# docs_fts_content

c1: EFTA00017950
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017950.pdf
c6: pdf
c7: images
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=== Page 1 ===
From:
To:
Subject: FW: MCC Video Extraction
Date: Mon, 09 Mar 2020 21:30:40 +0000
See below
Special Agent
FBI New York Field Office
Violent Crimes Task Force
From
Sent: Wednesday, August 14, 2019 5:48 PM
To:
Subject: Fwd: MCC Video Extraction
FYSA
Special Agent
FBI New York C-19
Violent Crimes Task Force
Forwarded message
From:
Date: Aug 14, 2019 5:04 PM
Subject: Fwd: MCC Video Extraction
To:
Cc:
-
Forwarded message
From:
Date: Aug 14, 2019 3:14 PM
Subject: MCC Video Extraction
To: "
Cc:
Technical Update:
At 12:30 pm today I met
the new Acting Warden of the MCC. Due to the transition of personnel at the
MCC there has been some miscommunication between the MCC, the FBI, and the video surveillance vendor
NiceVision. After speaking with NYO EM and then talking with
,
the following is the plan to extract all
relevant video surveillance from the MCC, which also allows for the MCC to maintain a video surveillance system for
security purposes.
As a quick background, the MCC has two (2) DVR surveillance systems which provide coverage for the entirety of
EFTA00017950

=== Page 2 ===
the facility. Each system, DVR system #1 and DVR system #2, contain sixteen (16) hard drives which recorded the
activity captured by the associated cameras. According to MCC staff, on 07/29/19, DVR system #2 had two to three
hard drives fail causing most of that system to stop recording. Two of the three camera feeds of obvious interest
resided on DVR system #2, meaning they were not recording at the time of the suicide on 08/10/19. Long before the
hard drive failures and the suicide of the subject, the MCC had contracted with NiceVision to replace the antiquated
system being utilized by the facility. NiceVision arrived at the MCC on Monday 08/12/19 to begin work on the
installation. NiceVision has not completed the work on the system because they have not had access to the equipment
room since FAVU arrived later that same day to export video from a camera feed on the working DVR system #1.
After consultation with NYO CART and OTD, it has been determined the best chance for the FBI to extract and
review video surveillance footage is to remove DVR system #2 immediately.
This system is currently being extracted with the permission of MCC Acting Warden
A member of NY
CART will transport this system down to OTD today where a team from DFAS-DSAU will be waiting to receive and
attempt a rebuild of the failed hard drives. This will be necessary in order for us to reconstitute the system later when
we receive DVR system #1 at OTD.
Another team from FBI FAVU is currently on-site working on exporting video from the third camera of interest
connected to DVR system #1, which is currently operational and being utilized by the MCC. We will continue to
export video from this camera back through at least 07/23/19, the date of the first alleged suicide attempt. Review has
begun on this camera by C-19 and SDNY. At the same time C-19 will maintain a 24-7 presence in the equipment
room to ensure integrity of the system and to also allow access for simultaneous work by NiceVision to complete the
install of the new video surveillance system. NiceVision is currently once again working on the install and estimated a
completion of the work as early as tomorrow (8/15/19). Once the new system is operational and FAVU has completed
the download from the one known camera of interest residing on DVR system #1, we will collect it and send that
down to OTD. We anticipate we could send down DVR system #1 down within the next two days. This will
potentially allow us to reconstitute both systems down at OTD where we can determine what video is present. Then
we will review the entirety of the recorded video surveillance for evidentiary purposes.
It should be noted that the 30 day over-write in these systems were suspended for DVR system #1 and DVR system
#2 on 08/12/19 and 08/10/19, respectively. Also of note, beside the attempt to rebuild the failed hard drives, there is a
significant chance the hard drives pulled from DVR #2 on 08/10/19, are corrupted and/or encrypted since they were
extracted while the system was running. We will know more about this issue once we can reconstitute the system and
review. It is estimated the work described in this communication may take several weeks to complete. After all efforts
have been made the possibility exists the rebuild of the hard drives and reconstitution of the systems may ultimately
fail to produce the desired outcome.
EFTA00017951


c1: EFTA00018031
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018031.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
)"
To: Jack Scarola
Cc:
)"
(USANYS)"
)"
Subject: Local Criminal Rule 23.1
Date: Mon, 02 Aug 2021 14:59:46 +0000
Attachments: 2021.07.30_Order_Regarding_Local_Rule_23.1.pdf
Hi Jack,
We wanted to let you know about a recent order from Judge Nathan regarding Local Criminal Rule 23.1, which applies not
only to counsel of record in a criminal case, but also to attorneys associated with a case, such as attorneys for witnesses.
The order is attached, and the full text version of the local SDNY rules can be found on the court's website. If you have
any questions about the rule or the order, please let us know.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00018031


c1: EFTA00018747
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018747.pdf
c6: pdf
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=== Page 1 ===
From:
(USANYS)"
To:
USANYS)"
Subject: NYLJ article
Date: Mon, 11 May 2020 20:06:14 +0000
Attachments: NYLJMay6.pd.pdf
I didn't see this when it came out, so I am sharing it in case you missed it as well.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00018747


c1: EFTA00019914
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019914.pdf
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
,
)"
Subject: Maxwell testifying witness 3500
Date: Sat, 19 Jun 2021 23:49:42 +0000
Attachments: 2021.06.07
prep_notes.pdf;
2021.06.09
prep_notes.pdf; 2021.06.07
prep_notes.pdf
Hi
Would you please save the attached pdfs in the respective witness and 3500 folders for the testifying witnesses in each
pdf's file name on the Epstein share drive?
Thanks,
EFTA00019914


c1: EFTA00020083
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020083.pdf
c6: pdf
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=== Page 1 ===
From:
)"
To:
)
[Contractor]"
Cc:
)"
Subject: Re:
proffer agreement
Date: Thu, 29 Aug 2019 17:28:32 +0000
I'm happy to pick it up if you want to leave it on your chair, I know you're busy.
Sent from my iPhone
On Aug 29, 2019, at 1:27 PM,
) [Contractor]
wrote:
Yep, I will bring it by your office now.
From:
Sent: Thursday, August 29, 2019 1:12 PM
To:
)
[Contractor]
Cc:
Subject:
proffer agreement
Hi
So sorry to bug you while you're on trial. We are flying to Florida on Tuesday morning for a proffer with
and I think you have the original proffer agreement in your files for the Epstein investigation. Any chance
we could please grab that from you by tomorrow?
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00020083


c1: EFTA00020345
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020345.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Jeffrey Epstein
Date: Tue, 23 Jul 2019 20:46:27 +0000
Let's discuss timing.
From:
Sent: Tuesday, July 23, 2019 3:25 PM
To:
Subject: RE: Jeffrey Epstein
Yes, I am happy to do what I can to assist your trial team. I will be here the rest of the week. My office number is
cell phone is
From:
Sent: Tuesday, July 23, 2019 2:22 PM
To:
Subject: Jeffrey Epstein
Hi,
Our Jeffrey Epstein team here is working on gathering material that may be discoverable in our case
or pertinent to an anticipated motion by Epstein for dismissal based on the S.D.Fla. agreement. We assume you
had to pull together a lot of discovery for the CVRA litigation, and that you probably have a good sense of where
else, or with whom else, in the S.D.Fla., we might need to look for pertinent information. The attorneys in the
N.D.Ga. who are handling the CVRA litigation said we should check directly with you, and ADAG
cleared us to reach out to you directly on this. Would you have some time this week for us to give you a call
about this? Thanks much,
-
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
New York, NY 10007
EFTA00020345


c1: EFTA00019348
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019348.pdf
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c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
Federal Bureau of Prisons
MASSACHUSETTS PERSONAL
EAULO
Inmate Investigative Report
Institution: New York MCC
Case Number: NYM-19-0061
Investigation Type: Investigative / Threat Assessment
Inmates Involved:
Register Number Name
Role
EPSTEIN, JEFFREY
Not Known
TARTAGLIONE, NICHOLAS
Not Known
Staff Involved:
Name
Title
**No information was found for the given criteria.**
Others Involved:
Name
Title
**No information was found for the given criteria.**
Investigator:
Date: 8/1/2019 5:06:24 AM CST
Captain:
Date: 8/2/2019 10:06:35 AM CST
Associate Warden:
Date: 8/2/2019 10:32:28 AM CST
Warden:
Date: 8/2/2019 11:34:41 AM CST
SBU - - Sensitive But Unclassified
Page 1 of 5
FOIA Exempt
EFTA00019348

=== Page 2 ===
Summary:
On July 23, 2019 at approximately 1:27 a.m., while making routine rounds inside the Special Housing Unit, staff
observed inmate Epstein, Jeffrey Reg. No.
lying in the fetal position on the floor with a homemade
fashioned noose around his neck. Inmate Epstein was breathing heavily, however appeared to be responsive.
Inmate Epstein was directed by staff to stand and submit to restraints. Inmate Epstein would not stand on his own
and would not comply with staff directives. Staff entered the cell and placed inmate Epstein in both hand and leg
restraints. Inmate Epstein was searched, metal detected, placed on a gurney and escorted from the scene without
further incident. Inmate Epstein was photographed, medically examined and determined to have sustained a circular
line of erythema at the base of the neck and friction marks on the front of neck, and small 2cm erthema on left knee.
Inmate Epstein was placed on suicide watch with all necessary notifications made. There were no staff injuries
reported.
Inmate Data:
Name:
- EPSTEIN, JEFFREY
Role: Not Known
Age: 66 Race: WHITE
Security Level: UNASSG
Custody Level: IN
Facility Arrival Date: 7/7/2019
Projected Release Date:
Charges:
Description
Sentencing District
No Charges Found
STGs:
CIMs:
HISTORY OF COMMITTING
No CIMs Found
Name:
- TARTAGLIONE, NICHOLAS
Role: Not Known
Age: 51 Race: WHITE
Security Level: UNASSG
Custody Level: IN
Facility Arrival Date: 1/23/2018
Projected Release Date:
Charges:
Description
Sentencing District
No Charges Found
STGs:
CIMs:
EX LAW ENFORCEMENT
SEPARATION
POSTED PICTURE CARD FILE
Victim Statements:
**No information was found for the given criteria.**
Assailant Statements:
**No information was found for the given criteria.**
SBU - Sensitive But Unclassified
Page 2 of 5
FOIA Exempt
EFTA00019349

=== Page 3 ===
Other Statements:
Date: 7/31/2019 9:00 AM
Location: Receiving And Discharge
Interviewer:
Title: LIEUTENANT
Interviewee:
- EPSTEIN, JEFFREY
On July 31, 2019, at approximately 9:10 A.M., inmate Epstein, Jeffrey; Reg. No.
was interviewed in the Receiving
and Discharge Area. During the interview Epstein stated he did not have any sleep in approximately twenty days and he was
extremely tired the night he was found on the floor. Epstein stated he got up off his bed at approximately 1:30 A.M., to get a drink
of water, and all he can recall is being on the floor and hearing someone snoring that's when he realized the snoring was coming
from him. Epstein alleged that his cell mate Tartaglione, Nicholas; Reg. No.
was on the floor sleeping at the time.
Epstein stated he has never had any issues with Tartaglione, he is not threatened by Tartaglione, and he do not want to make up
something that isn't there. Additionally, Epstein stated he can recall an incident that occurred two days prior when Tartaglione
went out to court and when Tartaglione returned he was upset. Epstein stated he attempted to talk to Tartaglione and Tartaglione
called him a pedophile. Epstein also stated he knew Tartaglione was upset and he let him cool off. Epstein stated he does not
have any issues with Tartaglione and he feels safe being housed with Tartaglione. Epstein stated he does not feel suicidal, he
has a new cell mate whom he gets along with, and he is able to sleep now that he has his C-Pap machine. Epstein stated if he
remembered anymore details he would reach out to staff or Psychology.
Date: 7/31/2019 10:00 AM
Location: SHU All Other
Interviewer:
Title: LIEUTENANT
Interviewee:
- TARTAGLIONE, NICHOLAS
On July 31, 2019, at approximately 10:00 A.M., inmate Tartaglione, Nicholas; Reg. No.
was interviewed in the
Special Housing Unit. During the interview Tartaglione stated he was asleep on the floor inside of his cell, his head was covered
with a sheet, and he had his headphones in his ear when he felt something hit his foot. Tartaglione stated when he uncovered his
head he observed Epstein, Jeffrey; Reg. No.
sitting on the floor in the corner with his eyes open. Tartaglione stated
he began to call Epstein's name and when Epstein did not answer he began to bang on the door for the officer. Tartaglione stated
he thought Epstein was having a heart attack because his eyes was open and he appeared to be snoring. Tartaglione stated he
does not have any issues being housed with Epstein although he keeps his conversation to a minimal. Tartaglione stated he does
not understand Epstein's motive and what he is trying to do. Tartaglione stated previously during one of their conversations
Epstein made him uncomfortable when Epstein stated fourteen (14) is legal in most states and I don't understand what's the
problem here". Additionally, Tartaglione stated Epstein normally paces the cell and complains about his attorney's not doing their
job and he needs to fire them. Tartaglione stated he does not have any issues being housed with Epstein however he does not
want to be involved with any plots Epstein have in mind in order to try to get released.
Factual Findings:
**No item information was found for the given criteria.**
SBU - Sensitive But Unclassified
Page 3 of 5
FOIA Exempt
EFTA00019350

=== Page 4 ===
Type
Subtype
File Name
Original Entered By
Inmate Discipline
Administrative Detention Order ADO.pdf
TF18813
Detention Order dated July 10, 2019, placing Epstein, Jeffrey; Reg. No.
in Administrative Detention
pending classification.
Inmate Discipline
Incident Report
INMATE EPSTEIN
TF18813
IR.pdf
On July 23, 2019, staff wrote Epstein an incident report for code 228- Self Mutilation.
Medical
Inmate Assessments
MEDICAL
TF18813
ASSESSMENT.pdf
On July 23, 2019, a medical assessment was conducted on inmate Epstein, Jeffrey; Reg. No.
8-
by
MLP. During the assessment Epstein was identified with a circular line of erythema at the base of his
neck reaching 2/3 of the neck circumference, 2 inches wide, sparing the back of the neck. Additionally, one section
of this erythema in the front has marks of friction, and Epstein was observed with a small erythema on the left
knee about 2cm in diameter(mild). During the assessment Epstein denied any respiratory problems and Epstein
denied any pain or discomfort.
Statements & Written
Operation's Lieutenant
OPS LT MEMO.pdf
TF18813
Memorandums
On July 23, 2019, at approximately 1:27 A.M., the Operations Lieutenant submitted a memorandum which
indicated the Control Center Officer requested assistance in the Special Housing Unit. Upon entering the Special
Housing Unit staff made notification that Epstein, Jeffrey; Reg. No.
, was observed laying in a fetal
position on the floor. Epstein was removed from the Special Housing Unit and escorted to the Health Services
Area.
Medical
Inmate Assessments
TARTAGLIONE
TF14688
MEDICAL.pdf
On July 31, 2019, a medical assessment was conducted on inmate Tartaglione, Nicholas; Reg. No.
7
I by
# PA-C. During the assessment Tartaglione was not identified with any injuries by Health Services
Staff.
Photographs
Contraband
PHOTOGRAPH OF TF14688
HOMEMADE
ROPE.pdf
PHOTOGRAPH OF HOMEMADE ROPE ECN#NYM-19-0147
Evidence Control
Chain Of Custody
CHAIN OF
TF14688
CUSTODY.pdf
CHAIN OF CUSTODY FORM
Conclusion:
On July 23, 2019 at approximately 1:27 a.m., while making routine rounds inside the Special Housing Unit, staff
observed inmate Epstein, Jeffrey Reg. No.
lying in the fetal position on the floor with a homemade
fashioned noose around his neck. Inmate Epstein was breathing heavily, however Epstein appeared to be
responsive. Inmate Epstein was directed by staff to stand and submit to restraints. Inmate Epstein would not stand
on his own and would not comply with staff directives. Staff entered the cell and placed inmate Epstein in both hand
and leg restraints. Inmate Epstein was searched, metal detected, placed on a gurney and escorted from the scene
without further incident. Inmate Epstein was photographed, medically examined and determined to have sustained a
circular line of erythema at the base of the neck and friction marks on the front of neck, and small 2cm erythema on
left knee. Inmate Epstein was placed on suicide watch with all necessary notifications made. On July 31, 2019, at
approximately 9:10 A.M., inmate Epstein, Jeffrey; Reg. No.
was interviewed in the Receiving and
Discharge Area by SIS Staff. During the interview Epstein stated he did not have any sleep in approximately twenty
days and he was extremely tired the night he was found on the floor. Epstein stated he got up off his bed at
approximately 1:30 A.M., to get a drink of water, and all he can recall is being on the floor and hearing someone
snoring that's when he realized the snoring was coming from him. Epstein alleged that his cell mate Tartaglione,
Nicholas; Reg. No.
was on the floor sleeping at the time. Epstein stated he have never had any issues
with Tartaglione, he is not threatened by Tartaglione, and he do not want to make up something that isn't there.
Additionally, Epstein stated he can recall an incident that occurred two days prior when Tartaglione went out to court
and when Tartaglione returned he was upset. Epstein stated he attempted to talk to Tartaglione and Tartaglione
SBU - Sensitive But Unclassified
Page 4 of 5
FOIA Exempt
EFTA00019351

=== Page 5 ===
called him a pedophile. Epstein also stated he knew Tartaglione was upset and he let him cool off. Epstein stated he
does not have any issues with Tartaglione and he feels safe being housed with Tartaglione. Epstein stated he does
not feel suicidal, he has a new cell mate, and he is able to sleep now that he has his C-Pap machine. Epstein stated
if he remembered anymore details he would reach out to staff or Psychology.
On July 31, 2019, at approximately 10:00 A.M., inmate Tartaglione, Nicholas; Reg. No.
was also
interviewed by SIS Staff in the Special Housing Unit. During the interview Tartaglione stated he was asleep on the
floor inside of his cell, his head was covered with a sheet, and he had his headphones in his ear when he felt
something hit his foot. Tartaglione stated when he uncovered his head he observed Epstein, Jeffrey; Reg. No.
sitting on the floor in the corner with his eyes open. Tartaglione stated he began to call Epstein's name
and when Epstein did not answer he began to bang on the door for the officer. Tartaglione stated he thought Epstein
was having a heart attack because his eyes was open and he appeared to be snoring. Tartaglione stated he does
not have any issues being housed with Epstein although he keeps his conversation to a minimal. Tartaglione stated
he does not understand Epstein's motive and what he is trying to do but previously during one of their conversations
Epstein made him uncomfortable when Epstein stated fourteen (14) is legal in most states and I don't understand
what's the problem here". Additionally, Tartaglione stated Epstein normally paces the cell and complains about his
attorney's not doing their job and he needs to fire them. Tartaglione stated he does not have any issues being
housed with Epstein however he does not want to be involved with any plots Epstein may have in mind in order to
try to get released. As a result of a threat assessment being conducted a medical assessment was conducted on
inmate Tartaglione and Tartaglione was not identified with any injuries. Based on the information received
throughout the course of the investigation there is insufficient evidence to support Epstein was assaulted by
Tartaglione. Additionally, based on the fact that during the interview with SIS staff Epstein indicated that he does not
feel threatened by Tartaglione, and he has a new cell mate whom he get along with it cannot be determined that
Epstein safety is in jeopardy at MCC New York.
Recommendation:
Based on the information received and the fact that Epstein, Jeffrey; Reg. No.
indicated that he does not
feel threatened by Tartaglione, Nicholas; Reg. No.
there are no CIMS Assignment of Separations
warranted at this time.
CIMS Separation Warranted: No
SBU - Sensitive But Unclassified
Page 5 of 5
FOIA Exempt
EFTA00019352

=== Page 6 ===
METROPOLITAN CORRECTIONAL CENTER
NEW YORK
MENT OF JI
TOWAY BUREAU OF SKOSING
JEFFREY, EPSTEIN
REG. NO.
583 REPORT OF
INCIDENT
NYM-19-0076
EFTA00019353

=== Page 7 ===
Form 583 Report of Incident
Incident #: NYM-19-
Submitted By:
Date/Time Of Incident: 7/23/2019 1:27 AM
0076
Section 1: General Information
Staff Aware Date: 7/23/2019 1:27 AM
FBI Notified: No
USMS Notified: No
Indicate Where Incident Occurred: Main Facility
Location Level 1: SHU
Level 2: Housing Unit, Special (SHU)
Level 3: 9 SOUTH SHU
Type Of Incident
Institution Locked Down: No
Assault On Inmate
Modified Operations: No
Assault On Staff
Cause Of Incident Known? No
Assault, Attempted On Inmate
Assault, Attempted On Staff
Cause Of Incident
Alcohol
Disruptive Behavior
Commissary
Escape From Non-secure Facility
Debts
Escape From Secure Facility
Disrespect Issue
Escape, Attempted From Non-secure Facility
Drugs
Escape, Attempted From Secure Facility
Ethnic Conflict
Fight
Food Issue
Inmate Death
Geographical Conflict
Institution Disturbance
Interfering with Staff duties
Introduction Of Contraband
Property Issue
Lethal Weapons Discharge
Racial Conflict
Self Mutilation
Recreation Equipment
Religious Issue
Setting A Fire
Security Threat Group Conflict
Sexual Act, Non-consensual On Inmate
Sexual Pressure
Sexual Assault On Staff
Sporting Events
Sexual Contact, Abusive On Inmate
Telephone
Sexual Harassment, Repetitive
Theft
Staff Homicide
Visiting
Strike, Food
Work Issue
Strike, Work
Suicide Attempt
Method: Hanging/Asphyxiation
Use Of Force
Use Of Force/Applications Of Restraints
Use of Restraints, Pregnant/Postpartum
Section 2: Inmates Involved
UNCLASSIFIED/LIMITED OFFICIAL USE ONLY/LAW ENFORCEMENT SENSITIVE
This document is marked Unclassified/Limited Official Use Only/Law Enforcement Sensitive and may be disseminated, with proper
attribution, to active Law Enforcement, DOD, or U.S. Intelligence Agencies. This document, or any segment/attachment thereof, may
not be released without the approval of the Bureau of Prisons to any media sources, any non-law enforcement entity, the general
public or those without a "need to know." It contains information that may be exempt from public release under the provisions of the
Privacy Act (5 U.S.C. 552).
1 of 3
EFTA00019354

=== Page 8 ===
Form 583 Report of Incident
Incident #: NYM-19-
Submitted By:
Date/Time Of Incident: 7/23/2019 1:27 AM
0076
Reg #:
Name: EPSTEIN, JEFFREY
Role: Victim
Medical Attention Required: No
Injury Category: Minor Injury
Weapon (per inmate): No
Use of Force (per inmate): No
Chemical Used (per inmate): No
CIMS: No
STG: Yes
Restraints (per inmate): Escort Only
Death (per inmate):
No
Reg #:
Name: TARTAGLIONE, NICHOLAS
Role: Not Known
Medical Attention Required: No
Injury Category: No Injury
Weapon (per inmate): No
Use of Force (per inmate): No
Chemical Used (per inmate): No
CIMS: Yes
STG: Yes
Restraints (per inmate): No
Death (per inmate):
No
Section 3: Others Involved
Name:
Person Type: Staff
Medical Attention Required: No
Death: No
Injury Category: No Injury
Staff Injury by Inmate: No
Sexual Assault: No
Name:
Person Type: Staff
Medical Attention Required: No
Death: No
Injury Category: No Injury
Staff Injury by Inmate: No
Sexual Assault: No
Name:
Person Type: Staff
Medical Attention Required: No
Death: No
Injury Category: No Injury
Staff Injury by Inmate: No
Sexual Assault: No
Name:
Person Type: Staff
Medical Attention Required: No
Death: No
Injury Category: No Injury
Staff Injury by Inmate: No
Sexual Assault: No
Name:
Person Type: Staff
Medical Attention Required: No
Death: No
Injury Category: No Injury
Staff Injury by Inmate: No
Sexual Assault: No
Name:
Person Type: Staff
Medical Attention Required: No
Death: No
UNCLASSIFIED/LIMITED OFFICIAL USE ONLY/LAW ENFORCEMENT SENSITIVE
This document is marked Unclassified/Limited Official Use Only/Law Enforcement Sensitive and may be disseminated, with proper
attribution, to active Law Enforcement, DOD, or U.S. Intelligence Agencies. This document, or any segment/attachment thereof, may
not be released without the approval of the Bureau of Prisons to any media sources, any non-law enforcement entity, the general
public or those without a "need to know." It contains information that may be exempt from public release under the provisions of the
Privacy Act (5 U.S.C. 552).
2 of 3
EFTA00019355

=== Page 9 ===
Form 583 Report of Incident
Incident #: NYM-19-
Submitted By:
Date/Time Of Incident: 7/23/2019 1:27 AM
0076
Injury Category: No Injury
Staff Injury by Inmate: No
Sexual Assault: No
Section 4: Lethal Weapon Discharge
No data found.
Section 5: Use of Force
No data found.
Section 6: Description of Incident
DESCRIPTION OF INCIDENT (If Use Of Force, include details such as name of supervisor applying the chemical
agent and/or restraints, reasons for use of hard restraints instead of soft restraints, etc.) Please be clear about
cause(s) of the incident in your description.
On July 23, 2019 at approx. 1:27 a.m., a call for assistance on the Special Housing Unit was announced by the Control
Center. Upon my arrival I was informed that an inmate had attempted suicide and proceeded to cell, Z05-124LAD.
I
observed inmate Epstein, Jeffrey
lying in the fetal position on the floor of his cell wearing a t-shirt and boxers.
He was breathing heavily and was snoring. I called out to inmate Epstein and observed him flicker his eyes and continue
snoring. His neck was red with no abrasions. I observed no further injuries to his person. An attempt was made to get
the inmate to stand on his own with negative results. The inmate was placed in hand restraints and staff was directed to
retrieve the stretcher. As inmate Epstein was being placed on the stretcher by responding staff, he would open his eyes
and observe staff. When staff made eye contact with him, he would hurriedly shut his eyes. The inmate was taken to
HA-Unit, dressed in the suicide smock and placed on suicide watch.
Upon the arrival of medical staff, inmate Epstein was examined and treated by, MLP
for a circular line of
erythema at the base of the neck, one section on the front with marks of friction and a small erythema on his left knee.
Section 7: Attachments
File Date
File Name
Original Entered By
Original Loc.
Code
No data found.
Approved By: NOT COMPLETED
UNCLASSIFIED/LIMITED OFFICIAL USE ONLY/LAW ENFORCEMENT SENSITIVE
This document is marked Unclassified/Limited Official Use Only/Law Enforcement Sensitive and may be disseminated, with proper
attribution, to active Law Enforcement, DOD, or U.S. Intelligence Agencies. This document, or any segment/attachment thereof, may
not be released without the approval of the Bureau of Prisons to any media sources, any non-law enforcement entity, the general
public or those without a "need to know." It contains information that may be exempt from public release under the provisions of the
Privacy Act (5 U.S.C. 552).
3 of 3
EFTA00019356

