
EFTA00010809

=== Page 25 ===
You corrupt fucking scumbags
Christopher Dilorio
From: Chris Dilorio
Sent: Saturday, April 13, 2019 11:30 AM
To:
Subject: Apollo/ Epstein/Kushner connection
Find a shell
Find a fraud
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0
Florida?
Pennsylvania?
or
Canada?
Welcomed on Cromwel/Wimpfheimer OTCM
De registered in 2015 and Frozen in time
Literally
http://eswgroup.com/esw-group-corporate/our-board/
Our Board - ESW Group®
MARK YUNG Mr. Yung is Co-Founder and Managing Principal of
OCV Management, LLC ("OCV"), an investor, owner and operator
of technology and life science companies based in Los Angeles.
Previously, Mr. Yung was a Managing Director at Orchard Capital
Corp., a firm he joined in 2006. Through his affiliation with [...]
EFTA00010810

=== Page 26 ===
eswgroup.com
Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al
Then,
There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?
The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
wait for it
Leon Black/Apollo Environmental Solutions Worldwide
https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
Enter the Amicus blocking release of Epstein docs
Krieger, Kim and Lewin
https://www.kkllp.com/
Krieger Kim & Lewin LLP
We are committed to providing the highest level of partner-driven representation in order to efficiently
achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal
criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United
States Government.
www.kklllp.com
Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
Now,
it gets VERY interesting
https://www.cnbc.com/2018/02/28/apolo-citigroup-loaned-kushner-companies-millions-new-york-times.htm)
Trump: Kushner's security clearance is up to
Kelly
Kushner even discussed the possibility of a White House job for
the founder of private equity firm Apollo, the New York Times
reported on Tuesday.
www.cnbc.com
Where another Milken protégé/Apollo founding partner Josh Harris was considered for a White House job
"Coindences"
https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-company/
EFTA00010811

=== Page 27 ===
SEC dropped probe month after firm aided
Kushner company
The feds last year dropped an investigation into a financial
company a month after the firm gave Jared Kushner's family real
estate business a $180 million loan, a new report said Friday.
There
nypost.com
Oh, baby
$60 billion+ inflows in 2018 for Apollo
https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports
Quarter-2018
Apollo Global Management, LLC Reports
Second Quarter 2018 Results I Business Wire
NEW YORK--(BUSINESS WIRE)--Apollo Global Management, LLC
(NYSE:APO) (together with its consolidated subsidiaries, "Apollo")
today reported results for the second quarter ended June 30,
2018.
www.businesswire.com
Mr's Krieger,Kim,Boltz et al:
Discovery will be a hoot!
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00010812


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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell fact witness travel
Date: Thu, 11 Nov 2021 22:57:55 +0000
Attachments: Fact_Witness_Travel_Request-
Hi
Attached please find a fact witness travel request for another witness in the Maxwell trial
We think he
could testify sometime between the afternoon of 12/1 and 12/3. Just to flag that, if we get him off the stand on 12/1 or
12/2, we'll probably want to change his travel so he can be back in
by 12/3.
Please let me know if you have any questions, and thank you so much for your help.
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00010021


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=== Page 1 ===
U.S. Department of Justice
Washington, D.C. 20530
June 23, 2008
Jay Lefkowitz, Esq.
Kenneth Starr, Esq.
Kirkland and Ellis LLP
777 South Figueroa Street
Los Angeles, CA 90017
Gentlemen:
This Office has completed a thorough review of the U.S. Attorney's handling of the matter
involving your client, Jeffrey Epstein. We have received and reviewed your letters of May 19,
June 3 and June 19, 2008, the attachments to the June 19 letter, as well as your submissions to
the Criminal Division and the U.S. Attorney's Office. Additionally, we have reviewed an
extensive set of materials provided by the U.S. Attorney's Office and conferred with a number of
highly experienced Department attorneys about this matter. The Deputy Attorney General has
also been briefed.
As you know, the Department of Justice vests considerable discretion in its U.S. Attorneys, and
the Deputy Attorney General will intervene in only the most unusual of circumstances. We do
not believe such intervention is warranted here. Even if we were to substitute our judgment for
that of the U.S. Attorney, we believe that federal prosecution of this case is appropriate.
Moreover, having reviewed your allegations of prosecutorial misconduct, and the facts
underlying them, we see nothing in the conduct of the U.S. Attorney's Office that gives us any
reason to alter our opinion.
Sincerely,
Senior Associate Deputy Attorney General
cc:
Alex Acosta
EFTA00013555


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=== Page 1 ===
From:
)"
To:
Subject: FW: Epstein search warrant documents
Date: Tue, 07 Apr 2020 18:59:37 +0000
Importance: High
- I hope you're doing alright in the midst of all the pandemic craziness, and staying healthy and safe. On these
Epstein issues, are you able to join a conference call tomorrow with
? I can generally express what you've told me,
but on the Relativity issues especially it would be hugely helpful to have your input in real-time. Are there times
tomorrow that would work for you?
thanks!
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
)
is
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
)
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
is
is
EFTA00010440

=== Page 2 ===
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
i
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
EFTA00010441

=== Page 3 ===
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
is
(USANYS)
is
in
(USANYS)
Cc:
is
i
>;
is
)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
V.