=== Page 10 ===
UNITEL
TATES GOVERNMENT
DEPARTMENT OF JUSTICE
Memorandum
FEDERAL BUREAU OF PRISONS
FEDERAL BUREAU OF PRESENT
Metropolitan Correctional Center
150 Park Row
New York. New York 10007
July 23, 2019
MEMORANDUM FOR ALL CONCERNED
FROM:
Operations Lieutenant
SUBJECT:
Possible Suicide Attempt
On July 23, 2019 at approx. 1:27 a.m., a call for assistance on the Special Housing Unit
was announced by the Control Center. Upon my arrival I was informed that an inmate
had attempted suicide and proceeded to cell, Z05-124LAD. I observed inmate
Epstein, Jeffrey
lying in the fetal position on the floor of his cell wearing a
t-shirt and boxers. He was breathing heavily and was snoring. I called out to inmate
Epstein and observed him flicker his eyes and continue snoring. His neck was red
with no abrasions. I observed no further injuries to his person. An attempt was made
to get the inmate to stand on his own with negative results. The inmate was placed in
hand restraints and staff was directed to retrieve the stretcher. As inmate Epstein was
being placed on the stretcher by responding staff, he would open his eyes and observe
staff. When staff made eye contact with him, he would hurriedly shut his eyes. The
inmate was taken to HA-Unit, dressed in the suicide smock and placed on suicide
watch. While awaiting the arrival of an inmate companion, inmate Epstein sat on the
edge of the bed and began moving forward as if he was attempting to fall over head
first. When I looked away, he straightened up. As I turned to look at him again, he
attempted the same act. I laid him down on the bed and directed him to cease his
action or he would be placed in restraints for his safety. At that moment, he stated,
"Okay, I won't do it again," and gave the thumbs up. Because of his unpredictable
behavior, the decision was made to have a staff member observe inmate Epstein. I
left HA-Unit in order to make staff notifications. Moments later, I spoke with Officer
who stated that inmate Epstein was alert and had indicated that his cellmate,
Tartaglione, Nicholas
had attempted to kill him and had been harassing
him. He stated that the inmate had indicated that he'd informed his attorney of this
matter.
I photographed and spoke with inmate Tartaglione, Nicholas
who stated
that he was asleep with his headphones on when he felt something hit his legs and
said, "Jeff, what you're doing?" He didn't answer, so he got up, turned on the light and
saw him with a string around his neck. He stated that he then called the guards and
ASensitive Limited Official Use Only
EFTA00019357

=== Page 11 ===
СОЬЛ

=== Page 12 ===
they ran down. Upon furner questioning, inmate Tartaglione lated that he sleeps on
the bottom bunk, but gave it to inmate Epstein because he's old. He stated that he
sleeps on the floor on a mattress. He stated that when he got up, he couldn't
remember if he sat up or stood up to check on Epstein. He stated that Epstein was
sitting on the floor leaning to the side with his eyes opened, but wasn't responding. He
stated that the last time he saw him he was snoring really loud.
Inmate Epstein stated that he came in from a legal visit at approx. 8:00PM and staff
handed him a copy of the Daily News. "Nick" was on the floor reading the Daily News.
He stated that he had given it to him. He stated that Tartaglione mentioned that he'd
been in court all day in Westchester and was carrying on. At that point, inmate
Tartaglione paused as if he was making the story up as he went along, and stated that
Tartaglione stated, "These fucking niggers. This place is inhumane, I wish I could
report it.
), that nigger hobbit mother fucker." He then turned to a page in
the Daily News that had his picture on it and stated that Epstein was worth seventy
seven million dollars. Epstein stated that he took his picture, balled it up and threw it in
the garbage. I asked inmate Epstein what happened prior to staff's arrival. He stated
that at approx. 1:00 AM, he'd gotten up to get a drink of water, as he gets up every
thirty minutes. He remember walking back to his bunk and waking up with staff there
in his cell. I asked if he'd waken up and seen staff, why didn't he respond when we
were calling out to him? He stated that he only remembered hearing himself making a
noise like snoring. When asked about the allegations against his cellmate, he stated
that he was told, if he hurt him, staff wouldn't care.
Duty medical, Dr.
was notified and briefed. It was determined no further
medical attention was needed. A medical assessment was not conducted at the time
of this incident, due to the fact, there was no medical staff available after 10:00 PM.
Upon the arrival of medical staff, inmate Epstein was examined and treated by, MLP
for a circular line of erythema at the base of the neck, one section on the front
with marks of friction and a small erythema on his left knee.
COPY
1-23-14
ASensitive Limited Official Use Only
EFTA00019359

=== Page 13 ===
EFTA00019360

=== Page 14 ===
DEPARTMENT OF JUSTICE
UNITED STATES GOVERNMENT
TELENAN BUREAU OF
MEMORANDUM
Metropolitan Correctional Center, New York, New York
DATE: 07-23-2019
TO: Ops
FROM:
SUBJECT: Suicide Attempt Inmate
On the above date at approx. 1:27am While working in the Special Housing Unit Myself and S/O
heard noise coming from the M tier Cell 124. Upon arrival inmate Epstein's cell mate (I/m
Tartaglione
)
was at the door stating I/M Epstein
had attempted to hang himself.
I kept a visual while Officer
grabbed door keys and called for assistance. After securing I/M
Tartaglione and removing him from the cell, I entered then placed I/M Epstein on his side and removed
an orange homemade rope from his neck. I/M was breathing at this time, But unresponsive. As I began
chest compressions addition staff and Ops Lt
arrived, I/M was then removed from the Special
Housing Unit without further incident.
EFTA00019361

=== Page 15 ===
COB
EFTA00019362

=== Page 16 ===
BUREAU OF OF JUSTICE SPECIMEN
UNITED STATES GOVERNMENT
MEMORANDUM
Metropolitan Correctional Center, New York, New York
DATE: July 23, 2019
TO:
Operations Lieutenant, LT
FROM:
Senior Officer
SUBJECT: Inmate Epstein reg#
On July 23, 2019 at approximately 1:27 AM while assigned to the Special Housing Unit, myself and Senior Officer
Specialist
heard some noises coming from M Tier. Upon checking cell Z05-124 I observed inmate Epstein
reg#
laying down near his bunk with what appeared to be a piece of handmade orange cloth around his
neck. I immediately called Control Center for staff assistance. Officer
kept a visual of inmate Epstein while I
proceeded to retrieve the door keys and the cutter from the main cabinet located in the MPA. Officer
applied
restraints to his cell mate inmate Tartaglione reg#
I secured inmate Tartaglione inside the bathroom while
Officer
provided assistance to inmate Epstein. When additional staff arrived inmate Epstein was removed from
his cell without further incident.
COPY
1-3-19 19
EFTA00019363

=== Page 17 ===
EFTA00019364

=== Page 18 ===
UNITED STATES GOVERNMENT
MEMORANDUM
Metropolitan Correctional Center, New York, New York
July 23, 2019
TO:
FROM:
SUBJECT: Incident on 9 south
On July 23, 2019 at approximately 1:27, I, S.O.S
responded to a body alarm on the
Special Housing Unit. While the 9-South officer was conducted rounds inmate Epstein, Jeffrey
was found in his cell with
und his neck and appeared to be unresponsive.
I assisted with taking inmate Epstein
from his cell and putting him on a stretcher.
The inmate was taken to the second floor and placed on suicide watch, where he was monitored by
staff. Moments afterwards, inmate Epstein became responsive. While observing inmate Epstein
he sat up on the bed and began telling me that he think his Bunkie, Tartaglione, Nicholas
tried to kill him. Inmate Epstein also stated that his Bunkie also tried to extort
money from him and stated that if he didn't pay him that he would beat him up. He stated that
this has been going on for a week. I asked inmate Epstein if he told staff about this and he told
me no, that he'd only told his lawyer. He went on to say that his Bunkie told him that if he beat
him up, because of his charges, the officers would not report it and because of this he was not
comfortable telling the officers about the prolong threats and alleged attempts to extort him. I
immediately reported this to the lieutenant.
EFTA00019365

=== Page 19 ===
COBA
EFTA00019366

=== Page 20 ===
OF
REDUCAL DISARTMENTO BUREAU OF JUSTICE FRIGHT
UNITED STATES GOVERNMENT
MEMORANDUM
Metropolitan Correctional Center, New York, New York
DATE:
July 23, 2019
TO:
Operations Lieutenant
FROM:
Senior Officer
SUBJECT:
Epstein, Jeffrey IM#
At approximately 1:27AM, I responded to a radio transmission asking for staff assistance
on 9 South (Special Housing Unit). Once I was granted access to said unit I made my way to the
location (M Tier) in which the disturbance stemmed from. I was told by Officer W.
that
Epstein, Jeffrey I/M#
has attempted to hang himself. Upon arrival to cell number 124
in which he was housed, I noticed J. Epstein I/M#
on the floor and Officer J.
placing restraints on him. Officer D.
, Lt.
and I entered said cell attempting to
assist in said process.
Now that I am inside of the cell I notice that J. Epstein I/M#
was snoring on the
floor of his cell, he appeared to be asleep. We made several verbal commands for him to wake up
and attempted to get him to his feet but they were all unsuccessful. After said attempts Lt.
asked for a stretcher to be retrieve to safely remove him out of his cell. Once the
stretcher arrived, Officer D.
, Officer J.
and I lifted J. Epstein I/M#
off
the floor and placed him on the stretcher. Once we secured him safely on the stretcher, Officer D.
and I lifted J. Epstein I/M#
who is now on the stretcher safely out of 9 South
(Special Housing Unit) and into the awaiting elevator.
COPY
EFTA00019367

=== Page 21 ===
COGA
EFTA00019368

=== Page 22 ===
UNITEL TATES GOVERNMENT
DIPARTMENT OF JUSTICE
Memorandum
FEDERAL BUREAU OF PRISONS
FEDERAL BUREAU OF PRINT
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
July 23, 2019
MEMORANDUM FOR ALL CONCERNED
FROM:
, Material Handler Supervisor H.
SUBJECT:
Possible Suicide Attempt
On July 23, 2019 at approx. 1:27 a.m., the Control Center announced a call for
assistance on the Special Housing Unit. Upon my arrival to 9-South, I/M Epstein,
Jeffrey
was lying on the floor of his cell handcuffed. I assisted with
carrying inmate Epstein to HA-Unit on a stretcher, where he was dressed in a suicide
smock and placed on Suicide Watch observation with staff.
72319
COPY
ASensitive Limited Official Use Only
EFTA00019369

=== Page 23 ===
000
EFTA00019370

=== Page 24 ===
MCC NEW YORK
Tuesday July 23, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
6 07:00- 15:00
9 12:00- 20:00
Post
Split Shift 2 00:00 - 08:00
3 06:00 - 14:00
8 08:00 - 16:00
10 14:00 - 22:00
12 16:00- 00:00
CAPTAIN
CAPTAIN SEC
OPS LT
ACT LT
ADMIN LT
SHU LT
SIS LT
SIS LT #2
SIA
SIS TECH #1
SIS TECH #2
PHONE MONITOR
SEC OFFICER #1
SEC OFFICER #2
TOOL ROOM
SEARCH OFFICER
2 SALLY OFF
3 SALLY OFF
LOBBY
CONTROL #1
CONTROL #2
INTERNAL
INTERNAL #2
ATTY CONF
UNIT 2
UNIT 3
5 NORTH
5 SOUTH
7 NORTH
7 SOUTH
9 NORTH
SHU #1
SHU #2
SHU #3
SHU #4
10 SOUTH #1
10 SOUTH #2
7/23/2019 7:02:27 AM
EFTA00019371

=== Page 25 ===
CODA
EFTA00019372

=== Page 26 ===
Tuesday July 23, 2019
Page 2
REC OFFICER #1
REC OFFICER #2
11 NORTH
11 SOUTH
11 SOUTH #2
REAR GATE
OSP #1
SANITATION OFF
VISIT #1
VISIT #2
VISIT #3
****Special Assignments***
EPO OFFICE
ESCORT OFF #1
ESCORT OFF #2
LOBBY #2
9 <unassigned>
PHONE RM
TOWN DRIVER
SUICIDE WATCH
8 <unassigned>
12 <unassigned>
****Back Page Categories***
DAY OFF
SICK LEAVE
ANNUAL LEAVE
LWOP
LWOP(M)
AWOL
SUSPENSION
Akparanta, c$
OFFICIAL TIME
Covington, T
7/23/2019 7:02:34 AM
EFTA00019373

=== Page 27 ===
Tuesday July 23, 2019
Page 3
COP
IF TRAINING
*Change Records****
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft
Changed By
TOOL ROOM
6
KS 7/14 13:31
[Sick / Annual]
KS 7/14 13:52
CONTROL #2
3
KS 7/16 07:54
(sp)PHONE RM 2
8
KS 7/16 07:54
SHU #1
8
KS 7/16 09:22
INTERNAL
8
KS 7/16 09:29
INTERNAL
8
KS 7/16 12:07
UNIT 3
2
RW 7/17 15:58
OT/CT Start End
OT
ATTY CONF
8
RW 7/18 08:00
OT/CT Start End
OT
7 SOUTH
8
RW 7/18 10:11
OT/CT Start End
OT
SHU LT
10
KS 7/18 10:19
LWOP
KS 7/18 11:35
5 SOUTH
2
RW 7/18 12:10
OT/CT Start End
at
[Inserted NCS]
RW 7/19 10:19
INTERNAL
2
RW 7/19 10:19
10 SOUTH #2
10
RW 7/19 12:15
OT/CT Start End
oT
ACT LT
10
JD
7/21 14:10
OT/CT Start End
oT
SHU #2
2
RW 7/22 08:21
OT/CT Start End
oT
VISIT #2
9
RW 7/22 08:26
OT/CT Start End
oT
7/23/2019 7:02:35 AM
EFTA00019374

=== Page 28 ===
Tuesday July 23, 2019
Page 4
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft
Changed By
VISIT #2
9
RW 7/22 08:27
[Sick / Annual]
RW 7/22 08:27
7 NORTH
2
Y
RW 7/22 08:34
OT/CT Start End
OT
11 NORTH
2
Y
RW 7/22 08:45
OT/CT Start End
OT
(sp)PHONE RM 2
8
KS 7/22 09:05
SHU #1
2
Y
RW 7/22 09:20
OT/CT Start End
OT
[Inserted NCS]
RW 7/22 09:39
SHU #3
3
RW 7/22 09:39
SHU #4
8
Y
RW 7/22 10:04
OT/CT Start End
OT
SHU #1
8
RW 7/22 10:19
SHU #2
8
Y
RW 7/22 10:19
OT/CT Start End
oT
7 NORTH
2
Y
RW 7/22 10:43
[Sick / Annual]
y
RW 7/22 10:43
9 NORTH
8
Y
RW 7/22 11:04
OT/CT Start End
OT
11 NORTH
8
MR 7/22 14:34
5 NORTH
8
MR 7/22 14:37
INTERNAL #2
2
Y RW 7/22 14:45
OT/CT Start End
CT
7 NORTH
2
A
Y RW 7/22 14:58
OT/CT Start End
OT
VISIT #2
9 <
Y RW 7/22 15:26
OT/CT Start End
oT
5 NORTH
2 <
Y MR 7/22 18:12
OT/CT Start End
oT
7/23/2019 7:02:35 AM
EFTA00019375

=== Page 29 ===
Tuesday July 23, 2019
Page 5
Relieved Officer's
Relieving Officer's
Ret
Post
Splt Shft Officer
New Status
Relieving Officer
Previous Status
Shft
Changed By
11 SOUTH
2
Y
SJ 7/22 19:21
OT/CT Start End
OT
INTERNAL
12
SJ 7/22 19:22
SHU #2
2
SJ 7/22 21:14
[Sick / Annual]
SJ 7/22 21:14
SHU #2
2
Y
SJ 7/22 21:14
OT/CT Start End
OT
5 SOUTH
2
-
GA 7/22 22:08
[Sick / Annual]
-
GA 7/22 22:08
5 SOUTH
2
Y
GA 7/22 22:12
OT/CT Start End
OT
[Inserted NCS]
GA 7/23 04:30
(sp)Suicide Watch
2
GA 7/23 04:31
(sp)Suicide Watch
2
GA 7/23 04:31
OT/CT Start End
OT 01:30 08:00
INTERNAL
2
GA 7/23 04:32
QT/CT Start End
OT 00:00 01:30
11 SOUTH
8 F
GA 7/23 05:05
***Recapitulation*****
Morning Watch
8
AM Watch
7
Day Watch 23
PM Watch 6
Evening Watch 17
**Back Page Categories**
Sick Leave 4
Day Off 20
Annual Leave 7
LWOP 1
LWOP(M) 4
AWOL 9
SUSPENSION 1
OFFICIAL TIME 1
COP 2
IF TRAINING 3
Total Correctional Svcs. Staff: 113
Non Correctional Svcs. Staff: 2
Overtime Occurrences: 18
Comptime Occurrences: 1
Ops Lt. Evening Watch Signature:
Captain's Signature:
7/23/2019 7:02:36 AM
EFTA00019376

=== Page 30 ===
Bureau of Prisons
Health Services
Clinical Encounter
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #:
Date of Birth:
Sex:
M Race: WHITE
Facility: NYM
Encounter Date: 07/23/2019 06:20
Provider:
MLP
Unit:
H01
Injury Assessment - Non-work related encounter performed at Health Services.
SUBJECTIVE:
INJURY 1
Provider:
MLP
Date of Injury:
07/23/2019 01:27
Date Reported for Treatment:
07/23/2019 08:25
Work Related:
No
Work Assignment:
UNASSG
Pain Location:
Pain Scale: 0
Pain Qualities:
Where Did Injury Happen (Be specific as to location):
Special Housing Unit Z05-Cell 124 L
Cause of Injury (Inmate's Statement of how injury occurred):
"I do not know. Just went to drink a little water and wake up snorting".
COPY
Symptoms (as reported by inmate):
None
OBJECTIVE:
Temperature:
Date
Time
Fahrenheit
Celsius
Location
Provider
07/23/2019
06:30 NYM
97.5
36.4
Oral
MLP
Pulse:
Date
Time
Rate Per Minute
Location
Rhythm
Provider
07/23/2019 06:30
92
Via Machine
Regular
MLP
Respirations:
Date
Time
Rate Per Minute Provider
07/23/2019
06:30 NYM
16
MLP
Blood Pressure:
Date
Time
Value
Location
Position
Cuff Size
Provider
07/23/2019
06:30 NYM
140/85
Right Arm
Sitting
Adult-regular
MLP
SaO2:
Date
Time
Value(%) Air
Provider
07/23/2019
06:30 NYM
96 Room Air
MLP
Exam:
General
Affect
Yes: Cooperative
Appearance
Yes: Appears Well, Alert and Oriented X 3
No: Appears Distressed, Lethargic, Dyspneic, Appears in Pain, Pallor, Cyanotic, Diaphoretic, Disheveled,
Generated 07/23/2019 09:05 by
MLP
Bureau of Prisons - NYM
Page 1 of 2
EFTA00019377

=== Page 31 ===
СОЬЛ

=== Page 32 ===
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #:
Date of Birth:
Sex:
M Race: WHITE
Facility: NYM
Encounter Date: 07/23/2019 06:20
Provider:
MLP
Unit:
H01
Exam:
Acutely III
Pulmonary
Auscultation
Yes: Clear to Auscultation, Vesicular Breath Sounds Bilaterally
No: Crackles, Rhonchi, Wheezing
Exam Comments
Inmate for injury report as requested by Operational Lt.
He is ambulatory, oriented X 3. In not apparent distress, smiling during this clinical encounter. Alleges, that he does not
know what happened. Can not explain the marks on his neck. Responded: "I don't know".
He does not want to talk of the events leading to the marks on his neck.
He does not look in any distress or pain.
Has an circular line of erythema at the base of the neck. Reaching 2/3 of the neck circumference, 2 inches wide, sparing
the back of the neck. Has one section of this erythema in the front with marks of friction.
No inflammation, no deformities, no hematomas, no lacerations, no tenderness. Patient moving his neck without any
restriction. Denies having any pain or discomfort. Denies any respiratory problem.
Has another small erythema on left knee about 2cm in diameter(mild).
As per information from custody staff inmate Epstein was found in his cell with a rope around his neck and sitting on the
floor.
Inmate is currently placed on suicide watch.
ASSESSMENT:
Injury, unspecified, T1490 - Current - R/O self inflicted injuries.
PLAN:
Disposition:
Follow-up at Sick Call as Needed
Placed on Suicide Watch
Follow-up in 2-4 Hours
Other:
For follow up with psychology service.
Patient Education Topics:
Date Initiated Format
Handout/Topic
Provider
Outcome
07/23/2019 Counseling
Access to Care
Verbalizes
Understanding
07/23/2019 Counseling
Plan of Care
Verbalizes
Understanding
Copay Required: No
Cosign Required: Yes
Telephone/Verbal Order: No
COPY
Completed by
MLP on 07/23/2019 09:05
Requested to be cosigned by
MD.
Cosign documentation will be displayed on the following page.
Generated 07/23/2019 09:05 by
MLP
Bureau of Prisons NYM
Page 2 of 2
EFTA00019379

=== Page 33 ===
OF WORKING OMA ino PRISONS SEQUITUR OF DEPARTUTION
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
7-23-19
EFTA00019380

=== Page 34 ===
OF STICE * SNOSIBA UNLINO35 ous FEDER PRO DOMINA WILLING
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
EFTA00019381

=== Page 35 ===
OM4 ino PRISONS* SEQUITUR OF DISNEY DEPARTMENT
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
EFTA00019382

=== Page 36 ===
AMOUNT OUR PRO DOMINA JUSTITIA OF F JUSTICE PRINONS
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 - -1:45 AM
COPY
bLEZ-L
EFTA00019383

=== Page 37 ===
OF WING Our FEDERAL IND SEQUITUR PRISONS* OF
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 - -1:45 AM
COPY
7-23-19
EFTA00019384

=== Page 38 ===
STATEST FEDER DUE DOMINA JUSTITIA OF F JUSTICE PRINONS
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
7-23-19
EFTA00019385

=== Page 39 ===
SHIPPING ORd FEDER no SEQUITUR PRISONS* OF DEPARTMENT
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
EFTA00019386

=== Page 40 ===
SHINGS One FEDELA IND SEQUITUR PRISONS * OF DEPARTMENT
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
7-23-19
EFTA00019387

=== Page 41 ===
THINGS ORd FEDERAL FEEDER no SEQUITUR PRISONS* OF DEPARTMENT
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
COPY
EFTA00019388

=== Page 42 ===
OF OH# PEPERAL ino SEQUITUR PRISONS* AFFISTA OF REPARTMENT
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
COPY
7-23-19
EFTA00019389

=== Page 43 ===
OF FIVE OFF FEED ino SEQUITUR PRISONS* DISTR OF DEPARTMENT
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas
Location of Incident
Special Housing Unit
Photograph(s) by
2, , Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
COPY
7-23-4
EFTA00019390

=== Page 44 ===
OF WISHINGS ORd FEDERAL no SEQUITUR PRISONS* OF DEPARTMENT
BU
REAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
COPY
EFTA00019391

=== Page 45 ===
TEDERAL 100 OF SOMINA BUREAU OF JUSTITIA OF F JUSTICE SECURITY
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
12379
COPY
EFTA00019392

=== Page 46 ===
PAINTICE OF * SNOSIBI WOLLINGS OUI FEDERAL PRO
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas #78514-
Location of Incident
Special Housing Unit
Photograph(s) by
1, Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
COPY
EFTA00019393

=== Page 47 ===
BP-A0308
ADMINISTRATIVE DETENTION ORDER
U.S. DEPARTMENT OF JUSTICE
JAN 17
FEDERAL BUREAU OF PRISONS
NEWYORK MCC
Institution
Date/Time: 07-10-2019
TO: Special Housing Unit Officer
FROM:
LIEUTENANT
, (Name/Title)
SUBJECT : Placement of
EPSTEIN, JEFFERY
Reg. No.
7-10-2019
, in Administrative Detention
(a) Is pending an investigation for a violation of Bureau regulations;
(b) Is pending an SIS investigation.
(c) Is pending investigation or trial for a criminal act;
(d) Is to be admitted to Administrative Detention
(1) Since the inmate has requested admission for protection;
I hereby request placement in Administrative Detentionfor my own protection.
Inmate Signature/Register No.:
Staff Witness Printed Name Signature:
(2) Since a serious threat exists to individual's safety as perceived by staff, although person has not requested admission; referral of
the necessary information will be forwarded for an appropriate hearing by the SRO.
(e)
Is pending transfer or is in holdover status during transfer.
(f)
Is pending classification; or
(g)
Is terminating confinement in Disciplinary Segregation and has been ordered into Administrative Detention by the Warden's
designee.
It is this Correctional Supervisor's decision based on all the circumstances that the above named inmate's continued presence in the general
population poses a serious threat to life, property, self, staff, other inmates. or to the security or orderly running of the institution because*
PENDING CLASSIFICATION
Therefore, the above named inmate is to be placed in Administrative Detention until further notice. The inmate received a copy of this Order on
(date/time)
7-10-19
StaffWitness Signature/Printed Name
m
Date 2-10-19
Supervisor 24 hour review of placement: Signature/Printed name
co
. In the case of DHO action, reference to that order is sufficient. In other cases, the Correctional supervisor will make an independent review and decision, which is
documented here.
Record Copy . Inmate Concerned (not necessary if placement is a result of holdover status): Copy - Captain; Copy - Unit Manager; Copy - Operation Supervisor
- Administrative Detention Unit; Copy - Psychology: Copy - Central File
COPY
PDF
Prescribed by P5270
(Replaces BP-A0308 of JAN 88.)
7-23-9
EFTA00019394

=== Page 48 ===
A0208
INCIDENT REPORT
N.17
J.S. DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF PRISONS
Part I - Incident Report
1. Institution:
MCC New York
Incident Report Number:
2. Inmate's Name:
3. Register Number:
4. Date of Incident:
63282555 5. Time:
Epstein Jeffery
07/23/2019
1:27am
6. Place of Incident:
7. Assignment:
8. Unit:
SHU M-Tier Cell 124
Unassigned
ZA
9.
Incident:
Self-Mutilation
10. Prohibited Act Code (s):
228
11. Description of Incident (Date: 07/23/2019
Time:
1:27AM
Staff became aware of incident):
On July 23,2019 at approx. 1:27am While working in the Special Housing Unit Myself and S/O
heard noise coming from the M tier cell Upon
arrival I/M's Epstein,
cell mate (I/M
was at the door stating I/M Epstein
had attempted to
hang himself. I kept a visual while S/O grabbed the door keys and called for assistance. After Securing I/M
and removing
him from the cell,I entered then placed I/M Epstein on his side and removed a orange homemade rope from his neck.I/M was breathing at this time
But unresponsive. Addition staff and Ops Lt
arrived I/M was then removed from SHU
12. Typed Name/Signature of Reporting Employee:
13. Date And Time:
J
07/23/2019 3:30am
14. Incident Report Delivered to Above Inmate By
15. Date Incident Report Delivered:
16. Time Incident Report Delivered:
(Type Name/Signature):
Part II - Committee Action
17. Comments of Inmate to Committee Regarding Above Incident:
18. A. It is the finding of the committee that you:
B.
The Committee is referring the Charge(s) to the DHO for further
Hearing
Committed the Prohibited Act as charged:
C.
The Committee advised the inmate of its finding and of the right
Did not Commit a Prohibited Act.
to file an appeal within 20 calendar days.
Committed Prohibited Act Code (s).
19. Committee Decision is Based on Specific Evidence as Follows:
20. Committee action and/or recommendation if referred to DHO (Contingent upon DHO finding inmate committed prohibited act):
21. Date and Time of Action:
accurately reflects the UDC proceedings).
(The UDC Chairman=s signature certifies who sat on the UDC and that the completed report
Chairman (Typed Name/Signature):
Member (Typed Name):
Member (Typed Name):
INSTRUCTIONS: All items outside of heavy rule are for staff use only. Begin entries with the number 1 and work up. Entries not completed will be
voided by staff.
COPY
Distribute: Original-Central File Record; COPY-1-DHO: COPY-2-Inmate after UDC Action: COPY 3-Inmate within 24 hours of Part I Preparation
PDF
Prescribed by P5270
Replaces BP-A0288 of AUG 11
EFTA00019395

=== Page 49 ===
Part III - Investigation
22. Date And Time Investigation Began
23. Inmate Advised Of Right To Remain Silent: You are advised of your right to remain silent at all
stages of the discipline process. Your silence may be used to draw an adverse inference against you
at any stage of the discipline process. Your silence alone may not be used to support a finding
that you have committed a prohibited act.
The Inmate Was Advised Of The Above Right By
At (Date/time)
24. Inmate statement and attitude
25. Other facts about the incident, statements of those persons present at scene, disposition of
evidence, etc.
26. Investigator's comments and conclusions
27. Action taken
Date and Time Investigation Completed
Printed Name/Signature Of Investigator
Title
COPY
bheil
PDF
Prescribed by P5270
Replaces BP-S288.052 Of MAY 94
EFTA00019396

=== Page 50 ===
Cop-Out 78514-054 TARTAglioNe
/ Legal Call in light of Event w Epstcia on
7-23-19
EFTA00019397

=== Page 51 ===
Bureau of Prisons
Health Services
Clinical Encounter
Inmate Name: TARTAGLIONE, NICHOLAS JOHN
Reg #: 78514-054
Date of Birth: 10/10/1967
Sex:
M Race: WHITE
Facility: NYM
Encounter Date: 07/31/2019 14:11
Provider:
PA-C
Unit:
Z06
Mid Level Provider - Evaluation encounter performed at Special Housing Unit.
SUBJECTIVE:
COMPLAINT 1
Provider:
PA-C
Chief Complaint: No Complaint(s)
Subjective: "I feel good today, can't complain. My anxiety is getting better and I have no side effect from
the new anxiety medication"
IM being seen in the SHU as per the request of lieutenants.
States he's been doing well and has no acute complaints.
For what happened to his previous cell mate about a week ago, states "I have no ideal what
was going on. I didn't do anything and I have no injury"
Pain:
No
OBJECTIVE:
Pulse:
Date
Time
Rate Per Minute
Location
Rhythm
Provider
07/31/2019 14:19
71
Via Machine
PA-C
Respirations:
Date
Time
Rate Per Minute Provider
07/31/2019
14:19 NYM
15
PA-C
Blood Pressure:
Date
Time
Value
Location
Position
Cuff Size
Provider
07/31/2019
14:19 NYM
118/70
Left Arm
Sitting
Adult-regular
PA-C
SaO2:
Date
Time
Value(%) Air
Provider
07/31/2019
14:19 NYM
98 Room Air
PA-C
Exam Comments
General: AAOx3. NAD
HEENT: PERRLA. EOMI. Nares patent.
Neck: Supple
Heart: S1, S2. RRR
Lungs: CTAB
EXT: No edema.
Neuro: Grossly normal CN II-XII
ASSESSMENT:
Encounter for general adult medical exam without abnormal findings, Z0000 Current
PLAN:
Disposition:
Follow-up at Sick Call as Needed
couply Page 1 of 2
Other:
Generated 07/31/2019 14:39 by
PA-C
Bureau of Prisons - NYM
EFTA00019398

=== Page 52 ===
EFTA0001
СОБА

=== Page 53 ===
Inmate Name: TARTAGLIONE CHOLAS JOHN
Reg #:
Date of Birth: 10/10/1967
Sex:
M Race: WHITE
Facility: NYM
Encounter Date: 07/31/2019 14:11
Provider:
PA-C
Unit:
Z06
IM states he feels as himself and denies being in acute distress.
Patient Education Topics:
Date Initiated Format
Handout/Topic
Provider
Outcome
07/31/2019 Counseling
Access to Care
Verbalizes
Understanding
Copay Required: No
Cosign Required: Yes
Telephone/Verbal Order: No
Completed by
PA-C on 07/31/2019 14:39
Requested to be cosigned by
MD.
Cosign documentation will be displayed on the following page.
COPY
sile
Generated 07/31/2019 14:39 by
PA-C
Bureau of Prisons - NYM
Page 2 of 2
EFTA00019400


c1: EFTA00018169
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018169.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: JE
Date: Thu, 11 Jul 2019 00:49:59 +0000
Importance: Normal
just called - FBI reached out to NYPD leadership already and they were told that SVU has been directed
to stand down and that all Epstein stuff needs to go to and through us. DANY could still try to go forward with
their own investigators, so I think it is worth a call over.
Sent from my iPhone
> On Jul 10, 2019, at 8:47 PM,
wrote:
>
> Also, as
has pointed out, DANY is presumably working with NYPD. But NYPD through the task force is
working with us, and even stood up to announce the charges with us. So we may also want to conduct outreach
that way.
>
>
Sent from my iPhone
>
On Jul 10, 2019, at 8:25 PM,
wrote:
Sorry - interviews lined up for Friday, not tomorrow.
Here's another fire: DANY is proceeding with their investigation and already reached out to nbc news victim
to arrange an interview. I'm not sure what the point is given both their double jeopardy and SOL issues. Let's
discuss outreach to them.
Sent from my iPhone
On Jul 10, 2019, at 8:18 PM,
wrote:
This is fine with me if they can be nimble. For example, the agents and
are in Florida as we
speak. Agents are doing approaches and interviews lined up for tomorrow - we cannot let the bureaucracy stand
in the way, have to delay things etc. I suppose we go with it for now and see if that becomes a concern.
Sent from my iPhone
On Jul 10, 2019, at 8:10 PM, Berman, Geoffrey (USANYS)
wrote:
I spoke to Sweeney. We will be going forward with the compromise. CFI in the room but interview
conducted by AUSA and agent. There will be a strategy session with CFI before each interview and any
suggestions from CFI will be incorporated by us in the interview to the extent we can. If CFI feels they have to
interject during the interview they can or they may talk to us outside of the room. We, of course, will be
solicitous of CFI. They are the experts. Does this work for everyone? Geoff
EFTA00018169


c1: EFTA00019729
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019729.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
FD-1087 (Rev. 5-8-10)
Document
signed
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Search Warrant Executed at 9
Date: 07/16/2019
East 71st Street, New York, New York
10021
Approved By: SSA
Drafted By:
Case ID #: 31E-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Collected From:
(U) 9 East 71st Street
New York, New York 10021
United States
Receipt Given?: Yes
Holding Office: NEW YORK
Details:
A search warrant, issued in the United States District Court for the
Southern District of New York on 07/11/2019, was executed at 9 East 71st
Street, New York, New York 10021 at approximately 2:35pm on 07/11/2019.
Item Type
Description
1B Digital
(U) Silver Apple Desktop Computer with keyboard and
mouse
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 1
Seizing Individual:
Collected By:
Location Area: Room B
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00019729

=== Page 2 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Specific Location: On desk
Device Type: Computer
Make: Apple
Serial Number: D25LGQSKF8JC
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
UNCLASSIFIED
2
EFTA00019730

=== Page 3 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
UNCLASSIFIED
3
EFTA00019731

=== Page 4 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Path/100 Hard Drives
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 2
Seizing Individual:
Collected By:
Location Area: Room B
Specific Location: Inside bookshelf cabinets
Device Type: Hard Drive
Make: Seagate Path
Number of Devices Collected: 1
1B Digital
(U) 1 Data Traveler 4GB USB's
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 3
Seizing Individual:
Collected By:
Location Area: Room A
Specific Location: Desk/Work Station
Device Type: USB Micro Storage Device (thumb drive)
Number of Devices Collected: 1
1B Digital
(U) 1 Data Traveler 4GB USB's
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 3
Seizing Individual:
Collected By:
UNCLASSIFIED
4
EFTA00019732

=== Page 5 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Location Area: Room A
Specific Location: Desk/Work Station
Device Type: USB Micro Storage Device (thumb drive)
Number of Devices Collected: 1
1B Digital
(U) 1 Mentor Media 32GB USB's
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 3
Seizing Individual:
Collected By:
Location Area: Room A
Specific Location: Desk/Work Station
Device Type: USB Micro Storage Device (thumb drive)
Number of Devices Collected: 1
1B Digital
(U) 1 HP Compaq Machine
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 4
Seizing Individual:
Collected By:
Location Area: Room A
Specific Location: Desk/Work Station
Device Type: Computer
Make: HQ Compaq
Number of Devices Collected: 1
1B Digital
(U) 1 Cube 9000 Siteserver
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 4
Seizing Individual:
Collected By:
Location Area: Room A
Specific Location: Desk/Work Station
Device Type: Other
Other Device Type: SiteServer
Number of Devices Collected: 1
1B Digital
(U) 1 DELL Machine
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 5
UNCLASSIFIED
5
EFTA00019733

=== Page 6 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Seizing Individual:
Collected By:
Location Area: Room A
Specific Location: Desk/Work Station
Device Type: Computer
Make: Dell
Model: EQ9S
Number of Devices Collected: 1
1B Digital
(U) 1 Silicone Power Micro SD Adapter with 16GB SD Card
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 6
Seizing Individual:
Collected By:
Location Area: Room F
Specific Location: Drawer inside photo table
Device Type: SD Card/Flash Drive
Number of Devices Collected: 2
1B Digital
(U) 10 assorted cd's
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 7
Seizing Individual:
Collected By:
Location Area: Room F
Specific Location: Drawer inside photo table
Device Type: Compact Disc/Digital Video Disc (CDs/DVDs)
Number of Devices Collected: 10
1B Digital
(U) 1 EMTEC 16 GB USB
Collected On: 07/11/2019 04:28 PM EDT
Receipt Number: 8
Seizing Individual:
Collected By:
Location Area: Room F
Specific Location: small tray on floor
Device Type: USB Micro Storage Device (thumb drive)
Make: EMTEC
Data Capacity: 16 GB
Number of Devices Collected: 1
UNCLASSIFIED
6
EFTA00019734

=== Page 7 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
1B Digital
(U) 1 Blue EMTEC 16 GB USB
Collected On: 07/11/2019 04:28 PM EDT
Receipt Number: 8
Seizing Individual:
Collected By:
Location Area: Room F
Specific Location: small tray on floor
Device Type: USB Micro Storage Device (thumb drive)
Make: EMTEC
Data Capacity: 16 GB
Number of Devices Collected: 1
1B Digital
(U) 1 Cruzer Guide 32GB USB
Collected On: 07/11/2019 04:28 PM EDT
Receipt Number: 9
Seizing Individual:
Collected By:
Location Area: Room H
Specific Location: cabinet back wall
Device Type: USB Micro Storage Device (thumb drive)
Make: Cruzer
Data Capacity: 32 GB
Number of Devices Collected: 1
1B Digital
(U) 1 Cruzer Guide 32GB USB
Collected On: 07/11/2019 04:28 PM EDT
Receipt Number: 9
Seizing Individual:
Collected By:
Location Area: Room H
Specific Location: cabinet back wall
Device Type: USB Micro Storage Device (thumb drive)
Make: Cruzer
Data Capacity: 32 GB
Number of Devices Collected: 1
1B Digital
(U) 1 Cruzer Guide 32GB USB
Collected On: 07/11/2019 04:28 PM EDT
Receipt Number: 9
UNCLASSIFIED
7
EFTA00019735

=== Page 8 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Seizing Individual:
Collected By:
Location Area: Room H
Specific Location: cabinet back wall
Device Type: USB Micro Storage Device (thumb drive)
Make: Cruzer
Data Capacity: 32 GB
Number of Devices Collected: 1
1B Digital
(U) 1 Cruzer Guide 32GB USB
Collected On: 07/11/2019 04:28 PM EDT
Receipt Number: 9
Seizing Individual:
Collected By:
Location Area: Room H
Specific Location: cabinet back wall
Device Type: USB Micro Storage Device (thumb drive)
Make: Cruzer
Data Capacity: 32 GB
Number of Devices Collected: 1
1B Digital
(U) 1 SPIEF 2014 Silver USB
Collected On: 07/11/2019 04:28 PM EDT
Receipt Number: 9
Seizing Individual:
Collected By:
Location Area: Room H
Specific Location: cabinet back wall
Device Type: USB Micro Storage Device (thumb drive)
Make: Spief
Number of Devices Collected: 1
1B Digital
(U) 1 Apple Desktop Computer with keyboard and mouse
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 10
Seizing Individual:
Other Locator:
Location Area: Room FF
Specific Location: On top of desk
Device Type: Computer
UNCLASSIFIED
8
EFTA00019736

=== Page 9 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Make: Apple
Serial Number: D25RC0RBGG7F
Number of Devices Collected: 1
1B Digital
(U) 1 Apple Desktop Computer with keyboard and mouse
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 11
Seizing Individual:
Collected By:
Location Area: Room 0
Specific Location: On top of desk
Device Type: Computer
Make: Apple
Serial Number: C0ZNM1LXFY14
Number of Devices Collected: 1
1B Digital
(U) 1 White Apple IPhone 5 64GB
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 12
Seizing Individual:
Collected By:
Location Area: Room FF
Specific Location: White/wood cabinet, lower left shelf
Device Type: Cell Phone
Make: Apple
Model: Iphone 5 - 64GB
Serial Number: NPJK0W1F38Y
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Backup Plus Portable Drive - 1TB
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 13
Seizing Individual:
Other Locator:
Location Area: Room FF
Specific Location: In shoebox on top of desk
Device Type: Portable Hard Drive
Make: Seagate
Model: Backup Plus
UNCLASSIFIED
9
EFTA00019737

=== Page 10 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Number of Devices Collected: 1
1B Digital
(U) 1 Gray Apple Desktop Computer with keyboard and
mouse
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 14
Seizing Individual:
Other Locator:
Location Area: Room II
Specific Location: On desk
Device Type: Computer
Make: Apple
Serial Number: C02VW0UVHX8F
Number of Devices Collected: 1
1B Digital
(U) 1 Sony Camera with black case
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 15
Seizing Individual:
Other Locator:
Location Area: Room II
Specific Location: kitchen drawer
Device Type: Digital Camera/Digital Video Camera
Make: Sony
Serial Number: C02VW0UVHX8F
Number of Devices Collected: 1
1B Digital
(U) 1 MSI PC Computer
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 16
Seizing Individual:
Other Locator:
Location Area: Room NN
Specific Location: Storage Area/Room
Device Type: Computer
Make: MSI
Serial Number: MSB01G8S0103317
Number of Devices Collected: 1
1B Digital
(U) 1 Seagate Barracuda 7200 harddrive 80GB
UNCLASSIFIED
10
EFTA00019738

=== Page 11 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 17
Seizing Individual:
Other Locator:
Location Area: Room NN
Specific Location: Storage Area/Room
Device Type: Hard Drive
Make: Seagate
Model: Barracuda
Data Capacity: 80GB
Number of Devices Collected: 1
1B Digital
(U) 1 Dell Precision Tower 5810
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 18
Seizing Individual:
Other Locator:
Location Area: Room NN
Specific Location: Storage Area/Room
Device Type: Other
Other Device Type: Tower 8510
Make: Dell
Model: Precision
Serial Number: C5KDGB2
Number of Devices Collected: 1
1B Digital
(U) 1 Sony Vaio Laptop
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 19
Seizing Individual:
Other Locator:
Location Area: Room 0
Specific Location: Desk Drawer Right
Device Type: Laptop/Tablet Computer
Make: Sony
Model: Vaio
Serial Number: 3000001
Number of Devices Collected: 1
1B Digital
(U) 45 Assorted Cd's
UNCLASSIFIED
11
EFTA00019739

=== Page 12 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 20
Seizing Individual:
Collected By:
Location Area: Room GG
Specific Location: Center closet organzier
Device Type: Compact Disc/Digital Video Disc (CDs/DVDs)
Number of Devices Collected: 45
1B Digital
(U) 1 Sony BM-560 Recorder
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 21
Seizing Individual:
Collected By:
Location Area: Room V
Specific Location: Top of right nightstand
Device Type: Digital Audio Tape/Digital Video Tape
Make: Sony
Number of Devices Collected: 1
1B Digital
(U) 1 Silver Olympus recorder
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 22
Seizing Individual:
Collected By:
Location Area: Room V
Specific Location: In nightstand drawer
Device Type: Digital Audio Tape/Digital Video Tape
Make: Olympus
Number of Devices Collected: 1
1B Digital
(U) 1 Black Radioshack recorder
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 22
Seizing Individual:
Collected By:
Location Area: Room V
Specific Location: In nightstand drawer
Device Type: Digital Audio Tape/Digital Video Tape
Make: Radioshack
UNCLASSIFIED
12
EFTA00019740

=== Page 13 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
Number of Devices Collected: 1
1B Digital
(U) 1 Space Gray Apple IPAD
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 23
Seizing Individual:
Collected By:
Location Area: Room U
Specific Location: under sink
Device Type: Laptop/Tablet Computer
Make: Apple
Model: IPAD
Serial Number: DMQTX2BEHLF9
Number of Devices Collected: 1
1B Digital
(U) 1 Space Gray Apple IPAD
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 23
Seizing Individual:
Collected By:
Location Area: Room U
Specific Location: under sink
Device Type: Laptop/Tablet Computer
Make: Apple
Model: IPAD
Serial Number: GCTV4YOUHLF9
Number of Devices Collected: 1
1B Digital
(U) 1 Silver IPAD - 64GB
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 24
Seizing Individual:
Collected By:
Location Area: Room Y
Specific Location: shelf in right corner under TV
Device Type: Laptop/Tablet Computer
Make: Apple - 64GB
Model: IPAD
Serial Number: DMPHFHG0DVGN
Number of Devices Collected: 1
UNCLASSIFIED
13
EFTA00019741

=== Page 14 ===
UNCLASSIFIED
Title: (U) Search Warrant Executed at 9 East 71st Street, New York, New
York 10021
Re: 31E-NY-3027571, 07/16/2019
1B Digital
(U) 1 Apple Desktop computer
Collected On: 07/11/2019 07:28 PM EDT
Receipt Number: 25
Seizing Individual:
Collected By:
Location Area: Room A
Specific Location: cardboard box along right wall
Device Type: Computer
Make: Apple
Serial Number: QP0230XS5RV
Number of Devices Collected: 1
UNCLASSIFIED
14
EFTA00019742


c1: EFTA00020176
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020176.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
"
Subject: RE: Epstein (FinCEN records)
Date: Fri, 16 Aug 2019 05:47:54 +0000
Great, received -- thanks very much.
Original Message
From:
Sent: Thursday, August 15, 2019 08:27
To:
Cc:
Subject: RE: Epstein (FinCEN records)
Original Message
From:
Sent: Tuesday, August 13, 2019 2:59 PM
To:
Cc:
i
Subject: RE: Epstein (FinCEN records)
,
Following up on the below - -- could you please circulate?
thanks,
Original Message
From:
Sent: Wednesday, August 07, 2019 15:00
To:
Cc:
Subject: RE: Epstein (FinCEN records)
,
Will do.
Thanks
EFTA00020176

=== Page 2 ===
Original Message
From:
Sent: Tuesday, August 06, 2019 5:43 PM
To:
Cc:
Subject: FW: Epstein (FinCEN records)
,
Could you please pull the FinCEN records listed below and circulate to the team? It sounds like they're
potentially useful so we'd like to review. Thank you!
Original Message
From:
Sent: Tuesday, August 06, 2019 11:53
To:
Cc:
Subject: RE: Epstein
,
We wanted to make sure you all were aware of several records. See below - a list of relevant document IDs that
will allow you to pull the records up in FinCEN Query or cross-reference with your files. Please let me know if
you have any issues.
BSA IDs:
Thanks,
Original Message
From:
Sent: Monday, August 5, 2019 9:45 AM
To:
;
Cc:
Subject: RE: Epstein
EFTA00020177

=== Page 3 ===
Sorry I was inartful. Yes, my understanding is that we have information to send your way.
can confirm that.
Assistant Chief Counsel
Financial Crimes Enforcement Network
This e-mail message and any attachments from the United States Department of the Treasury/Financial Crimes
Enforcement Network is for the exclusive use of the intended recipient and may contain privileged information,
including information protected by the attorney-client and attorney work product privileges. If you are not an
intended recipient, please do not read, distribute, or take action in reliance on this message. If you have received
this message in error, please notify the sender immediately by return e-mail and promptly delete this message
and its attachments from your computer system. Be advised that no privilege is waived by the transmission of
this message.
Original Message
From:
Sent: Monday, August 5, 2019 9:43 AM
To:
Cc:
Subject: [EXTERNAL] RE: Epstein
Hi
,
I had the impression from
email that you had particular documents or reports you were looking to
send our way ("so you can coordinate with them to make sure they have already seen any SAR information you
guys are looking at") -- if so, we would be grateful for you to send whatever it is you think would be useful. Or
please let us know if that's not correct (when
says "the relevant SAR information" I'm not sure what
that's referring to), and if so what it was you were envisioning.
thanks,
Original Message
From:
Sent: Monday, August 05, 2019 09:18
To:
Cc:
Subject: RE: Epstein
We just want to ensure you have the relevant SAR information you need. To that end, I'm copying
of
our Intelligence Division, with whom you can liaise directly if necessary.
Best,
EFTA00020178

=== Page 4 ===
Assistant Chief Counsel
Financial Crimes Enforcement Network
This e-mail message and any attachments from the United States Department of the Treasury/Financial Crimes
Enforcement Network is for the exclusive use of the intended recipient and may contain privileged information,
including information protected by the attorney-client and attorney work product privileges. If you are not an
intended recipient, please do not read, distribute, or take action in reliance on this message. If you have received
this message in error, please notify the sender immediately by return e-mail and promptly delete this message
and its attachments from your computer system. Be advised that no privilege is waived by the transmission of
this message.
Original Message
From:
Sent: Sunday, August 4, 2019 7:44 PM
To:
Cc:
Subject: [EXTERNAL] RE: Epstein
,
Thanks for reaching out, and let us know how we can best proceed.
thanks again,
Original Message
From:
Sent: Friday, August 02, 2019 20:17
To:
Cc:
Subject: Re: Epstein
Thanks so much for the introduction,
I'll have the folks on my end reach out to confirm the status of this.
Thanks again and nice weekend to all.
From: "Wilson, Alexander (USANYS) 3"
<mailto:
Date: Friday, August 2, 2019 at 7:00:36 PM
To:
<mailto:
EFTA00020179