(USANYS)
Cc:
is
)
is
>;
is
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
i
is
EFTA00010442

=== Page 4 ===
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
is
is
(USANYS)
Cc:
is
>;
is
is
Subject: RE: Epstein search warrant documents
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
EFTA00010443

=== Page 5 ===
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
is
Cc:
is
is
>;
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From: Brad Edwards
To:
(USAFLS)"
Cc:
(USAFLS)"
, Paul Cassell
Subject: RE: Draft Protective Order
Date: Fri, 15 Aug 2008 15:58:44 +0000
Importance: Normal
Attachments: Protective_Order.Final.doc
This is my proposed Order. I think it comports with the Judge's order from yesterday and I think it is slightly more thorough. It
is very similar to your Motion. If you are more satisfied with your wording or layout for the motion, then please incorporate the
additional points made in my proposed order.
My only real problem with your proposed Order is paragraph C. This just further delays us from getting the agreement, and I
do not believe the Judge placed this burden on us. I think, as I wrote in my proposed order, that it is my duty to instruct my
clients on the protective order and its function and to otherwise ensure that it is not violated by my clients. Getting my clients
to "acknowledge receipt of the order and agree to its terms" could take awhile and cause unnecessary delay. I plan to talk to
my clients about "the agreement" and at the same time instruct them as to the rules outlined in the protective order. That is all
the Judge indicated as needed to be done.
From:
(USAFLS) [mailto:
Sent: Friday, August 15, 2008 11:41 AM
To: Brad Edwards
Cc:
(USAFLS)
Subject: Draft Protective Order
Brad,
Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you
and Jane Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks.
<<Protective Order.doc>>
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=== Page 1 ===
From:
To:
Subject: Initial Response to Grand Jury Subpoena
Date: Thu, 12 Mar 2020 19:11:01 +0000
Attachments: 19353 - _certification.pdf
Michael Hantman Holland & Knight
Partner
Holland & Knight LLP
I
www.hklaw.com
Add to address book I View professional biography
NOTE: This e-mail is from a law firm, Holland & Knight LLP ("H&K"), and is intended solely for the use of the individual(s) to whom it is
addressed. If you believe you received this e-mail in error, please notify the sender immediately, delete the e-mail from your computer and do
not copy or disclose it to anyone else. If you are not an existing client of H&K, do not construe anything in this e-mail to make you a client
unless it contains a specific statement to that effect and do not disclose anything to H&K in reply that you expect it to hold in confidence. If you
properly received this e-mail as a client, co-counsel or retained expert of H&K, you should maintain its contents in confidence in order to
preserve the attorney-client or work product privilege that may be available to protect confidentiality.
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=== Page 1 ===
From:
"
(USAFLS)"
To:
(USAFLS)"
(USAFLS)"
(USAFLS)"
"
,
(USAFLS)"
Bcc:
(USAFLS)"
Subject: Emailing: 080826
Ltr to Lefkowitz and Black.wpd
Date: Mon, 25 Aug 2008 21:33:17 +0000
Importance: Normal
Attachments:
<080826
Ltr to Lefkowitz and Black.wpd>> Please let me know if you have any changes. Thank you.
The message is ready to be sent with the following file or link attachments:
080826
Ltr to Lefkowitz and Black.wpd
Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your
e-mail security settings to determine how attachments are handled.
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 Page 1 of 3
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 7/30/2020
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
MEMORANDUM
Defendant.
OPINION & ORDER
ALISON J. NATHAN, District Judge:
Both parties have asked for the Court to enter a protective order. While they agree on
most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language
allowing her to publicly reference alleged victims or witnesses who have spoken on the public
record to the media or in public fora, or in litigation relating to Ms. Maxwell or Jeffrey Epstein.
Second, Ms. Maxwell seeks language restricting potential Government witnesses and their
counsel from using discovery materials for any purpose other than preparing for the criminal trial
in this action. The Government has proposed contrary language on both of these issues. For the
following reasons, the Court adopts the Government's proposed protective order.
Under Federal Rule of Criminal Procedure 16(d)(1), "[a]t any time the court may, for
good cause, deny, restrict, or defer discovery or inspection, or grant other appropriate relief."
The good cause standard "requires courts to balance several interests, including whether
dissemination of the discovery materials inflicts hazard to others
whether the imposition of
the protective order would prejudice the defendant," and "the public's interest in the
information." United States V. Smith, 985 F. Supp. 2d 506, 522 (S.D.N.Y. 2013). The party
seeking to restrict disclosure bears the burden of showing good cause. Cf. Gambale V. Deutsche
Bank AG, 377 F.3d 133, 142 (2d Cir. 2004).
1
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=== Page 2 ===
Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 Page 2 of 3
First, the Court finds that the Government has met its burden of showing good cause with
regard to restricting the ability of Ms. Maxwell to publicly reference alleged victims and
witnesses other than those who have publicly identified themselves in this litigation. As a
general matter, it is undisputed that there is a strong and specific interest in protecting the
privacy of alleged victims and witnesses in this case that supports restricting the disclosure of
their identities. Dkt. No. 29 at 3 (acknowledging that as a baseline the protective order should
"prohibit[] Ms. Maxwell, defense counsel, and others on the defense team from disclosing or
disseminating the identity of any alleged victim or potential witness referenced in the discovery
materials"); see also United States V. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at
*11 (S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished for
individuals who have spoken on the public record about Ms. Maxwell or Jeffrey Epstein, because
they have voluntarily chosen to identify themselves. But not all accusations or public statements
are equal. Deciding to participate in or contribute to a criminal investigation or prosecution is a
far different matter than simply making a public statement "relating to" Ms. Maxwell or Jeffrey
Epstein, particularly since such a statement might have occurred decades ago and have no
relevance to the charges in this case. These individuals still maintain a significant privacy
interest that must be safeguarded. The exception the Defense seeks is too broad and risks
undermining the protections of the privacy of witnesses and alleged victims that is required by
law. In contrast, the Government's proffered language would allow Ms. Maxwell to publicly
reference individuals who have spoken by name on the record in this case. It also allows the
Defense to "referenc[e] the identities of individuals they believe may be relevant to Potential
Defense Witnesses and their counsel during the course of the investigation and preparation of the
defense case at trial." Dkt. No. 33-1, " 5. This proposal adequately balances the interests at
2
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=== Page 3 ===
Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 Page 3 of 3
stake. And as the Government's letter notes, see Dkt. No. 33 at 4, to the extent that the Defense
needs an exception to the protective order for a specific investigative purpose, they can make
applications to the Court on a case-by-case basis.