=== Page 5 ===
Cc:
Subject: [EXTERNAL] Epstein
,
As discussed, I'm cc'ing a couple of the AUSAs on the Epstein team so you can coordinate with them to make
sure they have already seen any SAR information you guys are looking at, or pass it over if they haven't.
Guys,
is with FinCEN counsel (formerly the Office's best friend at OIA), and has some information
FinCEN has seen and wants to make sure we're aware of.
Thanks,
Co-Chief, Money Laundering and Transnational Criminal Enterprises Unit
Asset Forfeiture Coordinator
United States Attorney's Office
Southern District of New York
Tel:
EFTA00020180


c1: EFTA00020261
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020261.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 1 of 34
USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT
ELECTRONICALLY FILED
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 4/16/21
United States of America,
-V-
20-cr-330 (AJN)
Ghislaine Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell
with facilitating the late financier Jeffrey Epstein's sexual abuse of minor victims from around
1994 to 1997. The Government filed a first (S1) superseding indictment shortly thereafter,
which contained only small, ministerial corrections. The S1 superseding indictment included
two counts of enticement or transportation of minors to engage in illegal sex acts in violation of
the Mann Act and two counts of conspiracy to commit those offenses. It also included two
counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to
begin on July 12, 2021.
Maxwell filed twelve pretrial motions seeking to dismiss portions of the S1 superseding
indictment, suppress evidence, and compel discovery. After the parties fully briefed those
motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking
count and another related conspiracy count.
This Opinion resolves all of Maxwell's currently pending pretrial motions other than
those seeking to suppress evidence, which the Court will resolve in due course. The motions, and
this Opinion, deal exclusively with the S1 superseding indictment and do not resolve any issues
EFTA00020261

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 2 of 34
related to the newly added sex trafficking charges. For the reasons that follow, the Court denies
Maxwell's motions to dismiss the S1 superseding indictment in whole or in part. It grants her
motion to sever the perjury charges for a separate trial. It denies her motion to further expedite
discovery.
The Court provides a brief summary of its conclusions here and its reasoning on the
pages that follow:
Maxwell moves to dismiss all counts based on a non-prosecution agreement between
Jeffrey Epstein and the U.S. Attorney for the Southern District of Florida. The Court
concludes that the agreement does not apply in this District or to the charged offenses.
Maxwell moves to dismiss all counts as untimely. The Court concludes that the
Government brought the charges within the statute of limitations and did not unfairly
delay in bringing them.
Maxwell moves to dismiss the Mann Act counts because they are too vague, or in the
alternative to require the Government to describe the charges in greater detail. The
Court concludes that the charges are specific enough.
Maxwell moves to dismiss the perjury counts because, in her view, her testimony
responded to ambiguous questioning and was not material. The Court concludes that
these issues are best left for the jury.
Maxwell moves to sever the perjury counts from the Mann Act counts so that they can
proceed in a separate trial. The Court concludes that severance is appropriate and will
try the perjury counts separately.
Maxwell moves to strike language from the indictment that she believes is superfluous
and to dismiss conspiracy counts she believes are redundant. The Court concludes that
these motions are premature before trial.
Maxwell moves to compel the Government to immediately disclose certain categories
of evidence. The Court concludes that she is not entitled to do so, but the Court will
order Maxwell and the Government to confer on a discovery schedule.
Maxwell moves to dismiss all counts because a grand jury in White Plains, rather than
Manhattan, returned the S1 superseding indictment. Because a jury in Manhattan
returned the S2 superseding indictment, the motion appears moot.
2
EFTA00020262

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 3 of 34
I.
Jeffrey Epstein's non-prosecution agreement does not bar this prosecution
In September 2007, under investigation by both federal and state authorities, Jeffrey
Epstein entered into a non-prosecution agreement ("NPA") with the Office of the United States
Attorney for the Southern District of Florida. Dkt. No. 142 at 1-2. Epstein agreed in the NPA to
plead guilty in Florida state court to soliciting minors for prostitution and to serve eighteen
months in a county jail. Id. In exchange, the U.S. Attorney's Office agreed not to charge him
with federal crimes in the Southern District of Florida stemming from its investigation of his
conduct between 2001 and 2007. Id. It also agreed not to bring criminal charges against any of
his "potential co-conspirators." Id.
As a recent report from the Department of Justice's Office of Professional Responsibility
observed, the NPA was unusual in many respects, including its breadth, leniency, and secrecy.
OPR Report, Gov. Ex. 3, Dkt. No. 204-3, at X, 80, 175, 179, 260-61. The U.S. Attorney's
promise not to prosecute unidentified co-conspirators marks a stark departure from normal
practice for federal plea agreements. This provision appears to have been added "with little
discussion or consideration by the prosecutors." Id. at 169, 185. The report concluded that the
U.S. Attorney's negotiation and approval of the NPA did not amount to professional misconduct,
but nonetheless reflected "poor judgment." Id. at 169.
Only the NPA's effect, and not its wisdom, is presently before the Court. Maxwell
contends that the NPA bars this prosecution, because she is charged as a co-conspirator of
Jeffrey Epstein and the NPA's co-conspirator provision lacks any geographical or temporal
limitations. The Court disagrees for two independent reasons. First, under controlling Second
Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of New
York. Second, it does not cover the offenses charged in the S1 superseding indictment.
3
EFTA00020263

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 4 of 34
A. The non-prosecution agreement does not bind the U.S. Attorney for the
Southern District of New York
United States Attorneys speak for the United States. When a U.S. Attorney makes a
promise as part of a plea bargain, both contract principles and due process require the federal
government to fulfill it. See Santobello V. New York, 404 U.S. 257, 262 (1971); United States V.
Ready, 82 F.3d 551, 558 (2d Cir. 1996). The question here is not whether the U.S. Attorney for
the Southern District of Florida had the power to bind the U.S. Attorney for the Southern District
of New York. The question is whether the terms of the NPA did so. Applying Second Circuit
precedent and principles of contract interpretation, the Court concludes that they did not.
In United States V. Annabi, the Second Circuit held: "A plea agreement binds only the
office of the United States Attorney for the district in which the plea is entered unless it
affirmatively appears that the agreement contemplates a broader restriction." 771 F.2d 670, 672
(2d Cir. 1985) (per curiam). This is something akin to a clear statement rule. Single-district plea
agreements are the norm. Nationwide, unlimited agreements are the rare exception. Applying
Annabi, panels of the Second Circuit have stated that courts cannot infer intent to depart from
this ordinary practice from an agreement's use of phrases like "the government" or "the United
States." United States V. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States V.
Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea
agreement need not painstakingly spell out "the Office of the United States Attorney for Such-
and-Such District" in every instance to make clear that it applies only in the district where
signed.
Maxwell asks this Court to draw the opposite conclusion. The provision of the NPA
dealing with co-conspirators does not expressly state that it binds U.S. Attorneys in other
districts. It does not expressly state that it applies in other districts. The relevant language, in
4
EFTA00020264

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 5 of 34
its entirety, reads as follows: "the United States also agrees that it will not institute any criminal
charges against any potential co-conspirators of Epstein." Dkt. No. 142-1 at 5. Under Annabi,
Salameh, and Gonzalez, a statement that "the United States" agrees not to prosecute implies no
restriction on prosecutions in other districts.
Two provisions of the NPA refer specifically to prosecution in the Southern District of
Florida. The first states that the U.S. Attorney for the Southern District of Florida will defer
"prosecution in this District" if Epstein complies with the agreement. Dkt. No. 142-1 at 2. The
second states that no prosecution "will be instituted in this District, and the charges against
Epstein if any, will be dismissed" after he fulfills the agreement's conditions. Maxwell contends
that the lack of similar language in the co-conspirator provision must mean that it lacks any
geographical limitation. If anything, that language reflects that the NPA's scope was expressly
limited to the Southern District of Florida. It is not plausible-let alone "affirmatively
apparent", Annabi, 771 F.2d at 672,-that the parties intended to drastically expand the
agreement's geographic scope in the single sentence on the prosecution of co-conspirators
without clearly so saying.
Without an affirmative statement in the NPA's text, Maxwell turns to its negotiation
history. Under Second Circuit precedent she may offer evidence that negotiations of the NPA
between the defendant and the prosecutors included a promise to bind other districts. See United
States V. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S.
Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA
from the Office of the Deputy Attorney General and communicated with attorneys in other
districts. Any involvement of attorneys outside the Southern District of Florida appears to have
been minimal. Maxwell has already received access to an unusually large amount of information
5
EFTA00020265

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 6 of 34
about the NPA's negotiation history in the form of the OPR report and yet identifies no evidence
that the Department of Justice made any promises not contained in the NPA. The OPR report
reflects that the Office of the Deputy Attorney General reviewed the NPA, but only after it was
signed when Epstein tried to get out of it. OPR Report at 103. Other documents show that
attorneys in the Southern District of Florida reached out to other districts for investigatory
assistance but not for help negotiating the NPA. Dkt. No. 204-2. Nor would direct approval of
the NPA by the Office of the Deputy Attorney General change the meaning of its terms. No
evidence suggests anyone promised Epstein that the NPA would bar the prosecution of his co-
conspirators in other districts. Absent such a promise, it does not matter who did or did not
approve it.
Second Circuit precedent creates a strong presumption that a plea agreement binds only
the U.S. Attorney's office for the district where it was signed. Maxwell identifies nothing in the
NPA's text or negotiation history to disturb this presumption. The Court thus concludes that the
NPA does not bind the U.S. Attorney for the Southern District of New York.
B. The non-prosecution agreement does not cover the charged offenses
The NPA would provide Maxwell no defense to the charges in the S1 superseding
indictment even against an office bound to follow it. The NPA bars prosecution, following
Epstein's fulfillment of its conditions, only for three specific categories of offenses:
(1) "the offenses set out on pages 1 and 2" of the NPA; namely, "any offenses that
may have been committed by Epstein against the United States from in or around
2001 through in or around September 2007" including five enumerated offenses;
(2) "any other offenses that have been the subject of the joint investigation by the
Federal Bureau of Investigation and the United States Attorney's Office"; and
(3) "any offenses that arose from the Federal Grand Jury investigation."
6
EFTA00020266

=== Page 7 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 7 of 34
Dkt. No. 142-1 at 2. The NPA makes clear that the covered charges are those relating to
and deriving from a specific investigation of conduct that occurred between 2001 and 2007.
Maxwell contends that the NPA's co-conspirator provision lacks any limitation on the
offenses covered. The Court disagrees with this improbable interpretation. The phrase
"potential co-conspirator" means nothing without answering the question "co-conspirator in
what?" The most natural reading of the co-conspirator provision is that it covers those who
conspired with Epstein in the offenses covered by the NPA for their involvement in those
offenses. Thus, it would cover any involvement of Maxwell in offenses committed by Epstein
from 2001 to 2007, other offenses that were the subject of the FBI and U.S. Attorney's Office
investigation, and any offenses that arose from the related grand jury investigation.
The Court has no trouble concluding that the perjury counts are not covered by the NPA.
Those charges do not relate to conduct in which Maxwell conspired with Epstein and stem from
depositions in 2016, more than eight years after Epstein signed the NPA. Maxwell now
concedes as much, though her motion sought to dismiss the S1 superseding indictment in its
entirety, perjury counts and all.
The Mann Act counts, too, fall comfortably outside the NPA's scope. The S1
superseding indictment charges conduct occurring exclusively between 1994 and 1997, some
four years before the period covered by the Southern District of Florida investigation and the
NPA. The NPA does not purport to immunize Epstein from liability for crimes committed
before the period that was the subject of the FBI and U.S. Attorney's Office investigation.
Maxwell's protection is no broader. The Court thus concludes that the NPA does not cover the
offenses charged in the S1 superseding indictment.
7
EFTA00020267

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 8 of 34
C. Maxwell is not entitled to an evidentiary hearing
In the alternative to dismissing the indictment, Maxwell requests that the Court conduct
an evidentiary hearing as to the parties' intent in the NPA. The Court finds no basis to do so.
The cases Maxwell cites where courts held hearings on the scope of a plea agreement
mostly involved oral agreements where there was no written record of the full set of terms
reached by the parties. All of them involved defendants with first-hand knowledge of
negotiations who claimed prosecutors breached an oral promise. "An oral agreement greatly
increases the potential for disputes such as
a failure to agree on the existence, let alone the
terms, of the deal." United States V. Aleman, 286 F.3d 86, 90 (2d Cir. 2002). Thus, an
evidentiary hearing may be necessary to determine the terms of an agreement never committed to
writing. This is no such case. The NPA's terms are clear. Beyond the NPA itself, an extensive
OPR report details its negotiation history. No record evidence suggests that prosecutors
promised Epstein anything beyond what was spelled out in writing. The Court agrees with the
Government that Maxwell's request for a hearing rests on mere conjecture.
For the same reason, the Court will not order the discovery on the NPA. In any case, it
appears that the Government has already produced two of the documents Maxwell seeks in her
motion-the OPR report and notes mentioned in a privilege log. Of course, the Government's
disclosure obligations would require it to disclose to Maxwell any exculpatory evidence or
evidence material to preparing the defense, including any evidence supporting a defense under
the NPA. The Government shall confirm in writing within one week whether it views any
evidence supporting Maxwell's interpretation of the NPA as material it is required to disclose,
and, if so, whether it has disclosed any and all such evidence in its possession.
8
EFTA00020268

=== Page 9 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 9 of 34
II.
The indictment is timely
A. The indictment complies with the statute of limitations
Federal law imposes a five-year limitations period for most non-capital offenses. 18
U.S.C. § 3282(a). Recognizing the difficulty of promptly prosecuting crimes against children,
Congress has provided a longer limitations period for "offense[s] involving the sexual or
physical abuse, or kidnaping" of a minor. 18 U.S.C. $ 3283. Until 2003, the operative version
of § 3283 allowed prosecution of these offenses until the victim reached the age of twenty-five.
Congress further extended the limitations period in the PROTECT Act of 2003, Pub. L. No. 108-
21, 117 Stat. 650, to allow prosecution any time during the life of the victim.
The parties agree that the Mann Act charges are timely if subject to the PROTECT Act,
but untimely under the general statute of limitations for non-capital offenses or the pre-2003
version of § 3283. Maxwell contends that the charged offenses do not qualify as offenses
involving the sexual or physical abuse or kidnapping of a minor and are thus governed by the
general statute of limitations. Alternatively, she contends that the pre-2003 version of § 3283
applies because the charged conduct occurred prior to 2003. The Court concludes that statute of
limitations in the PROTECT Act applies and that the charges are timely.
1. The Mann Act charges are offenses involving the sexual abuse of minors
Maxwell does not dispute that the facts alleged in the S1 superseding indictment involve
the sexual abuse of minors. The indictment charges that Epstein sexually abused each of the
alleged minor victims and that Maxwell allegedly enticed them to travel or transported them for
that purpose. Instead, Maxwell contends that charged offenses do not qualify as offenses
involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each
statutory offense. See Bridges V. United States, 346 U.S. 209, 221 (1953). In Maxwell's view,
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for example, it is possible to transport a minor with intent to engage in criminal sexual activity
and not follow through with the planned sexual abuse, and so sexual abuse is not an essential
ingredient of the offense. Maxwell makes the same argument for the enticement and related
conspiracy charges.
This approach is analogous to the "categorical approach" employed by courts to evaluate
prior convictions for immigration and sentencing purposes. See Taylor V. United States, 495
U.S. 575, 602 (1990). Generally speaking, the "categorical approach" requires that courts "look
only to the statutory definitions-i.e., the elements" of the relevant offense to determine if the
provision applies "and not to the particular facts underlying those convictions." Descamps V.
United States, 570 U.S. 254, 261 (2013) (internal quotation marks omitted). Whether a statute
requires a categorical or case-specific approach is a question of statutory interpretation. To
determine whether Congress used the word "offense" in a statute to refer to an offense in the
abstract or to the facts of each individual case, the Court must examine the statute's "text,
context, and history." United States V. Davis, 139 S. Ct. 2319, 2327 (2019).
Though it has not authoritatively settled the question, the Second Circuit has strongly
suggested that Maxwell's approach is the wrong one. In Weingarten V. United States, 865 F.3d
48, 58-60 (2d Cir. 2017), the Second Circuit discussed at length how the text, context, and
history of § 3283 show that Congress intended courts to apply the statute using a case-specific
approach. The Third Circuit reached the same conclusion in United States V. Schneider, 801
F.3d 186, 196 (3d Cir. 2015).
The Court sees no reason to depart from the reasoning in Weingarten. First, "[t]he
Supreme Court's modern categorical approach jurisprudence is confined to the post-conviction
contexts of criminal sentencing and immigration deportation cases." Weingarten, 865 F.3d at 58.
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To the extent that the categorical approach is ever appropriate in other contexts, it is
inappropriate here.
The Court begins with the statute's text. Statutes that call for application of the
categorical approach typically deal with the elements of an offense in a prior criminal conviction.
Id. at 59. "The language of $ 3283, by contrast, reaches beyond the offense and its legal
elements to the conduct 'involv[ed]' in the offense. That linguistic expansion indicates Congress
intended courts to look beyond the bare legal charges in deciding whether § 3283 applied." Id. at
59-60 (alteration in original) (quoting $ 3283). Maxwell cites one case holding otherwise, but
that case involved a venue statute presenting significantly different concerns. See United States
V. Morgan, 393 F.3d 192, 200 (D.C. Cir. 2004). The Supreme Court has likewise held that a
statute which uses the language "an offense that involves fraud or deceit in which the loss to
the victim or victims exceeds $10,000" is "consistent with a circumstance-specific approach."
Nijhawan V. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves"
generally means that courts should look to the circumstances of an offense as committed in each
case. This reading accords with a robust legislative history indicating that Congress intended to
apply $ 3283 to a wide range of crimes against children. See Weingarten, 865 F.3d at 60;
Schneider, 801 F.3d at 196.
The purposes underlying the categorical approach do not apply here either. For statutes
dealing with prior convictions, "[t]he categorical approach serves 'practical' purposes: It
promotes judicial and administrative efficiency by precluding the relitigation of past convictions
in minitrials conducted long after the fact." Moncrieffe V. Holder, 569 U.S. 184, 200-01 (2013).
In the context of § 3283, there is no prior conviction to assess, and the jury will determine in the
first instance whether "the defendant engaged in the applicable abusive conduct." Weingarten,
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865 F.3d at 60. Maxwell nonetheless contends that using a case-specific approach for § 3283
would be impractical because the Government would need to prove conduct beyond the elements
of the offense. It may be true that this approach requires the Government to prove some
additional facts, but any statute-of-limitations defense presents factual issues (including, at least,
when the alleged conduct took place). This is not a serious practical problem and does not
justify setting aside the statute's language and apparent purpose.
Maxwell relies primarily on Bridges V. United States, 346 U.S. 209 (1953), to urge this
Court to cast Weingarten aside. The Supreme Court in Bridges addressed a statute that extended
the limitations period for defrauding the United States during the Second World War. In that
case, the Supreme Court first concluded that making false statements at an immigration hearing
was not subject to the extended limitations period because it lacked any pecuniary element as
required by the statute. Id. at 221. Then, as an alternative basis for its holding, it explained that
the offense did not require fraud as an "essential ingredient." Id. at 222. It reached that
conclusion in large part because the statute's legislative history made clear that Congress
intended it to apply only to a narrow class of war frauds causing pecuniary loss. Id. at 216.
As the Second Circuit explained in Weingarten, Congress had the opposite intent in the
enacting in the PROTECT Act. Weingarten, 865 F.3d at 59 & n. 10. "In passing recent statutes
related to child sex abuse, including extensions of the § 3283 limitations period, Congress
'evinced a general intention to "cast a wide net to ensnare as many offenses against children as
possible." Id. at 60 (quoting Schneider, 801 F.3d at 196 (quoting United States V. Dodge, 597
F.3d 1347, 1355 (11th Cir. 2010) (en banc))). The primary basis for Bridges' holding-
legislative history supporting a narrow interpretation-does not exist here. Instead, both the
statute's plan meaning and its legislative history suggest it should apply more broadly.
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Based on the statute's text, context, and history, the Court follows Weingarten and
concludes that the appropriate inquiry is whether the charged offenses involved the sexual abuse
of a minor on the facts alleged in this case. There is no question that they did. The Court thus
concludes that § 3283 governs the limitations period for the charges here.
2. The 2003 amendment to the statute of limitations applies to these offenses
Maxwell next contends that because the charged conduct took place before the
PROTECT Act's enactment, that statute did not lengthen the statute of limitations applicable to
her alleged offenses. Here too, the Second Circuit has provided guidance in its decision in
Weingarten. Although the court did not provide a definitive answer there, it explained that the
view Maxwell now takes conflicts with established principles of retroactivity and the decisions
of at least two other circuit courts. Weingarten, 865 F.3d at 58 & n.8; see Cruz V. Maypa, 773
F.3d 138, 145 (4th Cir. 2014); United States V. Leo Sure Chief, 438 F.3d 920, 924 (9th Cir.
2006).
The Supreme Court has set out a two-step framework to determine whether a federal
statute applies to past conduct. See Landgraf V. USI Film Products, 511 U.S. 244, 280 (1994).
Courts look first to the language of the statute. If the statute states that it applies to past conduct,
courts must so apply it. Weingarten, 865 F.3d at 54. Otherwise, the statute applies to past
conduct unless doing so would create impermissible retroactive effects. Id.
The Court begins with Landgraf's first step. To assess a statute's meaning here, courts
must consider the text of the statute along with other indicia of congressional intent, including
the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. V. Enter.
Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004).
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Section 3283, as amended by the PROTECT Act, broadly states that "[n]o statute of
limitations that would otherwise preclude prosecution for an offense involving the sexual or
physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution
during the life of the child." The statute lacks an express retroactivity clause, but courts have
held that no such clause is necessary, including for this particular statute. See Leo Sure Chief,
438 F.3d at 923. The statute's plain language unambiguously requires that it apply to
prosecutions for offenses committed before the date of enactment. Instead of simply providing a
new limitations period for future conduct, Congress stated that no statute of limitations that
would otherwise preclude prosecution of these offenses will apply. That is, it prevents the
application of any statute of limitations that would otherwise apply to past conduct.
Courts have reached the same conclusion for other statutes employing similar language.
The Eighth Circuit has held that the 1994 amendments to § 3283, which allowed prosecution of
sex crimes against children until the victim reached age twenty-five, applied to past conduct. See
United States V. Jeffries, 405 F.3d 682, 684-85 (8th Cir. 2005). The Second Circuit has observed
that the Higher Education Technical Amendments of 1991, Pub. L. No. 102-26, 105 Stat. 123,
illustrates language that requires a statute's application to past conduct. See Enter. Mortg.
Acceptance Co., LLC, Sec. Litig., 391 F.3d at 407. That statute eliminated the statute of
limitations for claims on defaulted student loans by stating that "no limitation shall terminate the
period within which suit may be filed." Id. The PROTECT Act's language is quite similar.
The history of § 3283 confirms Congress's intent to apply the extended limitations period
as broadly as the Constitution allows. With each successive amendment to the statute, Congress
further extended the limitations period, recognizing that sex crimes against children "may be
difficult to detect quickly" because children often delay or decline to report sexual abuse.
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Weingarten, 865 F.3d at 54. Congress enacted the limitations provision of the PROTECT Act
because it found the prior statute of limitations was "inadequate in many cases." H.R. Conf.
Rep. No. 108-63, at 54 (2003). For example, a person who abducted and raped a child could not
be prosecuted beyond this extended limit-even if DNA matching conclusively identified him as
the perpetrator one day after the victim turned 25." Id.
Maxwell makes no argument based on the statute's text. Instead, she contends that
because the House version of the bill included an express retroactivity provision absent from its
final form, the Court should infer that Congress did not intend the statute to apply to past
conduct. However, the legislative history makes clear that Congress abandoned the retroactivity
provision in the House bill only because it would have produced unconstitutional results. The
Supreme Court has explained that a law that revives a time-barred prosecution violates the Ex
Post Facto Clause of the Constitution, but a law that extends an un-expired statute of limitations
does not. Stogner V. California, 539 U.S. 607, 632-33 (2003). Senator Leahy, who co-
sponsored the PROTECT Act, expressed concerns in a committee report that the proposed
retroactivity provision was "of doubtful constitutionality" because it "would have revived the
government's authority to prosecute crimes that were previously time-barred." 149 Cong. Rec.
S5137, S5147 (Apr. 10, 2003) (statement of Sen. Leahy). Congress removed the provision
shortly thereafter for this reason. The removal of the express retroactivity provision shows only
that Congress intended to limit the PROTECT Act to its constitutional applications, including
past conduct-like Maxwell's-on which the statute of limitations had not yet expired.
Both the text and history of the PROTECT Act's amendment to $ 3283 reflect that it
applies Maxwell's conduct charged in the S1 superseding indictment. The Court could stop here.
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However, it also concludes that even if the statute were ambiguous, it would properly apply to
these charges.
At Lanfgraf's second step, the Court asks whether application of the statute to past
conduct would have impermissible retroactive effects. "[A] statute has presumptively
impermissible retroactive effects when it 'takes away or impairs vested rights acquired under
existing laws, or creates a new obligation, imposes a new duty, or attaches a new disability, in
respect to transactions or considerations already past." Weingarten, 865 F.3d at 56 (quoting
Landgraf, 511 U.S. at 290). Thus, applying a new statute of limitations to previously time-
barred claims has an impermissible retroactive effect. Enter. Mortg. Acceptance Co., LLC, Sec.
Litig., 391 F.3d at 407. Applying it to conduct for which the statute of limitations has not yet
expired does not. Vernon V. Cassadaga Valley Cent. Sch. Dist., 49 F.3d 886, 890 (2d Cir. 1995).
Maxwell concedes that these offenses were within the statute of limitations when
Congress enacted the PROTECT Act. Thus, the Act did not deprive her of any vested rights.
Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that
occurred more than twenty years ago, but there is no dispute that Congress has the power to set a
lengthy limitations period or no limitations period at all. It has done so here, judging that the
difficulty of prosecuting these offenses and the harm they work on children outweighs a
defendant's interest in repose. Maxwell's fairness argument is a gripe with Congress's policy
judgment, not an impermissibly retroactive application of the statute. The Court concludes that
§ 3283 allows her prosecution now.
B. The Government's delay in bringing charges did not violate due process
"As the Supreme Court stated in United States V. Marion, the statute of limitations is 'the
primary guarantee against bringing overly stale criminal charges." United States V. Cornielle,
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171 F.3d 748, 751 (2d Cir. 1999) (cleaned up) (quoting United States V. Marion, 404 U.S. 307,
322 (1971)). There is a strong presumption that an indictment filed within the statute of
limitations is valid. To prevail on a claim that pre-indictment delay violates due process, a
defendant must show both that the Government intentionally delayed bringing charges for an
improper purpose and that the delay seriously damaged the defendant's ability defend against the
charges. See id. This is a stringent standard. "Thus, while the [Supreme] Court may not have
shut the door firmly on a contention that at some point the Due Process Clause forecloses
prosecution of a claim because it is too old, at most the door is barely ajar." DeMichele V.
Greenburgh Cent. Sch. Dist. No. 7, 167 F.3d 784, 790-91 (2d Cir. 1999).
The Court sees no evidence that the Government's delay in bringing these charges was
designed to thwart Maxwell's ability to prepare a defense. However, it is enough to say that
Maxwell does not make the strong showing of prejudice required to support this sort of claim.
Maxwell contends that the Government's delay in bringing charges has prejudiced her interests
because potential witnesses have died, others have forgotten, and records have been lost or
destroyed. It is highly speculative that any of these factors would make a substantial difference
in her case.
Maxwell first points to several potential witnesses who have passed away. These include
Jeffrey Epstein and his mother, one individual Maxwell believes worked with one of the alleged
victims in this case, and a police detective who investigated Epstein in Florida. She contends
they all would have provided exculpatory testimony were they alive today. Courts have
generally found that vague assertions that a deceased witness might have provided favorable
testimony do not justify dismissing an indictment for delay. See, e.g., United States V. Scala, 388
F. Supp. 2d 396, 399-400 (S.D.N.Y. 2005). The Court agrees with this approach. Maxwell
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provides no indication of what many of these potential witnesses might have testified to. The
testimony she suggests the detective might have offered-that witnesses in the Palm Beach
investigation did not identify Maxwell by name-is propensity evidence that does nothing to
establish her innocence of the charged offenses. There are also serious doubts under all of the
relevant circumstances that a jury would have found testimony from Epstein credible even if he
had waived his right against self-incrimination and testified on her behalf. See United States V.
Spears, 159 F.3d 1081, 1085 (7th Cir. 1999).
Maxwell's arguments that the indictment should be dismissed because of the possibility
of missing witnesses, failing memories, or lost records fail for similar reasons. These are
difficulties that arise in any case where there is extended delay in bringing a prosecution, and
they do not justify dismissing an indictment. United States V. Marion, 404 U.S. 307, 325-26
(1971); see United States V. Elsbery, 602 F.2d 1054, 1059 (2d Cir. 1979).
Finally, the Court finds no substantial prejudice from the pretrial publicity this case has
garnered. Maxwell contends that lengthy public interest in this case has transformed her
reputation from that of Epstein's friend to a co-conspirator. And she also alleges-without
evidence-that her accusers fabricated their stories based on media allegations. The Court will
not dismiss the indictment on Maxwell's bare assertion that numerous witnesses are engaged in a
perjurious conspiracy against her. And the Court will take all appropriate steps to ensure that the
pretrial publicity in this case does not compromise Maxwell's right to a fair and impartial jury.
The Court thus concludes that Maxwell has failed to establish actual prejudice from the
Government's delay in bringing charges. She may renew her motion if the factual record at trial
shows otherwise. On the present record, neither the applicable statute of limitations nor due
process bars the charges here.
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III.
The indictment describes the charged offenses with specificity
Maxwell seeks to dismiss the Mann Act counts for lack of specificity or in the alternative
to compel the Government to submit a bill of particulars providing greater detail of the charges.
The Court concludes that the charges in the S1 superseding indictment are clear enough.
Under Federal Rule of Criminal Procedure 7, an indictment must contain "a plain,
concise, and definite written statement of the essential facts constituting the offense charged."
The indictment must be specific enough to inform the defendant of the charges and allow the
defendant to plead double jeopardy in a later prosecution based on the same events. United
States V. Stavroulakis, 952 F.2d 686, 693 (2d Cir. 1992). "Under this test, an indictment need do
little more than to track the language of the statute charged and state the time and place (in
approximate terms) of the alleged crime." United States. V. Tramunti, 513 F.2d 1087, 1113 (2d
Cir. 1975). In addition to dismissal, "Rule 7(f) of the Federal Rules of Criminal Procedure
permits a defendant to seek a bill of particulars in order to identify with sufficient particularity
the nature of the charge pending against him, thereby enabling defendant to prepare for trial, to
prevent surprise, and to interpose a plea of double jeopardy should he be prosecuted a second
time for the same offense." United States V. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987).
The S1 superseding indictment sets out the elements of each charged crime and the facts
supporting each element. Nonetheless, Maxwell contends that the indictment is too vague
because it refers to open-ended time periods, describes conduct like "grooming" and
"befriending" that is not inherently criminal, and does not identify the alleged victims by name.
Maxwell's first argument fails because the Government need only describe the time and
place of charged conduct "in approximate terms." Tramunti, 513 F.2d at 1113. The details are
subject to proof at trial. "[T]he Second Circuit routinely upholds the 'on or about' language used
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to describe the window of when a violation occurred." United States V. Kidd, 386 F. Supp. 3d
364, 369 (S.D.N.Y. 2019) (quoting United States V. Nersesian, 824 F.2d 1294, 1323 (2d Cir.
1987)). "This is especially true in cases of sexual abuse of children: allegations of sexual abuse
of underage victims often proceed without specific dates of the offenses." United States V.
Young, No. 08-cr-285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (collecting
cases). As here, these cases frequently involve alleged abuse spanning a lengthy period of time,
and witnesses who were victimized as children may struggle to recall the precise dates when
abuse occurred. The indictment adequately describes the time and place of the charged conduct.
Maxwell next contends that allegations of noncriminal conduct render the charges
impermissibly vague. The Court disagrees. Rule 7 requires only that the language of the
indictment track the language of the statute and provide a rough account of the time and place of
the crime. Tramunti, 513 F.2d at 1113. The language of the S1 superseding indictment does so.
The Government's decision to provide more details than those strictly required does not hamper
Maxwell's ability to prepare a defense. Maxwell's argument that some of the conduct alleged is
not inherently criminal goes to the merits of the Government's case, not the specificity of the
charges.
Finally, Maxwell argues that the indictment is vague because the government does not
provide the names of the alleged victims. The Court sees no basis to require that the alleged
victims' names be included the indictment. The names of victims, even if important, generally
need not appear there unless their omission would seriously prejudice the defendant. See United
States V. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States V. Kidd, 386 F. Supp. 3d 364,
369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged victims described in the
indictment at this point because the Government has provided extensive discovery on them.
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Moreover, the Government has agreed to disclose their names in advance of trial. There is thus
no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require
the parties to negotiate and propose a full schedule for all remaining pretrial disclosures.
IV.
The perjury charges are legally tenable
The Court turns next to Maxwell's motion to dismiss the perjury counts stemming from
her answers to questions in a deposition in a civil case. She contends that these charges are
legally deficient because the questions posed were fundamentally ambiguous and the questions
were not material to the subject of the deposition. The Court concludes that the charges are
legally tenable and Maxwell's defenses are appropriately left to the jury.
The applicable perjury statute imposes criminal penalties on anyone who "in any
proceeding before or ancillary to any court
knowingly makes any false material declaration."
18 U.S.C. $ 1623(a). Testimony is perjurious only if it is knowingly false and is material to the
proceeding in which the defendant offered it.
A. The questions posed were not too ambiguous to support a perjury charge
The requirement of knowing falsity requires that a witness believe that their testimony is
false. United States V. Lighte, 782 F.2d 367, 372 (2d Cir. 1986). As a general matter, "[a] jury is
best equipped to determine the meaning that a defendant assigns to a specific question." Id.
Courts have acknowledged a narrow exception for questions that are so fundamentally
ambiguous or imprecise that the answer to them cannot legally be false. Id. at 372, 375; see also
United States V. Wolfson, 437 F.2d 862, 878 (2d Cir. 1970). A question is fundamentally
ambiguous only if reasonable people could not agree on its meaning in context. Lighte, 782 F.2d
at 375. The existence of some arguable ambiguity does not foreclose a perjury charge against a
witness who understood the question.
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At a minimum, Maxwell's motion is premature. Courts typically evaluate whether a
question was fundamentally ambiguous only after the development of a full factual record at
trial. See, e.g., United States V. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992). The evidence at
trial may shed further light on whether the questions posed were objectively ambiguous in
context or whether Maxwell subjectively understood them. In any event, the Court has closely
considered each of the categories of questions that Maxwell argues are ambiguous. None of the
alleged ambiguities Maxwell identifies rise to the level supporting dismissal of the charges. The
context of the questions and answers, in conjunction with the Government's evidence, could lead
a reasonable juror to conclude that the statements were perjurious. Truth and falsity are
questions for the jury in all but the most extreme cases. The Court declines to usurp the jury's
role on the limited pretrial record.
B. A reasonable juror could conclude that Maxwell's statements were material
Maxwell also argues that the perjury counts should be dismissed because none of the
allegedly false statements were material to the defamation action. In a civil deposition, a
statement is material if it has a natural tendency to influence the court or if a truthful answer
might reasonably lead to the discovery of admissible evidence. United States V. Gaudin, 515
U.S. 506, 509 (1995); United States V. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing
falsity, materiality is an element of the offense and thus ordinarily must be "decided by the jury,
not the court." Johnson V. United States, 520 U.S. 461, 465 (1997). Only the most extraordinary
circumstances justify departure from this general rule. United States V. Forde, 740 F. Supp. 2d
406, 412 (S.D.N.Y. 2010) (citing Gaudin, 515 U.S. at 522-23).
The charged statements do not fall within this narrow exception. Maxwell contends that
the questions did not relate to the sex trafficking and sexual abuse allegations at the center of the
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civil case, but that is not the legal standard. The Government may prevail if it proves that
Maxwell's answers could have led to the discovery of other evidence or could influence the
factfinder in the civil case. See Gaudin, 515 U.S. at 509; Kross, 14 F.3d at 753-54. At trial, a
reasonable juror could conclude that truthful answers to the questions may have permitted the
plaintiff to locate other victims or witnesses who could have corroborated the plaintiff's
testimony. The factual disputes relating to materiality are at least enough to preclude pretrial
resolution. In criminal cases, courts must guard against "invading the 'inviolable function of the
jury' in our criminal justice system," and if the "defense raises a factual dispute that is
inextricably intertwined with a defendant's potential culpability, a judge cannot resolve that
dispute on a Rule 12(b) motion." United States V. Sampson, 898 F.3d 270, 281 (2d Cir. 2018).
The Court concludes that the perjury charges are legally tenable and appropriately
presented to the jury.
V.
The perjury charges must be severed and tried separately
Although the perjury charges are legally tenable, the Court concludes that the interests of
justice require severing those counts and trying them separately. Trying the perjury counts
together with the Mann Act counts would require admitting evidence of other acts likely to be
unduly prejudicial. It would also risk disqualifying Maxwell's chosen counsel based on their
involvement in the earlier civil case.
Rule 14(a) of the Federal Rules of Criminal Procedure allows a court to order separate
trials if joining all offenses in a single trial would prejudice the defendant. A defendant seeking
severance must show significant unfairness to outweigh the burden on the court of conducting
multiple trials. United States V. Walker, 142 F.3d 103, 110 (2d Cir. 1998). The harm to the
defendant must be more than "solely the adverse effect of being tried for two crimes rather than
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one." United States V. Werner, 620 F.2d 922, 929 (2d Cir. 1980). Though this standard is
demanding, the Court concludes that, due to unique features of the perjury counts, Maxwell
meets it here. Trying all counts together would compromise Maxwell's right to the counsel of
her choice and risk an unfair trial.
Trying the perjury counts together with the Mann Act counts would risk an unfair trial on
each set of counts. First, it would introduce unrelated allegations of sexual abuse, which would
potentially expose the jury to evidence that might otherwise not be admissible. In particular, a
joint trial would potentially expose the jury to a wider swath of information regarding civil
litigation against Epstein that is remote from Maxwell's charged conduct. This presents a
significant risk that the jury will cumulate the evidence of the various crimes charged and find
guilt when, if considered separately, it would not do so. See United States V. Halper, 590 F.2d
422, 430 (2d Cir. 1978). Second, the evidence presented on the Mann Act counts may prejudice
the jury's ability to fairly evaluate Maxwell's truthfulness in her deposition, a critical element of
the perjury counts. The Court has concerns that a limiting instruction may be inadequate to
mitigate these risks given the nature of the allegations involved.
Importantly, a joint trial is also likely to require disqualification of at least one of
Maxwell's attorneys from participating as an advocate on her behalf. The perjury counts likely
implicate the performance and credibility of her lawyers in the civil action-two of whom
represent her in this case. The New York Rules of Professional Conduct generally forbid a
lawyer from representing a client in a proceeding in which the lawyer is likely also to be a
witness. N.Y. R. Prof'l Conduct $ 3.7(a). Maxwell's counsel in the civil action and the
deposition may be important fact witnesses on the perjury counts. Even if counsel were not
required to testify, trying all counts together could force Maxwell to choose between having her
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counsel testify on her behalf on the perjury charges and having them assist her in defending the
Mann Act charges.
The Second Circuit has recognized that witness testimony offered by a party's attorney
presents serious risks to the fairness of a trial. See Murray V. Metro. Life Ins. Co., 583 F.3d 173,
178 (2d Cir. 2009). The lawyer might appear to vouch for their own credibility, jurors might
perceive the lawyer as distorting the truth to benefit their client, and blurred lines between
argument and evidence might confuse the jury. Id. Disqualification of counsel also implicates
Maxwell's Sixth Amendment right to be represented by the counsel of her choice. See, e.g.,
United States V. Kincade, No. 15-cr-00071 (JAD) (GWF), 2016 WL 6154901, at *6 (D. Nev.
Oct. 21, 2016). The prejudice to Maxwell is especially pronounced because the attorneys who
represented her in the civil case have worked with her for years and are particularly familiar with
the facts surrounding the criminal prosecution. See United States V. Cunningham, 672 F.2d
1064, 1070-71 (2d Cir. 1982).
The Court is of course cognizant of the burden separate trials may impose on all trial
participants. But much of the proof relevant to the perjury counts and the Mann Act counts does
not overlap. In particular, materiality for statements made in a civil deposition is broad, and
evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at
753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to
both sets of charges, many are not. At a minimum, this will expand the scope of the trial far
beyond the narrower issues presented. And while the Court agrees with the Government that at
least some of Maxwell's concerns are overstated, there is little question that the jury's
consideration of the nature of the defamation action will require a significant investment of time
and resources to provide the requisite context.
25
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=== Page 26 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 26 of 34
The balance of these considerations favors severance. "Motions to sever are committed
to the sound discretion of the trial judge." United States V. Casamento, 887 F.2d 1141, 1149 (2d
Cir. 1989). In its discretion, the Court concludes that trying the perjury counts separately will
best ensure a fair and expeditious resolution of all charges in this case.
VI.
Maxwell's motion to strike surplusage is premature
Maxwell moves to strike allegations related to one of the alleged victims from the S1
superseding indictment as surplusage. The Court declines to do so at this juncture.
Federal Rule of Criminal Procedure 7(d) allows a court to strike surplusage from an
indictment on a defendant's motion. "Motions to strike surplusage from an indictment will be
granted only where the challenged allegations are not relevant to the crime charged and are
inflammatory and prejudicial." United States V. Hernandez, 85 F.3d 1023, 1030 (2d Cir. 1996)
(cleaned up). Courts in this District generally delay ruling on any motion to strike until after the
presentation of the Government's evidence at trial, because that evidence may affect how
specific allegations relate to the overall charges. See, e.g., United States V. Nejad, No. 18-cr-224
(AJN), 2019 WL 6702361, at *18 (S.D.N.Y. Dec. 6, 2019); United States V. Mostafa, 965 F.
Supp. 2d 451, 467 (S.D.N.Y. 2013).
Maxwell contends that the allegations related to "Minor Victim-3" are surplusage
because the indictment does not charge that Minor Victim-3 traveled in interstate commerce or
was below the age of consent in England where the alleged activities took place. Thus, she
argues, these allegations do not relate to the charged conspiracy and instead reflect an attempt to
introduce Minor Victim-3's testimony for impermissible purposes.
The Court will not strike any language from the S1 superseding indictment at this
juncture. The standard under Rule 7(d) is "exacting" and requires the defendant to demonstrate
26
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=== Page 27 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 27 of 34
clearly that the allegations are irrelevant to the crimes charged. United States V. Napolitano, 552
F. Supp. 465, 480 (S.D.N.Y. 1982). The indictment does not allege that the alleged victim
traveled in interstate commerce or was underage during sexual encounters with Epstein. But the
Court cannot rule out that the allegations may reflect conduct undertaken in furtherance of the
charged conspiracy or be relevant to prove facts such as Maxwell's state of mind. See United
States V. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Court will follow the well-worn
path of others in this District and reserve the issue for trial. Maxwell may renew her motion
then.
VII.
Maxwell's motion to dismiss multiplicitous charges is premature
Maxwell's motion to dismiss either the first or third count of the S1 superseding
indictment as multiplicitous is also premature. Maxwell contends that the Government has
alleged the same conspiracy twice in the indictment. "An indictment is multiplicitous when it
charges a single offense as an offense multiple times, in separate counts, when, in law and fact,
only one crime has been committed." United States V. Chacko, 169 F.3d 140, 145 (2d Cir. 1999).
"The multiplicity doctrine is based upon the double jeopardy clause of the Fifth Amendment,
which assures that the court does not exceed its legislative authorization by imposing multiple
punishments for the same offense." United States V. Nakashian, 820 F.2d 549, 552 (2d Cir. 1987)
(cleaned up).
"Where there has been no prior conviction or acquittal, the Double Jeopardy Clause does
not protect against simultaneous prosecutions for the same offense, so long as no more than one
punishment is eventually imposed." United States V. Josephberg, 459 F.3d 350, 355 (2d Cir.
2006). "Since Josephberg, courts in this Circuit have routinely denied pre-trial motions to
dismiss potentially multiplicitous counts as premature." United States V. Medina, No. 13-cr-272
27
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=== Page 28 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 28 of 34
(PGG), 2014 WL 3057917, at *3 (S.D.N.Y. July 7, 2014) (collecting cases). The Court therefore
denies Maxwell's motion to dismiss multiplicitous counts without prejudice.
VIII. The parties shall negotiate all remaining disclosures
Maxwell moves to compel the Government to produce certain documents she believes it
has in its possession and has failed to produce. She also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government's response in briefing and
letters the parties have since submitted to the Court, it appears that most of these requests have
been overtaken by events. Accordingly, although the Court concludes that Maxwell is not
entitled to expedite this discovery based on the arguments in her motion papers, the Court will
require the parties to confer on an overall schedule for all remaining pretrial disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady V. Maryland, 373 U.S. 83 (1963) and Giglio V.
United States, 405 U.S. 150 (1972) require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce "not only exculpatory material, but also
information that could be used to impeach a key government witness." United States V. Coppa,
267 F.3d 132, 135 (2d Cir. 2001) (citing Giglio, 405 U.S. at 154). As a general rule, "Brady and
its progeny do not require immediate disclosure of all exculpatory and impeachment material
upon request by a defendant." Id. at 146. "[A]s long as a defendant possesses Brady evidence in
time for its effective use, the government has not deprived the defendant of due process of law
simply because it did not produce the evidence sooner." Id. at 144.
28
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=== Page 29 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 29 of 34
Maxwell requests an order directing immediate disclosure of all Brady and Giglio
material and also requests a few specific documents she contends the Government has failed to
disclose. The Court begins with the specific requests. The requested materials include (1)
records of witness interviews in connection with an ex parte declaration in support of a response
to a motion to quash subpoenas; (2) an unredacted copy of two FBI reports; (3) pages from a
personal diary that is in the custody of a civilian third party; and (4) copies of all subpoenas the
Government has issued for Maxwell's records as part of its investigation in this case.
The Government represents that it is cognizant of its Brady obligations, that is has
reviewed the witness interviews and one of the FBI reports, and that neither set of documents
includes exculpatory information not previously disclosed. The Court has no reason to doubt the
Government's representation in this case that it is aware of its Brady obligations and that it has
complied and will continue to comply with them. And because the witness statements are
covered by the Jencks Act, the Court cannot compel production of such statements under the
terms of the statute. See 18 U.S.C. § 3500; Coppa, 267 F.3d at 145. Next, the Government
represents that it has already produced an unredacted copy of the other requested FBI report, and
so that request is moot. The diary pages she requests are within the control of a civilian third
party, not the Government, and so the Government need not (and perhaps cannot) produce them.
See United States V. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019). Finally, Maxwell's
request for copies of all subpoenas the Government has issued is overly broad and lacks a legal
basis. Maxwell is not entitled to compel production of these documents.
The Court also will not issue an order requiring the immediate disclosure of Brady and
Giglio material. The Government has represented that it recognizes its obligations under Brady
and that it has complied, and will continue to comply, with such obligations. The Court has no
29
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=== Page 30 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 30 of 34
reason to doubt these representations given its expansive approach to document production thus
far in this case. The Government has agreed in its recent letter to produce Giglio material six
weeks in advance of trial. The parties shall negotiate the specific timing, but assuming a
schedule along those lines is met, the Court concludes that Maxwell will be able to effectively
prepare for trial. See Coppa, 267 F.3d at 144.
B. Jencks Act material and co-conspirator statements
Maxwell also seeks to expedite discovery of Jencks Act material and non-exculpatory
statements of co-conspirators that the government may offer at trial. The Jencks Act, 18 U.S.C.
$ 3500, "provides that no prior statement made by a government witness shall be the subject of
discovery until that witness has testified on direct examination." Coppa, 267 F.3d at 145. The
statute therefore prohibits a district court in most cases from ordering the pretrial disclosure of
witness statements unless those statements are exculpatory. "A coconspirator who testifies on
behalf of the government is a witness under the Act." In re United States, 834 F.2d 283, 286 (2d
Cir. 1987). The Court therefore lacks the inherent power to expedite these disclosures. In any
case, the Government has agreed to produce all Jencks Act material at least six weeks in advance
of trial.
The Court also rejects Maxwell's alternative request for a hearing to determine the
admissibility of co-conspirator declarations. Co-conspirator statements may often be admitted at
trial on a conditional basis. If the Court determines that the Government has not met its burden
to show that the conditionally admitted statements were made in furtherance of the charged
conspiracy, the Court should provide a limiting instruction or, in extreme cases declare a
mistrial. United States V. Tracy, 12 F.3d 1186, 1199 (2d Cir. 1993). Although conditional
admissions can pose a problem, a pretrial hearing is unnecessary here because the Government
30
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=== Page 31 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 31 of 34
has committed to producing co-conspirator statements at least six weeks in advance of trial to
allow Maxwell to raise any objections. Maxwell will have adequate time to object to any
proffered co-conspirator testimony following the Government's Jencks Act disclosures.
C. Witness list
As a general matter, "district courts have authority to compel pretrial disclosure of the
identity of government witnesses." United States V. Cannone, 528 F.2d 296, 300 (2d Cir. 1975).
In deciding whether to order accelerated disclosure of a witness list, courts consider whether a
defendant has made a specific showing that disclosure is "both material to the preparation of the
defense and reasonable in light of the circumstances surrounding the case." United States V.
Bejasa, 904 F.2d 137, 139-140 (2d Cir. 1990) (cleaned up).
Maxwell has made a particularized showing that the Government must produce a witness
list reasonably in advance of trial. The nature of the allegations in this case-decades-old
allegations spanning multiple locations-present considerable challenges for the preparation of
the defense. However, the Government's proposed disclosure schedule-which will afford
Maxwell at least six weeks to investigate testifying witness statements-allows Maxwell
significantly more time to review disclosures than schedules adopted in most cases in this
District. See, e.g., United States V. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9
(S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States V. Nachamie, 91 F. Supp. 2d 565,
580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the
Government produced over 20,000 pages of interview notes, reports and other materials related
to non-testifying witnesses. After considering the circumstances, including the complexity of the
issues in this case and what the defense has already received and likely learned in the course of
discovery, the Court concludes that the Government's proposal is generally reasonable.
31
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=== Page 32 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 32 of 34
D. Rule 404(b) material
Maxwell's final discovery request is for early disclosure of evidence the Government
seeks to offer under Federal Rule of Evidence 404(b). Under Rule 404(b), if the prosecutor in a
criminal case intends to use "evidence of a crime, wrong, or other act" against a defendant, the
prosecutor must "provide reasonable notice of the general nature of any such evidence that the
prosecutor intends to offer at trial" and must "do so in writing before trial-or in any form
during trial if the court, for good cause, excuses lack of pretrial notice." The Government
represents that it will notify the defense of its intent to use 404(b) evidence at least 45 days in
advance of trial to allow Maxwell to file any motions in limine to be considered at the final
pretrial conference. The Government's proposal will give Maxwell an opportunity to challenge
admission of that evidence and to bring to the Court's attention any issues that require resolution
before trial. "This is all that Rule 404(b) requires." United States V. Thompson, No. 13-cr-378
(AJN), 2013 WL 6246489, at *9 (S.D.N.Y. Dec. 3, 2013). The Court concludes this schedule is
generally reasonable, although additional time to enable briefing and resolution in advance of
trial is strongly encouraged.
The Court's denial of Maxwell's requests to compel pretrial disclosures does not preclude
the parties from negotiating in good faith for an expedited discovery timeline that will account
for Maxwell's specific concerns. "[I]n most criminal cases, pretrial disclosure will redound to
the benefit of all parties, counsel, and the court." United States V. Percevault, 490 F.2d 126, 132
(2d Cir. 1974). In general, the Court will require the parties to negotiate a final, omnibus
schedule to propose to the Court. The Court concludes that the disclosure of all of the above
materials approximately six to eight weeks in advance of trial is appropriate and sufficient.
32
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=== Page 33 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 33 of 34
Given the complexities of the case and the addition of two counts via the S2 indictment, the
Court encourages the parties to agree to approximately eight weeks.
IX.
The S2 superseding indictment moots Maxwell's grand jury challenge
The Court has not received supplemental briefing on the motions in light of the return of
the S2 superseding indictment and so does resolve any such issues here.¹ However, Maxwell's
motion seeking to dismiss the S1 superseding indictment because it was returned by a grand jury
sitting at the White Plains courthouse appears moot. Maxwell argued that the use of a grand jury
drawn from the White Plains Division in this District did not represent a fair cross-section of the
community, because her trial would proceed in the Manhattan Division. A grand jury sitting in
Manhattan returned the S2 superseding indictment. By April 21, 2021, Maxwell shall show
cause why her grand jury motion should not be dismissed on that basis.
Conclusion
The Court DENIES Maxwell's motions to dismiss the indictment as barred by Epstein's
non-prosecution agreement (Dkt. No. 141), to dismiss the Mann Act counts as barred by the
statute of limitations (Dkt. No. 143), to dismiss the indictment for pre-indictment delay (Dkt. No.
137), to dismiss the Mann Act counts for lack of specificity (Dkt. No. 123), to dismiss the
perjury counts as legally untenable (Dkt. No. 135), to strike surplusage (Dkt. No. 145), to
dismiss count one or count three as multiplicitous (Dkt. No. 121), and to expedite pretrial
disclosures (Dkt. No. 147). The Court GRANTS Maxwell's motion to sever the perjury counts
for a separate trial (Dkt. No. 119).
1 The parties shall negotiate and propose a schedule for any available additional or supplement rulings in
light of the filing of the S2 indictment.
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=== Page 34 ===
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 34 of 34
The Court ORDERS the Government to confirm within one week whether it considers
any evidence related to negotiation of the non-prosecution agreement to constitute Brady or Rule
16 material and, if so, to confirm that it has or will disclose such evidence.
The Court further ORDERS the parties to negotiate a final schedule for all pretrial
disclosures that remain outstanding, including: Brady, Giglio, and Jenks Act materials, including
co-conspirator statements; non-testifying witness statements; testifying witness statements; the
identity of victims alleged in the indictment; 404(b) material; and the Government's witness list.
The Court also requires the parties to negotiate a schedule for any additional or supplemental
motions briefing in light of the S2 indictment. The Court ORDERS a joint proposal to be
submitted by April 21, 2021. If agreement is not reached, the parties shall submit their
respective proposals.
The Court further ORDERS Maxwell to show cause by April 21, 2021 why her motion to
dismiss the S1 superseding indictment under the Sixth Amendment (Dkt. No. 125) should not be
denied as moot.
so ORDERED.
Dated: April 16, 2021
New York, New York
Alin D.Netto
ALISON J. NATHAN
United States District Judge
34
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c1: EFTA00018663
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018663.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
AO 106 (Rev. 04/10) Application for a Search Warrant
UNITED STATES DISTRICT COURT
for the
District of New Hampshire
In the Matter of
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No. 1:20-
THE USE OF A CELL-SITE SIMULATOR TO LOCATE
)
THE CELLULAR DEVICE ASSIGNED CALL NUMBER
)
)
APPLICATION FOR A SEARCH WARRANT
I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):
located in the
District of
New Hampshire
, there is now concealed (identify the
person or describe the property to be seized):
Please see attached Affidavit and Attachment A.
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
evidence of a crime;
contraband, fruits of crime, or other items illegally possessed;
property designed for use, intended for use, or used in committing a crime;
a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section
Offense Description
18 U.S.C. 371
- Conspiracy to Entice Minors and Transport Minors
18 U.S.C. 2422, 2423(a)
- Enticement of a Minor, and Transportation of a Minor
18 U.S.C. 1623
- Perjury
The application is based on these facts:
Please see attached Affidavit.
Continued on the attached sheet.
Delayed notice of 30 days (give exact ending date if more than 30 days:
) is requested
under 18 U.S.C. $ 3103a, the basis of which is set forth on the attached sheet.
Applicant's signature
Special Agent, FBI
Printed name and title
Sworn to before me and signed in my presence.
UNITED STATES
Date:
07/01/2020
DESTRICT OF
Judge's signature
City and state: Concord, NH
Andrea K. Johnstone, U.S. Magistrate Judge
Printed name and title
EFTA00018663