Second, restrictions on the ability of potential witnesses and their counsel to use
discovery materials for purposes other than preparing for trial in this case are unwarranted. The
request appears unprecedented despite the fact that there have been many high-profile criminal
matters that had related civil litigation. The Government labors under many restrictions
including Rule 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and
other policies of the Department of Justice and the U.S. Attorney's Office for the Southern
District of New York, all of which the Court expects the Government to scrupulously follow.
Furthermore, the Government indicates that it will likely only provide potential witnesses with
materials that those witnesses already have in their possession. See Dkt. No. 33 at 6. And of
course, those witnesses who do testify at trial would be subject to examination on the record as to
what materials were provided or shown to them by the Government. Nothing in the Defense's
papers explains how its unprecedented proposed restriction is somehow necessary to ensure a
fair trial.
For the foregoing reasons, the Court adopts the Government's proposed protective order,
which will be entered on the docket.
This resolves Dkt. No. 29.
so ORDERED.
Dated: July 30, 2020
Alim Netto
New York, New York
ALISON J. NATHAN
United States District Judge
3
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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
MEMORANDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO
SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA
TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue New
York, NY 10022
Phone: 212-957-7600
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
EFTA00011452

=== Page 2 ===
TABLE OF CONTENTS
TABLE OF CONTENTS
i
TABLE OF AUTHORITIES
ii
TABLE OF EXHIBITS
iv
INTRODUCTION AND SUMMARY OF THE ARGUMENT
1
FACTUAL BACKGROUND
2
A.
The Protective Order in
V. Maxwell
2
B.
Maxwell's April and July 2016 depositions
4
C.
The Settlement And Boies Schiller's Refusal To Comply With The Protective Order
6
D. The Government's False Statements To Judge McMahon
6
E.
Judge Netburn Separately Rejects An Identical Gambit By The Government
10
ARGUMENT
11
A.
Pursuant To Its Inherent Power, This Court Should Suppress The Evidence Obtained
From Boies Schiller, And Dismiss Counts Five And Six, Which Are The Fruits Of That
Evidence
11
1.
The role of protective orders in civil litigation
11
2.
The government circumvented the protective order
12
3.
The government violated due process.
14
4.
This court possesses the inherent authority to order suppression
15
B.
At A Minimum, This Court Should Order A Hearing At Which Maxwell May Inquire
Into The Circumstances Surrounding The Government's Misrepresentations To Judge
McMahon
16
CONCLUSION
16
Certificate of Service
18
i
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=== Page 3 ===
TABLE OF AUTHORITIES
Cases
Benkovitch V. Gorilla, Inc., No. 2:15-cv-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017)
17
Brown V. Maxwell, 929 F.3d 41 (2d Cir. 2019)
3,6
Chambers V. NASCO, Inc., 510 U.S. 32 (1991)
17
Chemical Bank V. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994)
passim
Franks V. Delaware, 438 U.S. 154 (1978)
18
Giglio V. U.S., 405 U.S. 150 (1972)
16
V. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018)
6
Klein V. Weidner, Civ. No. 08-3798, 2017 WL 2834260 (E.D. Pa. June 30, 2017)
17
Manhattan Review LLC V. Yun, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept.
21, 2017)
17
Martindell V. Int 'l Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979)
12, 13
S.E.C. V. TheStreet. Com, 273 F.3d 222 (2d Cir. 2001)
12
Stewart V. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676 (S.D.N.Y. Dec. 9, 2020). 12
United States V. Avellino, 136 F.3d 249 (2d Cir. 1998)
16
United States V. Cortina, 630 F.3d 1207 (7th Cir. 1980)
16
United States V. Lambus, 897 F.3d 368 (2d Cir. 2018)
16
United States V. Paredes-Cordova, No. S1 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June
8, 2009)
18
United States V. Rajaratnam, 719 F.3d 139 (2d Cir. 2013)
18
United States V. Valentine, 820 F.2d 565 (2d Cir. 1987)
16
Young V. United States, 481 U.S. 787 (1987)
16
ii
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=== Page 4 ===
Other Authorities
Norman Mailer, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times
2
Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and
Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020)
9
Rules
Fed. R. Civ. P. 1
12
Constitutional Provisions
U.S. CONST. amend. V
15
iii
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=== Page 5 ===
TABLE OF EXHIBITS
EXHIBIT A: Civil Protective Order
EXHIBIT B:
Protective Order Proposal
EXHIBIT C: Sealed Affirmation and Application, USAO Ref. No. 2018R01618, 2/5/2019
EXHIBIT D: Transcript, 3/26/2019
EXHIBIT E: Transcript, 4/9/2019
EXHIBIT F: Sealed Order (19 Misc. 149 (CM)), 4/9/2019
EXHIBIT G: Sealed Memorandum Decision and Order Granting the Government's Application to
Modify the Protective Order (19 Misc. 149 (CM)), 4/9/2019
EXHIBIT H: Sealed Order (19-MC-00179 (SN)), 4/16/2019
EXHIBIT I: Sealed Letter to Judge Netburn, 4/9/2019
iv
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=== Page 6 ===
Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand
jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which
are the fruits of that unlawful subpoena.