=== Page 2 ===
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW HAMPSHIRE
IN THE MATTER OF THE USE OF A CELL-
Case No. 1:20-
SITE SIMULATOR TO LOCATE THE
CELLULAR DEVICE ASSIGNED CALL
Filed Under Seal - Level II
NUMBER
AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A SEARCH WARRANT
I,
, being first duly sworn, hereby depose and state as follows:
INTRODUCTION AND AGENT BACKGROUND
1.
I make this affidavit in support of an application for a search warrant under Federal
Rule of Criminal Procedure 41 to authorize law enforcement to employ an electronic investigative
technique, which is described in Attachment B, to determine the location of the cellular device
assigned call number
,
(the "Target Cellular Device"), which is described in
Attachment A.
2.
I am a Special Agent with the Federal Bureau of Investigation ("FBI"), and have
been since 2017. I am currently assigned to investigate violations of criminal law relating to the
sexual exploitation of children as part of an FBI Task Force. I have gained expertise in this area
through classroom training and daily work related to these types of investigations. As part of my
responsibilities, I have been involved in the investigation of cases involving sex trafficking,
enticement of minors, and transportation of minors for illegal sex acts, and have participated in the
execution of search warrants involving electronic evidence and cellular devices.
3.
The facts in this affidavit come from my personal observations, my training and
experience, and information obtained from other agents and witnesses. This affidavit is intended
EFTA00018664

=== Page 3 ===
to show merely that there is sufficient probable cause for the requested warrant and does not set
forth all of my knowledge about this matter.
4.
One purpose of applying for this warrant is to determine with precision the Target
Cellular Device's location. However, there is reason to believe the Target Cellular Device is
currently located somewhere within this district. On or about June 30, 2020, United States
Magistrate Judge Katharine H. Parker, signed a warrant for cellphone location information for the
Target Cellular Device (the "GPS Warrant"), which is attached as Exhibit A. Pursuant to the GPS
Warrant, the FBI has received GPS location data since approximately 10:15 p.m. on June 30, 2020
and has also historical cell site data for the Target Cellular Device for the period June 1, 2020 to
the present. That data shows that the Target Cellular Device is currently located in the District of
New Hampshire and has been located in the District of New Hampshire for the last 30 days. The
location data has allowed the FBI to identify approximately one square mile in which the Target
Cellular Device is located, but the location data is insufficiently specific to allow the FBI to
identify the particular building in which the Target Cellular Device is currently located. Pursuant
to Rule 41(b)(2), law enforcement may locate the Target Cellular Device outside the district
provided the device is within the district when the warrant is issued.
5.
Based on the facts set forth herein, there is probable cause to believe that
GHISLAINE MAXWELL has violated 18 U.S.C. $ 371 (conspiracy to entice minors to travel to
engage in illegal sex acts); 18 U.S.C. $ 2422 (enticement of a minor to travel to engage in illegal
sex acts); 18 U.S.C. $ 371 (conspiracy to transport minors with intent to engage in criminal sexual
activity); 18 U.S.C. $ 2423(a) (transportation of a minor with intent to engage in criminal sexual
activity); and 18 U.S.C. § 1623 (perjury). Specifically, on June 29, 2020, a grand jury sitting in
the Southern District of New York returned an indictment charging MAXWELL with these crimes,
2
EFTA00018665

=== Page 4 ===
which is attached as Exhibit B. That same day, United States Magistrate Judge Lisa Margaret
Smith signed an arrest warrant for MAXWELL, which is attached as Exhibit C.
6.
There is also probable cause to believe that the Target Cellular Device's location
will assist law enforcement in arresting MAXWELL, who is a "person to be arrested" within the
meaning of Federal Rule of Criminal Procedure 41(c)(4). In particular, and as detailed below,
there is probable cause to believe that MAXWELL is the primary user of the Target Cellular
Device which remains active. The FBI does not know MAXWELL's current location and
accordingly requires the information sought in this application in order to locate and arrest
MAXWELL.
7.
Because collecting the information authorized by this warrant may fall within the
statutory definitions of a "pen register" or a "trap and trace device," see 18 U.S.C. $ 3127(3) &
(4), this warrant is designed to comply with the Pen Register Statute as well as Rule 41. See 18
U.S.C. §§ 3121-3127. This warrant therefore includes all the information required to be included
in a pen register order. See 18 U.S.C. $ 3123(b)(1). Consistent with the requirement for a pen
register order, I certify that the information likely to be obtained is relevant to an ongoing criminal
investigation by FBI. See 18 U.S.C §§ 3122(b), 3123(b).
8.
Consistent with the requirement for a pen register order, I certify that the
information likely to be obtained is relevant to an ongoing criminal investigation by FBI. See 18
U.S.C §§ 3122(b), 3123(b)."
PROBABLE CAUSE
9.
Based on the following, I respectfully submit there is probable cause to believe that
the Target Cellular Device's location will assist law enforcement in locating and arresting
MAXWELL pursuant to the arrest warrant described in paragraph 5, above.
3
EFTA00018666

=== Page 5 ===
10.
As set forth in Exhibit A, United States Magistrate Judge Katharine H. Parker found
on June 30, 2020 that there is probable cause to believe that the location of the Target Cellular
Device will reveal the location of GHISLAINE MAXWELL. As set forth in paragraph 4 above,
that same day, the FBI received location information from AT&T revealing that the Target Cellular
Device is currently located in the District of New Hampshire and has been located in the District
of New Hampshire for at least the last 30 days.
11.
Based on my review of Customs and Border Patrol records, I know that
GHISLAINE MAXWELL is a United States citizen and that she most recently entered the United
States in or about June of 2019. There is no record of MAXWELL leaving the United States since
her arrival in June of 2019.
12.
Based on my review of court filings, I am aware that GHISLAINE MAXWELL is
represented by counsel in multiple ongoing civil lawsuits in the United States. As recently as in
or about June 2020, attorney Laura Menninger appeared in in the Southern District of New York
for oral argument before United States District Judge Loretta A. Preska on MAXWELL's behalf.
13.
Based on my review of AT&T records, I have learned that the Target Cellular
Device is subscribed in the name of "G Max," which appears to be a shortened version of
GHISLAINE MAXWELL's name.
14.
I further know from my review of AT&T records the following:
a. The Target Cellular Device has been in contact with a phone subscribed to
in the name of "Laura Menninger," which I know from my review of court records is the name of
an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
Menninger Phone"). The most recent contact between The Target Cellular Device and the Laura
Menninger Phone occurred within the last 30 days.
4
EFTA00018667

=== Page 6 ===
b. The Target Cellular Device has also been in contact with a phone subscribed
to the business "Haddon, Morgan, & Foreman," which I know from my review of court records is
the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the
"Haddon, Morgan, & Foreman Phone"). The most recent contact between The Target Cellular
Device and the Haddon, Morgan, & Foreman Phone occurred within the last 30 days.
c. The Target Cellular Device has also been in contact with a phone subscribed
to in the name of "Isabel Maxwell," which I know from my review of a law enforcement database
is the name of GHISLAINE MAXWELL's sister (the "Isabel Maxwell Phone"). The most recent
contact between The Target Cellular Device and the Isabel Maxwell Phone occurred in or about
May 2020.
d. The Target Cellular Device has also been in contact with a phone subscribed
to in the name of "Scott Borgerson," which I know from my review of bank records and Amazon
records is the name of an individual with whom GHISLAINE MAXWELL shares a joint bank
account and to whom MAXWELL's Amazon account has sent multiple packages within
approximately the last year (the "Scott Borgerson Phone"). The most recent contact between The
Target Cellular Device and the Scott Borgerson Phone occurred in or about March 2020.
15.
Accordingly, I respectfully submit that there is probable cause to believe that the
location of the Target Cellular Device will reveal the location of GHISLAINE MAXWELL.
MANNER OF EXECUTION
16.
In my training and experience, I have learned that cellular phones and other cellular
devices communicate wirelessly across a network of cellular infrastructure, including towers that
route and connect individual communications. When sending or receiving a communication, a
5
EFTA00018668

=== Page 7 ===
cellular device broadcasts certain signals to the cellular tower that is routing its communication.
These signals include a cellular device's unique identifiers.
17.
To facilitate execution of this warrant to determine the location of the Target
Cellular Device, law enforcement may use an investigative device or devices capable of
broadcasting signals that will be received by the Target Cellular Device or receiving signals from
nearby cellular devices, including the Target Cellular Device. Such a device may function in
some respects like a cellular tower, except that it will not be connected to the cellular network and
cannot be used by a cell phone to communicate with others. The device may send a signal to the
Target Cellular Device and nearby cellular devices and thereby prompt them to send signals that
include the unique identifier of the device. Law enforcement may monitor the signals broadcast
by the Target Cellular Device for non-content signal information and use that information to
determine the Target Cellular Device's location, even if it is located inside a house, apartment, or
other building. The device will not intercept the contents of the Target Cellular Device's
communications, such as telephone calls, text messages, and other electronic communications.
Further, the device will not collect any other data stored on the Target Cellular Device, including
e-mails, text messages, contact lists, images, or Global Positioning System (GPS) data.
18.
The investigative device may interrupt cellular service of phones or other cellular
devices within its immediate vicinity. Any service disruption to non-target devices will be brief
and temporary, and all operations will attempt to limit the interference with such devices. In order
to connect with the Target Cellular Device, the device may briefly exchange signals with all phones
or other cellular devices in its vicinity to determine whether those devices' unique identifiers match
the identifiers of the Target Cellular Device. These signals may include cell phone identifiers.
The device will not complete a connection with cellular devices determined not to be the Target
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=== Page 8 ===
Cellular Device, and law enforcement will limit collection of information from devices other than
the Target Cellular Device. To the extent that any information from a cellular device other than
the Target Cellular Device is collected by the law enforcement device, law enforcement will delete
that information, and law enforcement will make no investigative use of it absent further order of
the court, other than distinguishing the Target Cellular Device from all other cellular devices.
AUTHORIZATION REQUEST
19.
Based on the foregoing, I request that the Court issue the proposed search warrant,
pursuant to Federal Rule of Criminal Procedure 41. The proposed warrant also will function as a
pen register order under 18 U.S.C. $ 3123.
20.
I further request, pursuant to 18 U.S.C. $ 3103a(b) and Federal Rule of Criminal
Procedure 41(f)(3), that the Court authorize the officer executing the warrant to delay notice until
30 days from the end of the period of authorized surveillance. This delay is justified because
there is reasonable cause to believe that providing immediate notification of the warrant may have
an adverse result, as defined in 18 U.S.C. $ 2705. Providing immediate notice to the subscriber
or user of the Target Cellular Device would seriously jeopardize the ongoing investigation, as such
a disclosure would give that person an opportunity to destroy evidence, change patterns of
behavior, and flee from prosecution. See 18 U.S.C. $ 3103a(b)(1). There is reasonable necessity
for the use of the technique described above, for the reasons set forth above. See 18 U.S.C. $
3103a(b)(2).
21.
I further request that the Court authorize execution of the warrant at any time of
day or night, owing to the potential need to locate the Target Cellular Device outside of daytime
hours.
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=== Page 9 ===
22.
I further request that the Court order that all papers in support of this application,
including the affidavit and search warrant, be sealed until further order of the Court. These
documents discuss an ongoing criminal investigation that is neither public nor known to all of the
targets of the investigation. Accordingly, there is good cause to seal these documents because
their premature disclosure may seriously jeopardize that investigation.
23.
A search warrant may not be legally necessary to compel the investigative
technique described herein. Nevertheless, I hereby submit this warrant application out of an
abundance of caution.
Respectfully Submitted,
Special Agent
Federal Bureau of Investigation
The affiant appeared before me by telephonic conference on this date pursuant to Fed. R.
Crim. P. 4.1 and affirmed under oath the content of this affidavit and application.
Honorable Andrea K. Johnstone
United States Magistrate Judge
UNITED STATES BISTRICT COURT
District of New Hampshire
Dated: Jul 1, 2020
OF
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=== Page 10 ===
Original
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Second Warrant and Order For
Prospective and Historical Location
SECOND
Information and Pen Register
WARRANT AND ORDER
Information for the Cellphone Assigned
Call Number
USAO
,
Reference No. 2018R01618
Mag.
Second Warrant and Order
for Cellphone Location Information and Pen Register Information
and for Sealing and Non-Disclosure
TO:
AT&T ("Service Provider"), and any subsequent provider of service to the Target
Cellphone specified below ("Subsequent Service Provider")
Federal Bureau of Investigation ("Investigative Agency")
Upon the Application and Agent Affidavit submitted by the Government in this matter:
I. Findings
The Court hereby finds:
1. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is
assigned call number
,
is subscribed to in the name of "G Max" (the "Subscriber"),
and is currently serviced by the Service Provider.
2. Pursuant to 18 U.S.C. $ 2703(c)(1)(A) and the applicable provisions of Rule 41 of the
Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to
believe that the prospective and historical location information for the Target Cellphone will reveal
the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a),
and 1623 ("the Subject Offenses").
3. Pursuant to 18 U.S.C. $ 2703(d), the Government's application also sets forth specific
and articulable facts showing that there are reasonable grounds to believe that the toll records for
the Target Cellphone are relevant and material to an ongoing criminal investigation.
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=== Page 11 ===
4. Pursuant to 18 U.S.C. $ 3123(b)(1), the Government has certified that the pen register
information for the Target Cellphone is relevant to an ongoing investigation by the Investigating
Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations
of the Subject Offenses.
5. Pursuant to 18 U.S.C. $ 2705(b), there is reason to believe that notification of the
existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of
potential witnesses, or otherwise will seriously jeopardize an ongoing investigation.
NOW, THEREFORE, pursuant to Fed. R. Crim. P. 41, 18 U.S.C. §§ 3121 et seq., 18 U.S.C.
§§ 2701 et seq., and 18 U.S.C. $ 3103a, IT IS HEREBY ORDERED:
II. Order to Service Provider
6. Service Provider. This Order shall apply to the Service Provider specified above, and
to any subsequent provider of service to the Target Cellphone without need for further Order of
this Court.
7. Prospective Location Information. The Service Provider shall provide to the
Investigating Agency on a prospective basis, for a period of 45 days from the date of this Order,
information concerning the location of the Target Cellphone ("Prospective Location
Information"), including all available:
a. precision location information, including GPS data, E-911 Phase II data, and
latitude-longitude data; and
b. cell site data, including any data reflecting (a) the cell towers and sectors thereof
utilized in routing any phone, text, or data communication to or from the Target Cellphone, and
(b) the approximate range of the target phone from the cell towers during the communication
(including per-call measurement ("PCM") or round-trip time ("RTT") data);
2
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=== Page 12 ===
8. Historical Location Information and Toll Records. The Service Provider shall
provide to the Investigating Agency all available historical cell site location information reflecting
the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or
from the Target Cellphone, and the approximate range of the target phone from the cell towers
during the communication (PCM/RTT data), for the period from June 1, 2020 through the present,
as well as all available toll records (including call detail, SMS detail, or data session detail records)
for the communications.
9. Pen register with caller identification and/or trap and trace device. The Service
Provider shall provide to the Investigating Agency, for a period of 45 days from the date of this
order, all dialing, routing, addressing, or signaling information associated with each voice, text, or
data communication transmitted to or from the Target Cellphone, including but not limited to:
a. any unique identifiers associated with the phone, including ESN, MEIN,
MSISDN, IMSI, IMEI, SIM, MIN, or MAC address;
b. source and destination telephone numbers and/or Internet protocol ("IP")
addresses;
c. date, time, and duration of the communication; and
d. cell-site information as specified above.
1 The Service Provider is not required to provide post-cut-through dialed digits ("PCTDD"), or
digits that are dialed after a telephone call from the Target Phone has been connected. If possible,
the Service Provider will forward only pre-cut-through-dialed digits to the Investigative Agency.
However, if the Service Provider's technical capabilities require it to forward all dialed digits,
including PCTDD, to the Investigative Agency, the Investigative Agency will only decode and
forward to the agents assigned to the investigation, the numbers that are dialed before the call is
cut through.
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=== Page 13 ===
10. Technical Assistance. The Service Provider shall furnish the Investigating Agency all
information, facilities, and technical assistance necessary to accomplish the disclosure of all of the
foregoing information relating to the Target Cellphone unobtrusively and with the minimum
interference to the service presently provided to the Subscriber.
11. Non-Disclosure to Subscriber. The Service Provider, including its affiliates, officers,
employees, and agents, shall not disclose the existence of this Warrant and Order, or the underlying
investigation, to the Subscriber or any other person, for a period of one year from the date of this
Warrant and Order, subject to extension upon application to the Court, if necessary.
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=== Page 14 ===
III. Additional Provisions
12. Compensation for Costs. The Investigating Agency shall compensate the Service
Provider for reasonable expenses incurred in complying with the Warrant and this Order.
13. Sealing. This Warrant and Order, and the supporting Application and Agent Affidavit,
shall be sealed until otherwise ordered by the Court, except that the Government may without
further order of this Court: serve this Warrant and Order on the Service Provider; provide copies
of the Warrant and Order or the supporting Application and Agent Affidavit as need be to
personnel assisting the Government in the investigation and prosecution of this matter; and
disclose these materials as necessary to comply with discovery and disclosure obligations in any
prosecutions related to this matter.
Dated: New York, New York
6/30/2020
10:08 a.m.
Date Issued
Time Issued
Kathaw H Parke
UNITED STATES MAGISTRATE JUDGE
Southern District of New York
5
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=== Page 15 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
SEALED
UNITED STATES OF AMERICA
:
INDICTMENT
:
- V. -
:
20 Cr.
:
GHISLAINE MAXWELL,
:
:
20 Cr. 330
Defendant.
:
:
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1.
The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 1997, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as young as 14 years old when they were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00018677

=== Page 16 ===
Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
3.
During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein and also was paid by Epstein to manage his various
properties. Over the course of their relationship, MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
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=== Page 17 ===
4.
Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a. MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b.
Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
C.
MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
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=== Page 18 ===
massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d. In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
indebted and believed that MAXWELL and Epstein were trying to
help them.
e.
Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5. GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
placing a sex toy such as a vibrator on a victim's genitals,
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=== Page 19 ===
directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
6.
Between approximately in or about 1994 and in or
about 1997, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a.
A a multi-story private residence on the
Upper East Side of Manhattan, New York owned by Epstein (the
"New York Residence"), which is depicted in the following
photograph:
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=== Page 20 ===
b.
An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence"), which is depicted in the
following photograph:
C.
A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence"), which is depicted in the
following photograph:
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=== Page 21 ===
d.
MAXWELL's personal residence in London,
England.
7. Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In
particular, and during time periods relevant to this Indictment,
MAXWELL engaged in the following acts, among others, with
respect to minor victims:
a.
MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
7
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=== Page 22 ===
and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b. MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
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=== Page 23 ===
an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
C.
MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
8. In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
9
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=== Page 24 ===
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
9.
From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
10. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
11. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
10
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=== Page 25 ===
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
C.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
12. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
11
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=== Page 26 ===
13. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
12
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=== Page 27 ===
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423 (a)
16. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423 (a)
Overt Acts
17. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
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=== Page 28 ===
New York Residence, in violation of New York Penal Law, Section
130.55.
C. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
18. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
19. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 in
interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
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=== Page 29 ===
aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423 (a) and 2.)
COUNT FIVE
(Perjury)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
21. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q.
Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A.
I don't know what you're talking about.
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=== Page 30 ===
Q.
List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
A.
I'm not aware of anybody that I interacted with,
other than obviously [the plaintiff] who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT SIX
(Perjury)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
23. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q:
Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A:
No, not that I recall.
a
Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A. No.
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=== Page 31 ===
Q.
Other than yourself and the blond and brunette
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A.
I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
Q. I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A. That is my testimony, that is correct.
Q. Is it your testimony that you've never given
anybody a massage?
A.
I have not given anyone a massage.
Q. You never gave Mr. Epstein a massage, is that
your testimony?
A.
That is my testimony.
Q.
You never gave [Minor Victim-2] a massage is your
testimony?
A.
I never gave [Minor Victim-2] a massage.
(Title 18, United States Code, Section 1623.)
The
FOREPERSON
AUDREY
Audy STRAUSS Straws
Acting United States Attorney
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=== Page 32 ===
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
INDICTMENT
(18 U.S.C. §§ 371, 1623, 2422, 2423 (a),
and 2)
AUDREY STRAUSS
Acting United States Attorney
John
Foreperson
18
EFTA00018694

=== Page 33 ===
Mod AO 442 (09/13) Arrest Warrant AUSA Name & Telno:
212-637-2225
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
20 CR 330
V.
)
)
Case No.
)
)
)
Ghislaine Maxwell
)
Defendant
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested) Ghislaine Maxwell
who is accused of an offense or violation based on the following document filed with the court:
Indictment
Superseding Indictment
Information
Superseding Information
Complaint
Probation Violation Petition
Supervised Release Violation Petition
Violation Notice
Order of the Court
This offense is briefly described as follows:
Title 18, United States Code, Section 371 (conspiracy to entice minors)
Title 18, United States Code, Sections 2422 and 2 (enticement of a minor)
Title 18, United States Code, Section 371 (conspiracy to transport minors)
Title 18, United States Code, Sections 2423(a) and 2 (transportation of a minor)
Title 18, United States Code, Section 1623 (perjury)
Lisa Margaret Sun
Date:
06/29/2020
Issuing officer's signature
City and state:
White Plains, NY
Hon. Lisa Margaret Smith, U.S. Magistrate Judge
Printed name and title
Return
This warrant was received on (date)
, and the person was arrested on (date)
at (city and state)
Date:
Arresting officer's signature
Printed name and title
EFTA00018695


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=== Page 1 ===
From:
"
(USANYS)"
To:
"
Subject: SDNY-ODAG Call (Epstein/Maxwell)
Date: Tue, 18 Aug 2020 16:26:27 +0000
Importance: Normal
Attachments: unnamed
EFTA00020339


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=== Page 1 ===
727 Boeing - N908JE
JEGE, Inc.
MM11-727 BOEING-N908JE_JEGE INC-000001
EFTA00019442

=== Page 2 ===
JEGE
him
NC.
R MANIFEST
Registration Number: N908JE
Type: B-727-31
Pilots:
Flight
E
DATE:
1.12 2004
FROM PBI
TO
JFK
Departure
AM
6:15
Arrival
Time
PM
Time
8:23 AM PM
Trip
Number
241
PASSENGERS
1. Jeffrey Epstein
FROM Identifier Defined
City
WEST PALM BEACH
State or Country
FL
TO Identifier Defined
City
6
NEW york
7.
State or Country N.Y.
Nautical Miles 893
8.
Statute Miles 1027
9.
Gallons 3045
10.
AIRFRAME
11.
Pounds 18552 32849 6
Flight Time 2+07
12.
21
Altitude FL FL370 32851.7
13.
20.
Night
14.
21
21.
T/L
15.
111
22.
IMC
16.
-
23.
Approach
17.
24.
18.
25.
19.
26.
MM11-727 BOEING-N908JE_JEGEINC


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=== Page 1 ===
From:
To:
Subject: RE: Voice Message Attached from 2022466629 - HALL DAVID
Date: Fri, 15 Nov 2019 23:28:39 +0000
You too, thanks!
From:
Sent: Friday, November 15, 2019 3:19 PM
To:
Subject: Re: Voice Message Attached from 2022466629 - HALL DAVID
Thanks.
Have a great weekend.
On Nov 15, 2019, at 2:36 PM,
wrote:
Thanks very much,
Yes, l'll give him a call.
From:
Sent: Friday, November 15, 2019 2:34 PM
To:
Subject: Fwd: Voice Message Attached from 2022466629 - HALL DAVID
Hey
- passing this message on to you - relates to the Epstein case. A friend of mine (who is a former
AUSA in Cleveland) is the person who gave my number to this attorney, who was looking for an SDNY
contact.
Do you want to give him a call back? Thanks.
Begin forwarded message:
From: <postmaster@voip.usa.doj.gov>
Date: November 15, 2019 at 10:12:06 AM EST
To:
Cc:
Subject: Voice Message Attached from 2022466629 - HALL DAVID
Time: Nov 15, 2019 10:12:06 AM
Click attachment to listen to Voice Message
EFTA00019830


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=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Fri, 26 Mar 2021 19:37:09 +0000
Attachments: 2021-03-26,_subpoena_to_Interlochen.pdf
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
)
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
EFTA00019493

=== Page 2 ===
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00019494

=== Page 3 ===
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
EFTA00019495

=== Page 4 ===
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
EFTA00019496

=== Page 5 ===
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
EFTA00019497

=== Page 6 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Alison
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi Maurene -
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
EFTA00019498

=== Page 7 ===
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
=
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
EFTA00019499

=== Page 8 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
>,
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
EFTA00019500

=== Page 9 ===
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
>
Cc:
>;
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
EFTA00019501

=== Page 10 ===
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00019502


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=== Page 1 ===
Bank of America N.A.
Legal Order Processing
Christiana IV
800 Samoset Drive
Newark, DE 19713
Mail code DE5-024-02-08
Attention: Legal Order Processing
Delivered via: FEDEX
Rider
ALL OPEN AND CLOSED ACCOUNTS
Please provide all images of documents in Adobe PDF files on CDs. Additionally, please provide Data
Transaction Files in Excel of all account statements.
Please provide from inception to present any and all records pertaining to the following
accounts(s)/organization(s)/individuals(s) whether held jointly or severally or as trustee or fiduciary as
well as custodian, executor or guardian:
A. Please use the following identifiers:
NAMES/ENTITIES
AKA:
DOB
SSN
PHONE
EFTA00019755

=== Page 2 ===
EMAIL
ACCOUNT NUMBER
B. Records to be produced should include but are not limited to the items listed below:
1. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting additions
and/or subtractions to the account and how the account balances are being satisfied on a monthly
basis;
2. Signature cards;
3. Proof of identification (including but not limited to copies of identification used to open the
account);
4. Location of withdrawals
5. Opening account(s) documents with attachments, including any and all applications, internal
documents generated to open account(s), and identification information or other documentation
provided by Customer;
6. "Know your customer" documentation;
7. Wire transfer records (incoming and outgoing, and any and all applications and instructions);
8. Safe deposit records, including applications, signature cards, and sign-in records;
9. Trust accounts;
10. Monthly statements;
11. Credit card statements;
12. Bank, travelers, or cashier checks drawn on account or purchased with an account check;
13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks;
14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports,
applications, and payments made on loans;
15. Any and all corporate resolutions, certifications of incorporation, business certificates and/or
partnership agreements;
16. Online banking information- All information regarding the electronic use of banking systems to
include the following: username, registration IP address, online account creation date, online
account status and IP logs/history, MAC addresses and online session times and duration; and
17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text
messages, that reference or concern items (1) through (16), above, and/or any financial interests
involving the individuals and/or entities identified in Section A.
If you have any questions or comments, please contact
Forensic Accountant, at
EFTA00019756


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=== Page 1 ===
STATE
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 11, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing witness materials and discovery pertinent to Ghislaine
Maxwell (02879-509) is
!
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
Assistant United States Attorneys
EFTA00020104


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=== Page 1 ===
Haddon, Morgan and Foreman, P.C.
Jeffrey Pagliuca
HADDON
MORGAN
150 East 10th Avenue
FOREMAN
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
August 17, 2020
VIA EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: Request to Modify Protective Order (UNDER SEAL)¹
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court's Protective Order (Doc.
36), requests that the Court enter an Order allowing her to refer to and file under seal in Giuffre
V. Maxwell, 15-cv-5433 (LAP), and a related Second Circuit appeal, Giuffre V. Maxwell, No. 20-
2413 (the "Other Matters"), certain discovery materials produced by the government on August
5, 2020. She also seeks to refer to (but not file) discovery materials produced by the government
on August 13, 2020, specifically the 90,000 pages of documents received from Boies Schiller &
Flexner, which appears to include their entire civil file from the Giuffre case. 2
Disclosure to the judicial officers in the Other Matters is necessary for fair determination of
important issues impacting the privacy and due process rights of Ms. Maxwell and other third
parties. The ten discrete items to be filed ("the Material") are not confidential and disclosure
confined to the Honorable Loretta Preska and the Second Circuit Court of Appeals, under seal,
1 Ms. Maxwell seeks leave to file this Letter Motion under seal because it relates and refers to
discovery materials deemed Confidential under the terms of the Protective Order in this case.
2 Counsel for Ms. Maxwell have not conducted a document by document comparison of the
90,000 pages with documents in their possession related to the Maxwell civil matters but presumes they
are the same. Paragraph 16 of the Protective Order in this case exempts information obtained "from a
source other than the government." Because Ms. Maxwell has not yet compared the two sets of
documents she makes this request out of an abundance of caution.
EFTA00018749

=== Page 2 ===
The Honorable Alison J. Nathan
August 17, 2020
Page 2
will not prejudice the government.³ The items to be referred to (and not filed) are confidential;
accordingly, referring to them under seal in the Other Matters will not prejudice the government.
Relevant Facts and Procedural History
The defamation action and its Protective Order- Giuffre V. Maxwell
In 2015,
alleged in a civil suit that Ms. Maxwell defamed her, based on a
statement from Ms. Maxwell's attorney-hired press agent generally denying as "untrue" and
"obvious lies"
S allegations that Ms. Maxwell participated in a scheme causing her to be
"sexually abused and trafficked" by Jeffrey Epstein. Given the amount of personal, confidential
material and information sought in discovery, the district court entered a stipulated Protective
Order protecting confidential information from public disclosure. See Giuffre V. Maxwell, 15-cv-
7433 (Doc. # 62).⁴ The language agreed upon, and made an order of the district court,
specifically excluded an exception for law enforcement. Ms. Maxwell shortly thereafter
submitted to a deposition in reliance on the Protective Order; she also was compelled to - and
did - sit for a second deposition in July 2016. A year later and literally days before trial, the
parties agreed to a settlement of the defamation claim and the case was dismissed.
The Jane Doe 43 matter
On January 26, 2017, plaintiff Jane Doe 43 sued various individuals including Ms. Maxwell. A
Protective Order substantially similar to the Protective Order entered in Giuffre V. Maxwell was
entered by Magistrate Judge Netburn on November 29, 2018. 5 That matter was settled and
dismissed on December 20, 2018. Jane Doe 43 also was represented by BSF, the same lawyers
who represent
3 The Materials to be filed are attached, under seal, as exhibits 1-10. Although marked by the
government as "Confidential," the Materials are not "Confidential" as that term has been defined by the
Second Circuit. They consist of ex parte pleadings filed by the government, ex parte transcripts, and ex
parte rulings. Boies, Schiller & Flexner ("BSF") lawyers, cooperating with the government, are aware of
the Material. The Second Circuit has characterized these types of documents as "judicial documents" with
a presumptive right of public access. See Brown V. Maxwell, 929 F.3d 41, 47 (2d Cir. 2019). Ms. Maxwell
objected to the government's Confidential designation, under paragraph 9 of the Protective Order, and
requested that the government withdraw the designation. The Court does not need to decide the issue of
whether the Material is confidential at this time given that Ms. Maxwell seeks only to provide the
Material to judicial officers under seal as information necessary to fairly decide pending issues in those
cases.
4 Plaintiff originally proposed protective order language that would have allowed for a "law
enforcement" exception. In particular, Paragraph I(a)4 of the draft proposed 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." See Giuffre V.
Maxwell, 15-cv-7433 (Doc. # 1078-4 at 4). Ms. Maxwell and her counsel rejected this proposed language
because of her concerns that plaintiff and her lawyers were acting as either express or de facto agents of
the government.
5 See Ex. 4 at p. 7.
EFTA00018750

=== Page 3 ===
The Honorable Alison J. Nathan
August 17, 2020
Page 3
The motion to unseal and the first appeal
One year after Giuffre V. Maxwell was dismissed and closed, the Miami Herald sought to reopen
the case and to unseal every sealed filing on the district court docket. The district court denied
the motion to unseal. The Miami Herald appealed on September 28, 2018.
On July 3, 2019 the Second Circuit reversed Judge Sweet's ruling. Brown V. Maxwell, 929 F.3d
41, 44-45 (2d Cir. 2019). Upon the issuance of the mandate, on August 9, 2019, it largely
unsealed the summary judgment materials to the public and the press and remanded the case to
the district court to conduct a particularized review of the remaining records. Id. at 53-54.
The remand and the unsealing process.
On July 9, the Giuffre case was assigned to the Honorable Loretta Preska who was charged with
the difficult and time consuming task of sorting through thousands of filings, determining what
documents were "judicial," what were not, determining the process to notify the hundreds of
non-parties about their right to object to the disclosure of their confidential information, and
implementing a protocol for maintaining or unsealing the sealed status of thousands of pages of
material. Judge Preska sought input from the various Does, the lawyers for
primarily
Sigrid McCawley, a partner at BSF, and counsel for Ms. Maxwell. Judge Preska was obligated
by the Brown Court first to identify what was or was not a "judicial document"; second, to
determine the presumption of access to the document; and third, to identify and weigh numerous
factors for or against unsealing a judicial document. Since August 2019, this process has
consumed hundreds, if not thousands, of lawyer, court, and staff hours.
On July 23, 2020, Judge Preska, over Ms. Maxwell's objection, ordered the unsealing of her
April 2016 deposition transcript and the deposition transcript of John Doe 1. On July 30, 2020,
Ms. Maxwell filed a notice of appeal to the Second Circuit and an emergency motion with the
Second Circuit to stay the unsealing order pending appeal. See Giuffre V. Maxwell, No. 20-2413,
Doc. # 10 (2d. Cir.) (Maxwell Emergency Motion for Stay). When Judge Preska ordered the
unsealing of Ms. Maxwell's deposition on July 23 and denied Ms. Maxwell's motion to
reconsider on July 30, she apparently did not know that, as described below, Chief Judge
McMahon had already granted an ex parte request from the government to obtain Ms. Maxwell's
deposition (among thousands of other confidential and sealed materials that were protected under
the Protection Order from disclosures to non-parties) and that Magistrate Judge Netburn had
denied such a request from the government. Ms. Maxwell and her attorneys did not know
anything about the government's request for access to these materials.
On July 31, 2020, the Second Circuit stayed Judge Preska's order unsealing Ms. Maxwell and
John Doe 1's deposition transcripts. The Court ordered an expedited briefing schedule. Ms.
Maxwell's opening brief is due on August 20, 2020. Oral argument is September 22, 2020.
The Material
The government apparently contacted BSF at some time before February 2019 while the Second
Circuit appeal of Judge Sweet's order was pending. Based on some discussion with an as-yet
unidentified BSF lawyer, the government served BSF with a subpoena to produce (apparently)
all the BSF litigation files pertaining to both civil litigations. Ms. Maxwell was not served with
EFTA00018751

=== Page 4 ===
The Honorable Alison J. Nathan
August 17, 2020
Page 4
any subpoena. According to the government, "although [BSF] would not otherwise contest
compliance with the Subpoena, [BSF] believe[d] that the Protective Order preclude[d] [BSF]
from complying." See Exhibits 1 at p. 293 and 2, I 5.
In or about February 28, 2019 the government first applied to Judge Sweet for relief. The
government pressed its request in late March 2019 to Chief Judge McMahon and in April to
Magistrate Judge Netburn. During these ex parte proceedings, the government made numerous
unchallenged factual assertions. To Ms. Maxwell's knowledge, no one disclosed the pendency of
these applications to any judicial officer associated with the appeal or the unsealing process.
Certainly, no one not the government, any court, or any lawyer at BSF disclosed to Ms.
Maxwell that, while the issues surrounding the unsealing of thousands of confidential documents
were being litigated in the Second Circuit, BSF and the government were secretly working
together to "modify" the Protective Orders so that the government could gain access to the
materials subject to the Protective Orders.
Over the last year, none of the filings submitted to any court involved in the sanctioned, public
unsealing process hints at the fact that, even though Ms. Maxwell and numerous Does were
contesting the release of the confidential information in the Second Circuit, BSF had already
turned over (apparently) all of the confidential information to the government, as well as all of
the discovery produced by Ms. Maxwell and numerous non-parties. Ms. Maxwell assumes that,
to this day, Judge Preska has never been told that the government was given all the material as
part of the Martindell-avoidance, ex parte processes in front of Judges Sweet, McMahon, and
Netburn.
The indictment with reference to sealed materials
On July 2, 2020, one day after Ms. Maxwell filed her Reply concerning the unsealing of
approximately 5,000 pages of material in the civil matter including her deposition, the
government arrested Ms. Maxwell. On July 8, the government filed a superseding indictment
alleging that Ms. Maxwell "assisted, facilitated, and contributed" to Epstein's abuse of minors.
Regarding the civil action, the indictment alleges that in 2016 Ms. Maxwell made "efforts to
conceal her conduct" by "repeatedly provid[ing] false and perjurious statements" in deposition
testimony. Superseding Indictment, Doc. # 17 at 298.
Ms. Maxwell first learned on August 7, 2020⁶ how the government obtained the sealed
transcripts. On the two applications referenced above (one before Chief Judge McMahon and the
other before Magistrate Judge Netburn), the two SDNY courts rendered a split decision. Judge
McMahon, based on many ex parte, but soon to be challenged, factual assertions granted the ex
6 The first batch of discovery was provided by the government to NY counsel on August 5, 2020
in the late afternoon on a hard disk. Due to the time upload and securely transfer files, undersigned
counsel for Ms. Maxwell (also counsel for her in the Giuffre case) only received these materials at 11:38
a.m. on Friday, August 7, 2020.
EFTA00018752

=== Page 5 ===
The Honorable Alison J. Nathan
August 17, 2020
Page 5
parte application. Magistrate Judge Netburn denied the application. Both courts reached different
results applying the same authority.
Counsel for Ms. Maxwell then learned, on August 14, 2020, that BSF has produced 90,000 pages
of discovery from BSF, including their entire civil file comprised not only of sealed judicial
documents but all of the discovery produced by Ms. Maxwell and numerous non-parties in the
Giuffre case. As the Second Circuit has already held, much of the discovery was compelled, and
responses provided, based on the promise of confidentiality by the Giuffre Protective Order. See
Brown, 929 F.3d 41, n. 22 & 51.
The pressing issue that necessitates the filing of this request concerns Ms. Maxwell's due process
right to fairly litigate issues in the rapidly unfolding unsealing litigation and related appeal.
These issues, in turn, impact her rights as the accused in this matter, constitutionally presumed
innocent unless and until the government proves her guilt beyond all reasonable doubt.
The Protective Order in this case
The Protective Order in this case prohibits the use of the discovery materials or confidential-
designated materials "for any civil proceeding or any purpose other than the defense of this
action" absent mutual agreement in writing between the government and defense counsel or if
"modified by further order of the Court." Doc. # 36 at II 1(a), 10(a), 18. Ms. Maxwell agreed to
that limitation after assurances by the government, consistent with their representation to this
Court, that "the Government rarely provides any third party, including a witness, with any
material they did not already possess," and therefore "concerns defense counsel raises about
future use in civil litigation are not likely to occur." Letter of Alex Rossmiller at 6 (Doc. # 33)
(July 28, 2020). This Court relied on that representation in its ruling that government witnesses
should not be limited in their use of materials gained from the government in any related civil
litigation. Memorandum Op'n & Order at 3 (July 30, 2020). Yet as described above, the
government must have given a copy of the sealed order to BSF, BSF has now used that (or its
omission) to their tactical advantage in the Giuffre unsealing process, and Ms. Maxwell is unable
to respond to the judicial officers with the complete truth.
Paragraph 18 of the Protective Order permits modification by the Court. Further, any concerns
that the government may raise concerning their on-going grand jury investigation will be
obviated by submission of these materials under seal in the other matters.
The reasons this Court should grant the request
In contravention of Martindell and its progeny, the government achieved modification of a valid
protective order entered in connection with settled civil litigation. Knowing that significant
issues relating to the confidences and identities of multiple deponents and other innocents were
being actively litigated, it appears that the government worked in tandem with BSF to secretly
obtain tens of thousands of pages of confidential information, discovery, and sealed materials.
7 The controlling authority relied on by both courts to reach opposite results is Martindell V.
International Telephone and Telegraph Corp., 594 F.2d 291, 293 (2d Cir. 1979).
EFTA00018753

=== Page 6 ===
The Honorable Alison J. Nathan
August 17, 2020
Page 6
There are at least three compelling reasons to modify the Protective Order. First, Judge Preska
might well decline to unseal Ms. Maxwell's depositions if she knew how the government
obtained it despite the Protective Order. We do not know what impact the government's
possession of the BSF file may have on the carefully crafted unsealing process. Judge Preska has
jurisdiction over the Protective Order entered in the Giuffre V. Maxwell case. Issues related to the
administration of that Protective Order should be litigated in that forum. There is a compelling
need for Ms. Maxwell to be able to advise Judge Preska about the Material so that she and the
non-parties can fairly adjudicate the multiple issues being addressed in the unsealing process.
Judge Preska might decide that disclosure to the government obviates the need for further
analysis of the remaining documents.
The partial secrecy surrounding the Material has also fundamentally undermined the fairness of
the adversarial process. Although the grand jury subpoena and government investigation were
known to opposing civil counsel BSF, they failed to move for a modification of the Protective
Order as contemplated by Martindell or disclose the material fact that these items had been
handed over to the government months ago.
Any suggestion that BSF's obligations regarding candor to the tribunal was somehow limited by
the Fed. R. Crim.P. 6(e) is misplaced. "The rule does not impose any obligation of secrecy on
witnesses." Fed. R. Crim. P. 6, Advisory Committee Note to Subdivision 6(e)2. Indeed,
Martindell expressly contemplated that an affected party would have the ability to move to quash
any subpoena issued by a grand jury that would implicate his or her rights under a valid
protective order. Martindell, 524 F.2d at 294. Too many questions remain unanswered
including exactly what was said between the government and BSF, when was it said, and
precisely what was turned over. In the Giuffre V. Maxwell litigation, certain orders entered by
Judge Sweet restricted certain information to "attorney eyes only." Without the ability to use the
Material in the very limited fashion proposed Ms. Maxwell she is unfairly disadvantaged in the
process. Moreover, instead of candidly revealing the fact of the subpoena and production, the
BSF lawyers misleadingly suggested to the courts that Ms. Maxwell's concerns about an
investigation were fabricated.
Second, following the revelation that the government had already obtained her deposition
through an ex parte proceeding, Ms. Maxwell moved Judge Preska to temporarily stay the
unsealing process. See Giuffre V. Maxwell, 15-cv-7433 (Doc. # 1100). But because of the
Protective Order in this case, Ms. Maxwell could not inform Judge Preska of what she knew. On
August 12, Judge Preska denied the motion to stay, finding that: "Given that Ms. Maxwell is not
at liberty to disclose this new information because it is subject to the protective order in the
criminal action, the Court has no reasonable basis to impose a stay." See Giuffre V. Maxwell,
15-cv-7433 (Doc. # 1103) Unless this Court modifies the Protective Order, Judge Preska will
continue to remain in the dark, and Ms. Maxwell will be deprived of a fair opportunity to seek a
stay of the unsealing process. The unsealing process in Giuffre is moving ahead to other
pleadings and exhibits, which include Ms. Maxwell's July 2016 deposition, also sealed and a
part of the indictment in this case. Without modification of this Protective Order, Ms. Maxwell
EFTA00018754

=== Page 7 ===
The Honorable Alison J. Nathan
August 17, 2020
Page 7
will not be able to articulate her many concerns fully and fairly about the unsealing of that
deposition to Judge Preska.
Further, and as this Court knows, ample Second Circuit authority supports staying a civil case
pending the resolution of a related criminal case. See SEC V. Blaszczak, No. 17-CV-3919 (AJN),
2018 WL 301091, at (S.D.N.Y. Jan. 3, 2018) (granting motion to stay civil case and holding
that "[a] district court may stay civil proceedings when related criminal proceedings are
imminent or pending, and it will sometimes be prudential to do so" (quoting Louis Vuitton
Malletier S.A. V. LY USA, Inc., 676 F.3d 83, 98 (2d Cir. 2012))). Among other things, the stay
vindicates the Fifth Amendment and guards against witnesses learning information in the civil
case and then "conforming" their testimony in the criminal case to what was disclosed in the
civil case. This concern is all the more real when one law firm, BSF, is in possession of these
sealed materials representing accusers who may be witnesses in this case. The concern becomes
exponentially magnified when the accusers are purporting to recall and relate memories for
events that allegedly occurred decades ago, and their credibility will be a central challenge at the
criminal trial.
Ms. Maxwell further anticipates the very immediate need to disclose the Materials to the Second
Circuit Court of Appeals in connection with her appeal of Judge Preska's unsealing order, since
the appellate opening brief due on August 20, 2020. Again, disclosure is necessary to correct the
misleading statements of opposing counsel and to frame the issues related to the unsealing
orders.
Notably, the Material at issue is not accuser-related or sensitive in any regard. These ex parte
pleadings, hearings, and rulings are already known to the BSF lawyers. These materials, absent
sealing, would enjoy a presumptive right of public access as judicial documents. Given that the
Material has been disclosed in this case by the government under the terms of this Court's
Order, and without any application to the sealing courts, the government has conceded that this
Court has the authority to authorize use of the Material under the terms of this Court's Protective
Order. And, the government has previously agreed that the appropriate forum to consider issues
related to the civil Protective Order is in the civil litigation, positing the opinion "that neither it
nor this Court is well-positioned to, or should, become the arbiter of what is appropriate or
permissible in civil cases." Doc. # 33 at 7. What Ms. Maxwell asks is that she be allowed to
disclose, under seal, the Material so that she can advise the appropriate arbiters about
information already known to but not disclosed by her opponent.
The Protective Order in this case should not preclude judicial review by other Article III
judicial officers
The Material, as part of the court files in the United States District Court for the Southern
District of New York, may be judicially noticed by either Judge Preska or the Second Circuit
Court of Appeals. See FRE 201; Hong Mai Sa V. Doe, 406 F.3d 155, 158 (2d Cir. 2005) (the
Second Circuit Court of Appeals can take judicial notice of its own files as well as those of the
district court); In re Pruitt, 72 B.R. 436, 440 (Bankr. E.D.N.Y. 1987) (a bankruptcy court may
EFTA00018755

=== Page 8 ===
The Honorable Alison J. Nathan
August 17, 2020
Page 8
take judicial notice of the contents of its own files proceeding and the case in which an adversary
proceeding arose).⁸
The Protective Order restricts Ms. Maxwell from asking the Courts to exercise this authority or
direct the Courts to the applicable miscellaneous actions. Given that the appellate court and
district court are authorized to review, and are capable of reviewing, the Material it is illogical
and unjust that Ms. Maxwell be prohibited from referencing the Material in the civil litigation.
Conclusion
Ms. Maxwell requests that this Court modify the Protective Order to allow her to refer to and file
under seal in Giuffre V. Maxwell, 15-cv-5433 (LAP), and the related Second Circuit appeal,
Giuffre V. Maxwell, No. 20-2413, the Material at issue in this letter motion.
Respectfully Submitted,
Jeffrey S. Pagliuca
CC: Counsel of Record (via Email)
8 See also In the Matter of Lisse, 905 F.3d 495 (7th Cir. 2018) (under Rule 201, federal courts
may take judicial notice of public records, such as state court orders); U.S. ex rel. Osheroff V. Humana
Inc., 776 F.3d 805, 811 (11th Cir. 2015) (documents filed in state court litigation); Rosales-Martinez V.
Palmer, 753 F.3d 890, 894 (9th Cir. 2014) (can take judicial notice of proceedings on any court); Fletcher
V. Menard Correctional Center, 623 F.3d 1171, 1173 (7th Cir. 2010) (court can take judicial notice of
other proceedings in a case involving the same litigant); U.S. V. Mattox, 402 Fed. Appx. 507, 509 n.5
(11th Cir. 2010) (court may take judicial notice of its own records and those of inferior courts).
EFTA00018756


c1: EFTA00020213
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020213.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Epstein search warrant documents
Date: Fri, 19 Jun 2020 18:55:07 +0000
I want to see what FBI sends to us - i.e., whether it's usable or not. If it is, great! And if not, hopefully at that point we'll
have an estimate to forward along.
From:
Sent: Friday, June 19, 2020 13:52
To:
y.
Subject: RE: Epstein search warrant documents
Great, and thanks. What's the game plan with BRG?
From:
Sent: Friday, June 19, 2020 1:43 PM
To:
is
Subject: FW: Epstein search warrant documents
Just FYI - lots of calls about this today.
From:
Sent: Friday, June 19, 2020 13:43
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein search warrant documents
I just had positive conversations with
and
(and
-
had understood that FBI was getting their own
hard drive to transfer the data, which obviously makes sense.
response to
email was to just have
order a 12 TB drive, which she expects will get to
next week. I also think that's a better option than the 2 TB
drive that
says we have available on short notice, given that we expect the data to be somewhere around 20-40 TB
(the capacity of the devices we seized is around 40-50 TB).
I take it from
email that he's otherwise ready to give us the data, although that certainly would be a new
development, but we're obviously hopeful that's the case. The key question then will be whether what we get from him
this time is actually usable. If it's not, I think at that point it will make sense to just have BRG do it - they can physically
take the devices themselves and do it. We had asked about that possibility from the beginning and CART was resistant,
but given the past nine months I think we should do it if necessary. But, hopefully the intervention of higher-ups solves
the problem and we can get the data in the next couple weeks, which would be great.
From:
(USANYS)
Sent: Friday, June 19, 2020 13:36
To:
Cc:
(USANYS)
Subject: FW: Epstein search warrant documents
EFTA00020213