INTRODUCTION AND SUMMARY OF THE ARGUMENT
Counts Five and Six allege that Maxwell committed perjury during two civil depositions
conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of
the firm's clients.
V. Maxwell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective
Order entered in that case prohibited the parties and their lawyers from sharing confidential
discovery material (including the two Maxwell depositions) with anyone else, including with the
government and law enforcement. Faced with that Protective Order, the government issued a
grand jury subpoena for Boies Schiller's file and instituted an ex parte proceeding before Chief
Judge McMahon to modify the Protective Order. By proceeding ex parte, the government
ensured that no one before the court would be able to contest the accuracy of its representations
in support of its application.
The government then took full advantage. Judge McMahon, citing this Court's decision
in Chemical Bank V. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994), asked the
government, point blank, whether Southern District prosecutors had previously met with the
Boies Schiller firm or otherwise "collu[ded]" with that firm in arranging the discovery request.
The government lawyer assured Judge McMahon that the prosecutors had no idea what was in
Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies
Schiller and United States Attorney's Office before the government commenced its investigation.
Nor, said the prosecutor, did Boies Schiller have any role instigating the Maxwell inquiry.
1
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=== Page 7 ===
To paraphrase Mary McCarthy's philippic about Lillian Hellman, every word of the
government's representation was untrue, "including 'and' and 'the. The government knew
what was in the Boies Schiller file; the law firm had provided that information well before the
investigation began. The government did indeed have previous contact with the firm. And Boies
Schiller was instrumental in fomenting the Maxwell prosecution.
The record is surpassingly clear: But for the government's misrepresentation, witting or
not, Judge McMahon never would have permitted the circumvention of the civil Protective
Order, on which Maxwell relied in agreeing to sit for her depositions. This Court therefore has
both the authority and the duty to suppress the fruits of that misrepresentation, including the
deposition transcripts and the two perjury counts based on those transcripts. If the Court is
disinclined to exercise that inherent authority on the present record, Maxwell should be granted a
hearing to examine the circumstances that resulted in the government's misrepresentations to
Judge McMahon.
FACTUAL BACKGROUND
A. The Protective Order in
v. Maxwell
Counts Five and Six of the superseding indictment allege that Maxwell committed
perjury during two civil depositions taken in
V. Maxwell, a civil defamation case
filed in 2015.
claimed that Maxwell defamed her when Maxwell's attorney-hired
press agent denied as "untrue" and "obvious lies"
numerous allegations, over the span
of four years, that Maxwell had participated in a scheme to cause
to be "sexually abused
and trafficked" by Jeffrey Epstein.
1 See Norman Mailer, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York
Times.
2
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=== Page 8 ===
a public figure required to prove actual malice, had an uphill battle-even she
was constrained to acknowledge that many of her public statements were false. Using a time-
honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the
lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter,
hard-fought, and wide-ranging. It spanned more than a year and included large document
productions, many responses to interrogatories, and thirty-some depositions, including
depositions of
and Maxwell as well as several third parties. See Brown V. Maxwell, 929
F.3d 41, 46, 51 (2d Cir. 2019) (explaining that discovery was "hard-fought" and "extensive" and
noting that the court file, which includes only some of the documents created during discovery,
totals in the "thousands of pages").
sought and obtained a wide variety of private and confidential information about
Maxwell and others, including information about financial and sexual matters. Brown, 929 F.3d
at 48 n.22. Given the intimate and highly confidential nature of the discovery exchanged between
the parties, the district court entered a stipulated Protective Order. See Ex. A. The Protective
Order included a mechanism for one party to challenge another party's confidentiality
designation (such a challenge never occurred) and provided that it did not apply to any
information or material disclosed at trial. (Because the case settled before trial, that sole
exception to the Protective Order was never triggered.)
Notably, Boies Schiller sought to add a "law enforcement" exception to the Protective
Order, doubtless because the firm was eager to enlist the government in its campaign against
Maxwell. In particular, Boies Schiller proposed to include a provision stating that
"CONFIDENTIAL information shall not be disclosed or used for any purpose except the
preparation and trial of this case and any related matter, including but not limited to,
investigations by law enforcement." Ex. B 1(a)(4) (emphasis supplied). Maxwell flatly rejected
3
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=== Page 9 ===
this proposal, and it was never included in the Protective Order. Ex. A.² To the contrary, the
order strictly limited the parties' disposition of Confidential Material, including at the conclusion
of the case. In particular, paragraph 12 of the order provided that:
[a]t the conclusion of this case, unless other arrangements are agreed upon, each
document and all copies thereof which have been designated as CONFIDENTIAL
shall be returned to the party that designated it CONFIDENTIAL, or the parties
may elect to destroy CONFIDENTIAL documents. Where the parties agree to
destroy CONFIDENTIAL documents, the destroying party shall provide all parties
with an affidavit confirming destruction.
Ex. A I 12.
B. Maxwell's April and July 2016 depositions
Relying on the confidentiality protections of the Protective Order, Maxwell declined to
invoke her privilege against compulsory self-incrimination and agreed to testify at her April
2016 deposition. In that deposition,
attorneys asked Maxwell whether "Jeffrey Epstein
[had] a scheme to recruit underage girls for sexual massages? If you know." Maxwell replied, "I
don't know what you're talking about." And when asked to "[I]ist all the people under the age of
18 that you interacted with at any of Jeffrey's properties," Maxwell responded, "I'm not aware of
anybody that I interacted with, other than obviously
who was 17 at this point." Count
Five of the superseding indictment alleges those two answers were false.
Following the deposition,
moved to compel Maxwell to answer additional
intimate and personal questions that she had previously declined to answer. In support of the
motion, Boies Schiller assured the district court that "[s]uch questions are entirely appropriate in
the discovery phase of this case, particularly where any answers will be maintained as
confidential under the Protective Order in this case."
2 This proposal was rejected because of justifiable concerns about the misuse and abuse of this
information by plaintiff and her lawyers including the selection and misleading leaking of confidential
material to the media, other false claimants, and the government.
4
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=== Page 10 ===
The district court granted the motion. In requiring Maxwell to answer highly intrusive
questions "relating to [her] own sexual activity" and "her knowledge of the sexual activity of
others," the court held that Maxwell's "privacy concerns are alleviated by the protective order in
this case."
Secure in the belief that the Protective Order would be honored, Maxwell appeared at a
second deposition, in July 2016, and answered hundreds of pages worth of questions about her
"own sexual activity" and "her knowledge of the sexual activities of others." From the very first
question, Maxwell discussed the intimate details of her sexual activity with Epstein, with other
adult men, with other adult women, the use of sex toys, participation in "threesomes," and a full
gamut of other sordid sexual topics. She was asked where she had sex, when she had sex, with
whom she had sex, what types of sexual predilections Epstein had, whether others watched her
having sex, whether she watched other people having sex, and whether she slept with clothes on.
She was asked whether Epstein had sex with any number of women, and the names of women he
might have had sex with. Maxwell was also grilled extensively about massages: when, where,
what she was wearing, who gave them.
Count Six of the superseding indictment alleges that Maxwell provided false testimony
when she testified during her July 2016 deposition that: (1) she could not recall whether sex toys
or devices were used in sexual activities at Epstein's Palm Beach house; (2) she did not know
whether Epstein possessed sex toys or devices used in sexual activities; (3) she wasn't aware that
Epstein was having sexual activities with anyone other than herself when she was with him; and
(4) she never gave anyone, including Accuser-23, a massage.
3 The indictment refers to the accusers as Minor Victim-1, Minor Victim-2, and Minor Victim-3.
We will refer to them as Accuser-1, Accuser-2, and Accuser-3.
5
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=== Page 11 ===
C. The Settlement And Boies Schiller's Refusal To Comply With The
Protective Order
In 2017, the parties settled the defamation claim, and the case was dismissed.
V.
Maxwell, 325 F. Supp. 3d 428, 436 (S.D.N.Y. 2018), vacated and remanded sub nom. Brown,
929 F.3d 41. As the district court found, "a significant, if not determinative, factor" in reaching a
settlement was its confidentiality. Id. at 446.
After the case was settled and concluded, Maxwell repeatedly invoked Paragraph 12 of
the Protective Order and demanded that
either return or destroy all confidential
information, including her deposition transcripts. Boies Schiller refused. Instead, and
unbeknownst to Maxwell, Boies Schiller produced some 90,000 pages of discovery material to
the government, including both of Maxwell's deposition transcripts.
D. The Government's False Statements To Judge McMahon
Only in August 2020, after she was indicted in this case, did Maxwell finally learn that
the government had obtained the Boies Schiller file by grand jury subpoena. Maxwell also
learned that, to overcome the strictures of the Protective Order, the government had instituted an
ex parte proceeding before Judge McMahon, Case No. 19-Misc.-149 (CM) (S.D.N.Y). Ex. C.
Needless to say, neither Maxwell nor her attorneys were given the opportunity to oppose that
application or to contest the government's representations in support of the application. This was
all in direct violation of Paragraph 14 of the Protective Order, which provides that the order may
be modified by the court only "for good cause shown following notice to all parties and an
opportunity to be heard." Ex. A I 14 (emphasis added).
In its ex parte application, the prosecutors professed that they had sought out Boies
Schiller's file only because "publicly available information regarding the
V. Maxwell]
6
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=== Page 12 ===
Litigation, including the complaint and other docketed filings
appear[ed] to make reference
to certain subjects relating to the Investigation." That "publicly available information," the
government claimed, indicated that the Boies Schiller file might "contain information relevant to
the ongoing Investigation" of Jeffrey Epstein. Ex. C, I 4. Nowhere did the government
acknowledge that Boies Schiller had in fact approached the prosecutors multiple times well
before the grand jury subpoena issued.
In March 2019, in the first appearance before Judge McMahon, the Government
continued this refrain, professing ignorance about what was in Boies Schiller's file or who was
deposed in the case. The prosecutor defended the subpoena's breadth-which sought all "copies
of discovery and related materials" in
V. Maxwell-on the ground that the government
simply had too little knowledge of what was in the law firm's files to craft a more narrowly
tailored subpoena:
Here, we are essentially unable to significantly narrow the request for information
in part for exactly the reasons that you describe. We have either little or no
additional information than the Court does in terms of what materials there are, who
was deposed, and that is in marked contrast to some of the other cases.
Ex. D, p 17. For all the government knew, according to the Assistant U.S. Attorney, what he was
seeking was "page after page of people taking the Fifth." Ex. D, p 19.
The government appeared a second time before Judge McMahon in April 2019. Ex. E.
Judge McMahon held that conference for one reason: to learn "about contacts between the
United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the
subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the government's
investigation began on either November 30 or December 3, 2018, omitting mention of any
contacts between Boies Schiller and the government prior to that time:
In the initial days and weeks of the investigation, we endeavored to identify
information about the subject of the investigation, including, among other things,
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possible victims who we should speak to. In the process of doing so, we identified
certain counsel that were identified as representing victims or witnesses either in
public filings or in media reports. Boies Schiller was among those plaintiff
attorneys. So following the opening of the investigation, we were in touch with
Boies Schiller, among other plaintiff and witness counsel, in connection with their
representation of witnesses or victims.
With respect to Boies Schiller in particular, we quickly came to learn during
the investigation that they had at the time either active or recently completed civil
litigation and so asked them, as is our standard practice, told them, I should say,
that we expected to make document requests. They generally advised us that they
believed there was a protective order that would govern at least some of the
materials, and that is why we ultimately made the application to the Court.
Ex. E, 99 pp 2-3.
Those representations were false. At the time the government claims it began the
investigation (late November or early December 2018), its knowledge of the civil case was not
based exclusively on public filings. It knew that Boies Schiller possessed relevant information
because the firm had come to the government asking it to open an investigation. In particular, on
February 29, 2016, AUSA
met with attorneys from Boies Schiller, who "urged
to open an investigation of" Epstein and Maxwell.4 Then, after Maxwell's two
depositions, David Boies himself apparently approached the government in the summer of 2016,
asking "if the Southern District would consider charging Maxwell with perjury." Brown, supra
n.2. Said Mr. Boies:
"We were saying to anyone who would listen: We've got clients who were abused.
Some of them were underage. We have the evidence. There's a whole record that's
been developed. We can establish beyond any reasonable doubt there was a massive
sex trafficking ring going on."
Id.
4 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and
Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020),
https://www.nydailynews.com/nev-york/ny-jefrey-epstein-maxwell-case-20201013-
jmzhl7zdrzdgrbbs7yc6bfnszu-story.html.
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=== Page 14 ===
At that time, however, the government did not act. Boies "was particularly frustrated by
the failure to pursue a perjury charge [against Maxwell]," reported one person, who recalled him
saying, "We have her dead to rights." Id. All of this contradicts The government's
representations to Judge McMahon, who specifically asked if the government had any contact
with Boies Schiller before it issued the subpoena.
Reassured by the government that no contact had occurred, Judge McMahon modified
the Protective Order so that Boies Schiller could comply with the subpoena. Ex. F. Judge
McMahon found that Maxwell could not have reasonably relied on the Protective Order as
prohibiting Boies Schiller from cooperating with the government. In making this finding, Judge
McMahon relied on the Assistant U.S. Attorney's misrepresentations, and she distinguished the
government's subpoena to Boies Schiller from the subpoena at issue in Chemical Bank. Said
Judge McMahon:
[T]he only thing on which Maxwell or anyone else might reasonably have relied is
that
or her lawyers would not do what the defendant in Chemical Bank
did-that is, forward discovery materials in their possession to prosecutors for the
purpose of fomenting an investigation. But I am not faced with that situation.
Nothing in this record suggests to me that
or Boies Schiller had anything to
do with the Government's decision to convene a grand jury to look into the matters
that were the subject of the
Action. On the contrary-the Government has
advised the Court that it contacted Boies Schiller as part of its search for parties
who might have been victims in its investigation; and that Boies Schiller told the
Government that it could not consensually produce at least some documents in its
files because of the existence of the Protective Order. There is no evidence of
"collusion," to invoke a term of the moment, and it is quite clear that Boies Schiller
did not foment the Government's investigation. Moreover, the Assistant United
States Attorney has represented to this Court that he has no idea what is in Boies
Schiller's files, and that for all he knows every witness who was deposed stood on
his/her Fifth Amendment rights and refused to answer questions.
Ex. G, P 21.
5 Ms. Maxwell strenuously disagrees with Mr. Boies' comments. We reference them here only to
show their connection to the perjury counts that the government subsequently charged.
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=== Page 15 ===
Contrary to the government's misrepresentations, Boies Schiller did foment the
investigation (or at least it tried to). And the evidence of "collusion" between the government
and Boies Schiller was ample, tracing to at least early 2016 and precisely designed to have
Maxwell charged with perjury.⁶ Had Judge McMahon known the truth, she likely would have
denied the government's application to modify the
V. Maxwell Protective Order, and the
government would have been unable to secure a copy of Boies Schiller's ninety-thousand-page
file, including Maxwell's two deposition transcripts.
E. Judge Netburn Separately Rejects An Identical Gambit By The
Government
Around the same time that Judge McMahon granted the government's ex parte request,
Magistrate Judge Netburn rejected an identical request from the government in a different civil
case, Jane Doe 43 V. Epstein, Case No. 17-cv-616 (JGK) (SN). Judge Netburn recognized the
government's conduct for what it was: an attempt to deprive Maxwell of notice and an
opportunity to be heard. Ex. H. Indeed, Judge Netburn rebuffed the government even after it
alerted her to Judge McMahon's order. Ex. I. As Judge Netburn found, the government's
"abstract concern" about the "secrecy" of its investigation-a concern that exists with any
investigation and is hardly unique to this case-could not overcome the parties' reasonable
reliance on the Protective Order or justify the government's secret, ex parte application. Ex. H, P
6. Judge Netburn also implicitly recognized what Judge McMahon never knew-that Boies
Schiller was all too eager for the government to investigate and prosecute Maxwell:
6 Maxwell has not yet been provided discovery of whether Boies Schiller shared actual sealed
materials or the contents of sealed materials during its meetings with the United States Attorney's Office
in 2016. As noted below, the bare minimum that is required here is an evidentiary hearing to probe the
extent to which Boies Schiller "colluded," in a Chemical Bank sense, with the prosecutor's office.
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[T]he extraordinary posture of the case requires the Court to police carefully
government intrusions into areas of protections agreed to by civil litigants and so-
ordered by the Court. The Government is attempting to side-step these protections
by serving a subpoena only upon a party who is willing (and perhaps eager) to
comply with the Government's investigation.
Ex. H, P 6.
ARGUMENT
A. Pursuant To Its Inherent Power, This Court Should Suppress The
Evidence Obtained From Boies Schiller, And Dismiss Counts Five And
Six, Which Are The Fruits Of That Evidence
1. The role of protective orders in civil litigation.
Protective orders serve a "vital function" in civil litigation. Martindell V. Int'l Tel. & Tel.
Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the 'secure the just, speedy, and
inexpensive determination' of civil disputes, by encouraging full disclosure of all evidence." Id.
(quoting Fed. R. Civ. P. 1). "If protective orders were easily modified
parties would be less
forthcoming in giving testimony and less willing to settle their disputes." S.E.C. V.
TheStreet. Com, 273 F.3d 222, 230 (2d Cir. 2001). In particular, as here, "witnesses might be
expected frequently to refuse to testify pursuant to protective orders if their testimony were to be
made available to the Government for criminal investigatory purposes in disregard of those
orders." Martindell, 594 F.2d at 295-96. Parties thus rely on protective orders, and courts strictly
enforce them. See, e.g., Stewart V. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676, at
*2 (S.D.N.Y. Dec. 9, 2020) ("In the Second Circuit, there is a strict standard for modification of
a protective order entered by a district court." (citation and quotation marks omitted)).
This case illustrates just how crucial a protective order is. The Maxwell depositions
sought highly intrusive evidence of the most personal aspects of Maxwell's life. Her sexual
practices. Her sexual preferences. Her sexual partners. In urging the district court to permit these
extraordinary intrusions-in what should have been a simple defamation case-Boies Schiller
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expressly invoked the assurances of the Protective Order. So did the district court in permitting
these intrusions and ordering Maxwell to sit for a second deposition. Maxwell likewise relied on
the Protective Order in choosing to render such intimate details, rather than assert her Fifth
Amendment privilege as she had every right to do.
And why shouldn't Maxwell have relied on the Protective Order? The central protection
in the Order was that none of Maxwell's answers could be disclosed to the government. Boies
Schiller had expressly sought a law enforcement exception but was rebuffed. Instead, the law
firm was required either to return the confidential material or, at Maxwell's option, to destroy it.
Maxwell had every reason to take that assurance seriously, even if Boies Schiller did not.
2. The government circumvented the protective order.
Faced with a duly entered Protective Order-which quite deliberately omitted any "law
enforcement" exception-the government had lawful options to pursue the confidential
discovery. It could have moved to intervene in the civil case and to amend the Protective Order.
It could have issued a subpoena for the materials and given Maxwell an opportunity to respond.
Martindell, 594 F.2d at 294. It could even have applied for a search warrant, assuming
(counterfactually) that it could show probable cause in support of such a warrant.
The government did none of those things. Instead, it initiated an ex parte proceeding and
secured a secret modification of the Protective Order based on material misrepresentations to the
presiding judge. This was not among the lawful options available to the government.
It cannot fairly be disputed that Judge McMahon's ruling to amend the Protective Order
was based on the government's misrepresentations. Immediately before issuing her decision,
Judge McMahon held a hearing with the sole purpose of asking the prosecutor, point blank,
about the government's contacts with Boies Schiller. Judge McMahon's stated reason for so
inquiring was to ensure that the government and Boies Schiller had not coordinated as the parties
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=== Page 18 ===
had in the Chemical Bank case. In no uncertain terms, Judge McMahon explained why she had
haled the prosecutor back into court:
I'll be very up-front with you. I want to make sure I'm not in a Chemical Bank kind
of situation, so I would like to know about contacts between the United States
Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena
on the subject of your investigation.
Ex. E, P 2.
In Chemical Bank, a protective order precluded parties to a civil case from disclosing
confidential documents to others. 154 F.R.D. at 92-93. Despite this prohibition, counsel for the
defendant approached the Manhattan District Attorney's Office and suggested that it had
evidence of criminal violations relating to the case. Id. at 93. A grand jury issued a subpoena,
and the defendant produced to the government various confidential documents without
complying with any of the specific procedures or exceptions provided in the protective order. Id.
Once this collusion came to light, the district court reprimanded the defendant for its "disregard
of the [protective] order[]" and admonished its behavior as "contrary to the traditions of the Bar
which dictate that court orders be respected." Id.
In addressing the government's application here, Judge McMahon specifically asked
whether Boies Schiller had acted as the defendant did in Chemical Bank. The prosecutor omitted
any mention of his office's previous meetings with the firm, and falsely led the court to believe
that Boies Schiller had not encouraged its investigation. Reassured by the misrepresentations,
Judge McMahon commented:
Nothing in this record suggests to me that
or Boies Schiller had anything to
do with the Government's decision to convene a grand jury to look into the matters
that were the subject of the
Action. On the contrary-the Government has
advised the Court that it contacted Boies Schiller as part of its search for parties
who might have been victims in its investigation; and that Boies Schiller told the
Government that it could not consensually produce at least some documents in its
files because of the existence of the Protective Order. There is no evidence of
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"collusion," to invoke a term of the moment, and it is quite clear that Boies Schiller
did not foment the Government's investigation.
Had Judge McMahon known the truth, she likely would not have granted the government's
application to modify the Protective Order to allow Boies Schiller to comply with the subpoena.
3. The government violated due process.
The government's conduct cannot be squared with elemental due process. U.S. CONST.
amend. V. Pursuant to this guarantee, "[t]he responsibility of a public prosecutor differs from
that of the usual advocate; his duty is to seek justice, not merely to convict." Young V. United
States, 481 U.S. 787, 803 (1987). The government engages in misconduct and violates due
process when it materially misrepresents facts before a court. See United States V. Valentine, 820
F.2d 565, 570 (2d Cir. 1987) (holding that the government violated due process and reversing
conviction when the government mischaracterized the substance of grand jury testimony).
The prosecutor may well have known that his representations to Judge McMahon were
false (or at best misleading). But the Assistant U.S. Attorney's personal knowledge doesn't
matter. "An individual prosecutor is presumed to have knowledge of all information gathered
in connection with his office's investigation of the case." United States V. Avellino, 136 F.3d 249,
255 (2d Cir. 1998); see also Giglio V. U.S., 405 U.S. 150, 154 (1972) ("The prosecutor's office is
an entity and as such it is the spokesman for the Government. A promise made by one attorney
must be attributed, for these purposes, to the Government."). At the barest minimum, a federal
prosecutor has a duty to check the entire file to ensure that his representations to a federal judge,
submitted on behalf of the office he serves and under oath, are true and complete. The Assistant
U.S. Attorney did not discharge that basic function.
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=== Page 20 ===
4. This court possesses the inherent authority to order suppression.
Incident to its inherent power to superintend proceedings, this Court has the authority to
suppress the fruits of the government's misrepresentation. See, e.g., United States V. Cortina, 630
F.3d 1207, 1214 (7th Cir. 1980) ("The court has inherent authority to regulate the administration
of criminal justice among the parties before the bar
[by] exclud[ing] evidence taken from
the defendant by willful disobedience of law." (citation omitted)); United States V. Lambus, 897
F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence
gathered unlawfully in order to maintain the integrity of its own proceedings
"); Benkovitch
V. Gorilla, Inc., No. 2:15-cv-7806 (WJM), 2017 WL 4005452, at *2 (D.N.J. Sept. 12, 2017)
("District courts have 'inherent authority' to impose a variety of sanctions, including
suppression of evidence
").
It does not matter that the government made its misrepresentations to Judge McMahon
and not directly to this Court. "As long as a party receives an appropriate hearing,
the party
may be sanctioned for abuses of process occurring beyond the courtroom
" Chambers V.
NASCO, Inc., 510 U.S. 32, 57 (1991). "Courts have held that inherent authority sanctions may be
imposed for misconduct in another court where the misconduct is
in some way related to the
case before the sanctioning court." Klein V. Weidner, Civ. No. 08-3798, 2017 WL 2834260, at *6
(E.D. Pa. June 30, 2017) (citation and alteration omitted); Manhattan Review LLC V. Yun, 16
Civ. 0102 (LAK) (JCF), 2017 WL 11455317, *7 n.3 (S.D.N.Y. Sept. 21, 2017) ("The inherent
power
can punish conduct before a different court if it is intimately related to the relevant
case." (citing Klein, 2017 WL 2834260, at *4)). Here, the government's misrepresentation to
Judge McMahon was not simply "related" to Counts Five and Six; only by the government's
deception was it able to obtain the factual predicate for those counts. Accordingly, the Court may
exercise its inherent authority to suppress that evidence. And it should.
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B. At A Minimum, This Court Should Order A Hearing At Which Maxwell
May Inquire Into The Circumstances Surrounding The Government's
Misrepresentations To Judge McMahon
If the Court is disinclined to grant relief on the present record, then at a minimum it
should hold an evidentiary hearing to probe the government's misstatements to Judge McMahon
and the extent to which the prosecutor's office had, in fact, coordinated with Boies Schiller prior
to the issuance of the grand jury subpoena. These factual issues go directly to whether the
predicate finding for Judge McMahon's ruling-namely, that no Chemical Bank collusion had
occurred-was mistaken. See, e.g., United States V. Paredes-Cordova, No. S1 03 CR. 987DAB,
2009 WL 1585776, at *1 (S.D.N.Y. June 8, 2009) ("An evidentiary hearing is normally required
to address motions to suppress where a factual issue is in dispute.").
An evidentiary hearing is warranted for an additional reason as well: If it turns out that
the prosecutor knew (or was reckless in not knowing) that Boies Schiller had previously
approached his office, both before and after the Maxwell depositions, in an effort to stir up a
criminal prosecution and dangled the deposition transcripts as a carrot, then suppression would
be warranted on that basis alone. Cf. Franks V. Delaware, 438 U.S. 154, 155-56 (1978); United
States V. Rajaratnam, 719 F.3d 139, 146 (2d Cir. 2013) ("Franks instructs a district court to hold
a hearing to determine whether the alleged misstatements or omissions in the warrant or wiretap
application were made intentionally or with reckless disregard for the truth and, if so, whether
any such misstatements or omissions were material.").
CONCLUSION
For these reasons, this Court should: (1) suppress all evidence the government obtained
from Boies Schiller and any other evidence derived therefrom; or (2) suppress the April and July
2016 depositions and all evidence derived therefrom; and (3) dismiss Counts Five and Six.
Maxwell requests an evidentiary hearing on this Motion.
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=== Page 22 ===
Dated: January 25, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue New York, NY 10022 Phone:
212-957-7600
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
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Certificate of Service
I hereby certify that on January 25, 2021, served by email, pursuant Rule 2(B) of the
Court's individual practices in criminal cases, the Memorandum of Ghislaine Maxwell in Support
of Her Motion Under the Due Process Clause to Suppress All Evidence Obtained from the
Government's Subpoena to Boies Schiller and to Dismiss Counts Five And Six upon the
following:
U.S. Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
s/ Christian R. Everdell
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