=== Page 2 ===
Are we just talking about getting these across the street? He should not ship them.
can bring.
From:
(USANYS) [Contractor]
Sent: Friday, June 19, 2020 1:35 PM
To:
(NY) (FBI)
in
Cc:
(USANYS)
is
(NY) (FBI)
i
)
is
)
in
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Hello
I can have the drives shipped to you or if you want you can come and pick up the drives from Saint Andrews. Someone
would be available for you to meet up with between 9:30 am - 12:30 pm Monday - Friday. Please let me know which you
prefer.
Thank you.
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 1:14 PM
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
i
(NY) (FBI)
V.
)
is
>;
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
>;
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
is
)
is
(NY) (FBI)
in
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
EFTA00020214

=== Page 3 ===
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what
the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go from
there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
EFTA00020215

=== Page 4 ===
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in searchable
format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to specific devices -
so if we're able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to
get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
y.
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
>;
(NY) (FBI)
in
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
EFTA00020216

=== Page 5 ===
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
EFTA00020217

=== Page 6 ===
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
EFTA00020218

=== Page 7 ===
back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
in
Cc:
is
)
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
is
Cc:
is
)
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
EFTA00020219

=== Page 8 ===
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
i
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
i
)
V.
(NY) (FBI)
is
(USANYS)
EFTA00020220

=== Page 9 ===
Cc:
(USANYS) [Contractor]
is
is
V.
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks- it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
>;
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
EFTA00020221

=== Page 10 ===
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
is
is
)
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
EFTA00020222

=== Page 11 ===
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
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.
EFTA00020223

=== Page 12 ===
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
>;
(USANYS)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
i
is
(NY)
EFTA00020224

=== Page 13 ===
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
>;
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
)
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
V.
is
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
EFTA00020225

=== Page 14 ===
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
EFTA00020226

=== Page 15 ===
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
EFTA00020227


c1: EFTA00019051
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019051.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
)"
Cc:
(USANYS)"
)"
Subject: RE: Fedex
Date: Thu, 05 Aug 2021 13:49:18 +0000
Importance: High
Attachments: EDMRevenue_Customer_invoice_doc__Produced.xlsx
Inline-Images: image001.jpg
Good morning,
Sorry for the late response. Our IT team was not able to go back past 2007. I am attaching a spreadsheet with the
shipments on his account from 2007 - 2020 for your review. Please let me know if you have any questions or need
anything further.
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Friday, July 30, 2021 8:46 AM
To:
Cc:
(USANYS) ;
)
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Hi
Thank for your help with this inquiry. We're not sure whether this would have been the same account number during the
time period we're looking at, but the account number we have is
More broadly, we are searching for any
accounts or data associated with Ghislaine Maxwell or Jeffrey Epstein.
Thank you,
From:
Sent: Friday, July 30, 2021 9:40 AM
To:
Cc:
Subject: RE: Fedex
Importance: High
Do you have a FedEx Express account number? I am going to reach out to IT and see what they can find or have.
Thank you,
Senior Paralegal
EFTA00019051

=== Page 2 ===
Federal Express Corporation
FedEx®
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Thursday, July 29, 2021 5:02 PM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Hi
I hope all's well. Do you have a few minutes to talk tomorrow? We'd like to follow up on something with you.
Thanks,
From:
Sent: Friday, July 16, 2021 10:11 AM
To:
Subject: RE: Fedex
Good morning,
Sorry for my late response. I have been out of the office all week. I can testify if need be. Let me know if you need
anything further.
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Tuesday, July 13, 2021 2:34 PM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Thanks,
We'd like to identify a records custodian who could testify, in the event that it would be necessary.
We found the attached cover letter and certification from FedEx in 2008, in case they are helpful in finding the specific
production on your end.
Thanks,
From:
Sent: Wednesday, July 7, 2021 11:07 AM
To:
Cc:
Subject: RE: Fedex
Good morning,
Please see attached. Let me know if you need anything further.
Thank you,
EFTA00019052

=== Page 3 ===
Senior Paralegal
Federal Express Corporation
FedEx®
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Tuesday, July 6, 2021 12:33 PM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Hi
We'd like someone to sign an affidavit for now, but we'd also like to identify someone who could testify at trial if need be.
The trial is for Ghislaine Maxwell, scheduled to start in New York in November.
I've attached a proposed declaration, though if FedEx has its own standard format, that will likely work too.
Thanks,
From:
Sent: Tuesday, July 6, 2021 10:49 AM
To:
Cc:
Subject: RE: Fedex
Good morning,
I have reviewed the records and they seem to be our records. Are you needing someone to sign an affidavit or appear in
person at trial? (is this "the" Jeffrey Epstein?)
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Tuesday, July 6, 2021 9:25 AM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Hi
I hope you had a nice weekend, and thanks again for the call last week. I've attached the FedEx records for which we are
looking for a records custodian. According to a log, the U.S. Attorney's Office for the Southern District of Florida sent
FedEx a subpoena in February 2008, and the FedEx point of contact was Tracy Ferrara. If we find any front matter, like an
internal tracking number, we'll let you know.
Thanks again for your assistance with this. Please let me know if you have any questions.
EFTA00019053

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
From:
Sent: Friday, July 2, 2021 11:08 AM
To: Markevitch, Erin (CTR)
is
Subject: RE: Fedex
Thanks, Erin!
would you mind giving me a call when you have a chance? My number is 646-627-0926.
Thanks,
From: Markevitch, Erin (CTR)
Sent: Friday, July 2, 2021 11:05 AM
To:
;
)
Subject: Fedex
Hi
You have been extremely helpful in the past with me I was hoping you can lend assistance to the assistant United States
attorney,
,
I'm working with.
is ccd on this email, if you want to reply and see what she can help
with.
Thank you in advance for al your help,
Erin
Sent with BlackBerry Work
(www.blackberry.com)
EFTA00019054


c1: EFTA00019430
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019430.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Meet re: Epstein Investigation
Start Date: 2018-12-06 21:30:00 +0000
End Date: 2018-12-06 22:30:00 +0000
Location: Conference Room 646
Class: X-PERSONAL
Comment:
Date Created: 2018-12-05 01:34:02 +0000
Date Modified: 2018-12-05 01:34:02 +0000
Priority: 5
DTSTAMP: 2018-12-05 00:22:07 +0000
Attendee:
)
EFTA00019430


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: Re: Next week events
Date: Fri, 12 Jul 2019 21:55:47 +0000
Importance: Normal
There's a bail hearing on Monday?
Sent from my iPhone
On Jul 12, 2019, at 5:36 PM,
wrote:
Monday - Bail hearing for Epstein, 10am before Judge Berman
From:
Sent: Friday, July 12, 2019 8:35 AM
To:
Subject: Next week events
Good morning all. As always, please don't forget to get me your updates for next week sometime today.
Thanks,
Laura
P.S. I didn't feel like wishing anyone Happy Pecan Pie Day (although, of course, you should partake if you celebrate), but
of course, Monday is Be a Dork Day, so you could get a jump on planning your outfits now.
Chief, Criminal Division
United States Attorney's Office, SDNY
(212) 637-1117
EFTA00018270


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
(USANYS)"
N
)"
(USANYS)"
(USANYS)"
Subject: Re: US V Epstein
Date: Sat, 10 Aug 2019 23:54:42 +0000
I am looping in
and
on this question. Have you guys ever dealt with an issue like this?
Sent from my iPhone
On Aug 10, 2019, at 7:47 PM,
)
wrote:
Per the below, Epstein's counsel has asked to have a pathologist at the autopsy (and whether it can be delayed
until they're able to arrange for that. Anyone I can point them toward on that issue?? This seems way outside
our lane but not sure who else they could ask. Thanks and sorry for the unusual question.
Begin forwarded message:
From: "Miller, Michael"
Date: August 10, 2019 at 19:34:37 EDT
To:
)"
>, , "Martin G. Weinberg"
"Weingarten, Reid"
Cc:
)"
)"
Subject: RE: US V Epstein
Thanks for being available today and for getting the wheels turning for an investigation into how he died.
On a related note, we are hearing that Jeffrey's autopsy may occur tomorrow morning. We would like to
have a pathologist present for his autopsy and cannot line up someone on such short notice. Is there any
way to push the autopsy off until Tuesday to give us time to do that?
Mike
From:
Sent: Saturday, August 10, 2019 7:31 PM
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: RE: US V Epstein
Mike, Marty, Reid,
EFTA00018974

=== Page 2 ===
I just wanted to let you know that I don't expect we'll have any further updates today, and so wanted to send you a
brief note to let you know that since we hadn't otherwise been in touch since earlier this afternoon. I imagine we will
continue to be in contact in the coming days; meanwhile, I appreciate you being in touch today, and I hope the
investigations of these events will be thorough and swift.
respectfully,
EFTA00018975


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=== Page 1 ===
From:
To:
Subject: RE: MCC/Epstein Meeting
Date: Wed, 14 Aug 2019 20:45:18 +0000
Awesome. Thanks!
From:
Sent: Wednesday, August 14, 2019 4:45 PM
To:
is
;
Subject: RE: MCC/Epstein Meeting
Yes, good for us.
From:
Sent: Wednesday, August 14, 2019 4:44 PM
To:
is
Subject: RE: MCC/Epstein Meeting
Hey guys,
I assume you've probably spoken with
/the brass about this, but just want to confirm this is ok?
Thanks,
From:
Sent: Wednesday, August 14, 2019 1:14 PM
To:
>;
Subject: MCC/Epstein Meeting
Hey guys,
would like to meet 12-2pm tomorrow after the MCC visit with the brass, you two, the MCC team, and the folks
visiting from main justice/FBI/IG
(
etc.)
We'll be in the 8th floor library.
Thanks!
EFTA00019346


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=== Page 1 ===
From:
To:
Subject: Canceled: Epstein estate counsel call
Date: Fri, 25 Oct 2019 22:24:57 +0000
Importance: High
EFTA00019727


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Subject: FW: Friendly Subpoena to
Attorney
Date: Fri, 26 Mar 2021 22:59:30 +0000
Attachments: 2021.03.26,
FYI, haven't heard from Audrey.
From:
Sent: Friday, March 26, 2021 12:05 PM
To: Strauss, Audrey (USANYS)
Cc:
(USANYS)
is
(USANYS)
is
is
(USANYS)
is
Subject: Friendly Subpoena to
Attorney
Hi Audrey,
The Maxwell team would like to send the attached "friendly subpoena" to
attorney
During our interviews in Florida,
informed me that he has a copy of the settlement agreement between
and
Epstein, which resolved
2009 civil suit against Epstein.
is willing to provide us with a copy of the
agreement, but he indicated that he believes he needs a subpoena before he can do so. His firm has already provided us
with copies of all other court filings and deposition transcripts from the civil case voluntarily. The settlement agreement
resolving the case is relevant to our ongoing investigation into Maxwell's participation in the abuse of
and other
underage girls.
Thanks,
EFTA00019080


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=== Page 1 ===
From:
Subject: RE: reporter query about Epstein
Date: Tue, 09 Jul 2019 18:55:22 +0000
Importance: Normal
Got it. Thanks.
From:
Sent: Tuesday, July 9, 2019 2:54 PM
To:
Subject: FW: reporter query about Epstein
FYI
From: Ostrowski, Jeffrey
Sent: Tuesday, July 09, 2019 14:26
To:
Subject: reporter query about Epstein
I'm writing about the indictment of Jeffrey Epstein, and I wonder if the government it plans to pursue the Palm
Beach property. I'm trying to reconcile the mention forfeiture of "any property" with the lack of a specific
mention of the address or legal description of the El Brillo Way real estate.
Thanks.
Jeff Ostrowski
Reporter
The Palm Beach Post Palm Beach Daily News GateHouse Florida
This message may contain confidential and/or privileged information. If you are not the intended recipient or authorized to
receive this for the intended recipient, you must not use, copy, disclose or take any action based on this message or any
information herein. If you have received this message in error, please advise the sender immediately by sending a reply e-
mail and delete this message. Thank you for your cooperation.
EFTA00018167


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Re: wbtw
Date: Mon, 01 Jun 2020 22:39:59 +0000
Great. I was just on the phone w/
about another case. Told him we could use another person and prefer
He
said he'll talk to
and let us know, so that seems like a good sign.
From:
Sent: Monday, June 1, 2020 6:33 PM
To:
(USANYS)
Subject: RE: wbtw
Definitely has bandwidth, he has been telling me he is looking for work.
From:
(USANYS)
Sent: Monday, June 1, 2020 6:29 PM
To:
Subject: Re: wbtw
Sounds good. Any sense of
bandwidth? If he's not very busy, could use that to pitch him to the chiefs.
From:
Sent: Monday, June 1, 2020 6:18 PM
To:
(USANYS)
Subject: RE: wbtw
Hey-
That sounds good to me, thanks. I think it makes sense to discuss our theory of the case, both on the wbtw scheme and
on the possible PPE scam, just to make sure everyone is on the same page as we continue reviewing. In particular, now
that
is openly taking a salary, we should discuss materiality-I don't think those issues are prohibitive at all, but it
might be helpful to make sure everyone is attuned to those issues as we review.
In terms of staffing, can we add
? I know he'd want to do it. Apologies that I haven't been working on this case since
we moved to remote work-I reviewed emails before we left the office, but haven't continued since then. In terms of
bandwidth, Epstein/Rikers stuff has been taking up my time, although I'm hopeful that will relent a bit over the summer
(or that someone up the chain will get tired of reading memos?). More immediately, I should be able to dig into email
review probably starting next weekish. Regardless, don't be shy about passing things off to me if you think of things we
should be doing that I'm not spotting.
From:
(USANYS)
Sent: Monday, June 1, 2020 5:01 PM
To:
Subject: wbtw
EFTA00019603

=== Page 2 ===
hey - thought it made sense to check in before our call tomorrow. in terms of current status, i think we continue to review
the email returns, schedule the new financials and dig in on this covid scheme that
is doing, and probably do
another warrant (either a refresh or some new accounts).
is going to assign a GCer to do priv review, and I'm
continuing to hassle
about the iCloud returns. What's your bandwidth like? I know you're probably busy with
Epstein and Rikers stuff. We're getting close to doing a superseder in the Ukrainians case, but then I'm pretty free until my
currently scheduled trial in September (which I bet gets moved, but who knows). I think it may make sense to add a third
person to assist with email review and pushing this closer to charging. There are some people in our unit who are slow,
and/or GC is actually pretty slow except for compassionate release. On the other hand, fine to wait on this if you think we
should. Let me know.
Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
Cell:
EFTA00019604


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=== Page 1 ===
From:
"
)"
To:
)"
(USANYS)"
(USANYS)"
Cc:
)"
Subject: RE: The Prince and the Proffer I New York Law Journal
Date: Wed, 06 May 2020 23:45:34 +0000
Similarly just for awareness, albeit slightly further afield -- Judge Berman commenting, in the middle of a
random fraud sentencing, on his objections to DOJ policies and investigations post-Epstein.
https://www.nydailynews.com/new-york/ny-judge-berman-epstein-bar-bop-20200506-
a6p4hvl3tncpndjbz2pda2hsde-story.html
Original Message
From:
)
Sent: Wednesday, May 06, 2020 18:31
To:
(USANYS)
(USANYS)
Cc:
)
i
)
Subject: The Prince and the Proffer I New York Law Journal
Hi,
Just flagging this for your awareness given that this is an ongoing issue.
https://www.law.com/newyorklawjournal/2020/05/06/the-prince-and-the-proffer/
Thanks,
Sent from my iPhone
EFTA00018735


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 16, 2019
Wells Fargo Bank N.A.
Attn: Legal Order Processing Department
1090 Vermont Ave
Washington, DC 20005
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing
the existence of the subpoena to any third party. While you are under no obligation to comply
with our request, we are requesting you not to make any disclosure in order to preserve the
confidentiality of the investigation and because disclosure of the existence of this investigation
might interfere with and impede the investigation.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United
By:
Assistant United States Attorney
Southern District of New York
EFTA00019966

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Wells Fargo Bank N.A.
Attn: Legal Order Processing Department
1090 Vermont Ave
Washington, DC 20005
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 1591, 1594(c), 2422(b), 371
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1)
produced by on or before the return date to Special Agent
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
;
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please
contact Forensic Accountant
at
or Special Agent
at
with any questions.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 16, 2019
Gilby
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
UNITED COURT
FOR
Assistant United States Attorney
THE
One St. Andrew's Plaza
RICT
YORK
New York, New York 10007
Telephone:
EFTA00019967

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Wells Fargo, dated August 16, 2019)
Please provide from account inception to the present any and all records pertaining to the following
accounts(s)/organization(s)/individuals(s), whether held jointly or severally or as trustee or
fiduciary as well as custodian, executor, or guardian, to include all open and closed accounts.
Please provide all images of documents in Adobe PDF files on CDs.
A. Please use the following identifiers:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBERS:
B. Records to be produced should include but are not limited to the items listed below:
1. Data transaction files
2. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting
additions and/or subtractions to the account and how the account balances are being satisfied
on a monthly basis;
3. Signature cards;
4. Proof of identification (including but not limited to copies of identification used to open the
account);
3
EFTA00019968

=== Page 4 ===
5. Opening account(s) documents with attachments, including any and all applications, internal
documents generated to open account(s), and identification information or other
documentation provided by Customer; and Customer's email address
6. "Know your customer" documentation;
7. Wire transfer records (incoming and outgoing, and any and all applications and instructions);
8. Safe deposit records, including applications, signature cards, and sign-in records;
9. Trust accounts;
10. Monthly statements;
11. Credit card statements;
12. Bank, travelers, or cashier checks drawn on account or purchased with an account check;
13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks;
14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit
reports, applications, and payments made on loans;
15. Online banking information- All information regarding the electronic use of banking systems
to include the following: username, registration IP address, online account creation date,
online account status and IP logs/history, MAC addresses and online session times and
duration;
16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or
partnership agreements; and
17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text
messages, that reference or concern items (1) through (16), above, and/or any financial
interests involving the individuals and/or entities identified in Section A.
N.B.: Personal appearance is not required if the requested records are (1) produced by on or
before the return date to Special Agent
, Federal Bureau of Investigation, 26
Federal Plaza, New York, NY 10278, telephone
,
; and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records.
PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.
Please contact Forensic Accountant
at
or Special Agent
at
with any questions.
IMPORTANT: REQUEST FOR NON-DISCLOSURE
Due to the ongoing nature of the investigation, it is requested that you do not
disclose any information relating to this Grand Jury subpoena request to any third party.
4
EFTA00019969

=== Page 5 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. $ 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 16, 2019, and signed by Assistant
United States Attorney
,
requesting specified records of the business named
below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
EFTA00019970


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
New York, New York 10007
November 3, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
Attached please find the parties' joint request to charge and proposed verdict sheet. The
Government is docketing a redacted version today and submitting the unredacted versions to the
Court. The redline text in the documents reflect the objections of the defense. Further detail of
the parties' objections are contained in comment bubbles.
The Government has proposed the only redactions in the Request to Charge. These
proposed redactions are consistent with the three-part test articulated by the Second Circuit in
Lugosch V. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's
request to charge is a judicial document subject to the common law presumption of access, the
proposed redactions are narrowly tailored to protect the privacy interests of a third party.
The Government is also providing under seal Exhibit A, which pertains to a defense
comment. The defense informs the Government that this exhibit is a document from another case
EFTA00018881

=== Page 2 ===
Page 2
that was not itself publicly docketed and therefore is submitting Exhibit A under seal.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: s/
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (By ECF)
EFTA00018882


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: Read: US V. Epstein
Date: Thu, 25 Mar 2021 19:26:55 +0000
EFTA00020337


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=== Page 1 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
1 9MAG 6439
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
19 Cr. 490 (RMB)
)
See Attachment A
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
July 12, 2019
(not to exceed 14 days)
X
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. $ 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
days (not to exceed 30).
Juntil, the facts justifying, the later specific date of
Date and time issued:
7/11/19
S/Henry Pitman
Judge signature
City and state:
New York, NY
Hon. Henry Pitman, U.S. Magistrate Judge
Printed name and title
EFTA00018425

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00018426

=== Page 3 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a multi-story
single-family residence located at 9 East 71st Street, New York, New York, and include all locked
and closed containers found therein. A photograph of the front entrance to the Subject Premises
is included below:
Google
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex
trafficking conspiracy) (the "Subject Offenses") described as follows:
The items to be seized from the Subject Premises are any computer devices and storage
media that may contain any electronically stored information falling within the categories set forth
in Section B of this Attachment, including, but not limited to, desktop and laptop computers, disk
drives, modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners,
routers, modems, and network equipment used to connect to the Internet. In lieu of seizing any
such computer devices or storage media, this warrant also authorizes, in the alternative, the
copying of such devices or media for later review.
The items to be seized from the Subject Premises also include:
2017.08.02
EFTA00018427

=== Page 4 ===
1.
Any items or records needed to access the data stored on any seized or copied
computer devices or storage media, including but not limited to any physical keys, encryption
devices, or records of login credentials, passwords, private encryption keys, or similar information.
2.
Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or software manuals or other information
concerning the configuration of the seized or copied computer devices or storage media.
3.
Any evidence concerning the identities or locations of those persons with access to,
control over, or ownership of the seized or copied computer devices or storage media.
B. Search and Seizure of Electronically Stored Information
As set forth in Section A to this attachment, this warrant authorizes the search of the Subject
Premises for any computer devices and storage media that may contain any electronically stored
information falling within the categories set forth below:
4.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
5.
Any photographs of victims or potential victims of the Subject Offenses;
6.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger;
7.
Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usernames and passwords, user profiles, e-mail contacts, and photographs;
8.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
C. Review of ESI
Law enforcement personnel (including, in addition to law enforcement officers and agents,
and depending on the nature of the ESI and the status of the investigation and related proceedings,
attorneys for the government, attorney support staff, agency personnel assisting the government in
this investigation, and outside technical experts under government control) will create a forensic
image of the Subject Devices (if practicable) and review the ESI contained therein for information
responsive to the warrant, that is, for the materials specified in Section B of this Attachment.
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
2
2017.08.02
EFTA00018428

=== Page 5 ===
surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
"scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation⁶; and
reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section
II.A of this Attachment. However, law enforcement personnel are authorized to conduct a
complete review of all the ESI from seized devices or storage media if necessary to evaluate its
contents and to locate all data responsive to the warrant.
6 Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
keyword searches work only for text data, yet many types of files, such as images and videos, do
not store data as searchable text. Moreover, even as to text data, there may be information properly
subject to seizure but that is not captured by a keyword search because the information does not
contain the keywords being searched.
3
2017.08.02
EFTA00018429


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: Re: Cooperator info re Epstein
Date: Sat, 24 Aug 2019 18:54:01 +0000
He did, but
is the one who spoke directly with him, so he can give you the most detail. (I took
off
this, so he doesn't respond with the substance and create needless 3500.) The most significant takeaway I recall
from
summary was that
said he gave Epstein the sheets he used. But again, this is second-hand,
and
has his own issues we can discuss separately.
Sent from my iPhone
On Aug 24, 2019, at 2:38 PM,
(USANYS)
wrote:
Thanks. Did he provide more substance beyond he heard information relating to Epstein? If so, let's talk Monday.
From:
(USANYS)
Sent: Saturday, August 24, 2019 1:52 AM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
i
(USANYS)
is
(USANYS)
V.
(USANYS)
Subject: Re: Cooperator info re Epstein
Let me know if you want to meet with
and we haven't yet
decided whether to extend him a cooperation agreement.
Sent from my iPhone
On Aug 23, 2019, at 6:12 PM,
(USANYS)
wrote:
Hi
and
I just spoke with
who got a call from an aspiring cooperator at MCC named
reported that another MCC inmate known as
gave him information relating to Epstein. For
several months,
has been desperately trying to figure out how he can cooperate, often relying on second- and
third-hand information that's not actionable unless another inmate also cooperates. We can also talk in person next
week about the relative quality of his information.
I leave it to you guys to follow up with
as you see fit. I'm sure someone on this email can make
available
to you, if you want, once you get a sense of what he's about. I just don't want to unilaterally sit on this.
Have a nice weekend!
EFTA00018857

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
EFTA00018858


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: FW: U.S. V. Ghislaine Maxwell 20 Cr. 330 (AJN) submission under seal
Date: Tue, 16 Mar 2021 22:49:45 +0000
Attachments: Maxwell_Cover_Letter_3-16-21.pdf
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
Sent: Tuesday, March 16, 2021 6:34 PM
To: Nathan NYSD Chambers
Cc:
is
>;
(USANYS)
>; Christian Everdell <CEverdell@CohenGresser.com>; Laura Menninger
<lmenninger@hmflaw.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>
Subject: U.S. V. Ghislaine Maxwell 20 Cr. 330 (AJN) submission under seal
Good evening-
As set forth in the attached cover letter (to be filed via ECF)
and pursuant to Rule 2(B) of the Court's individual rules,
attached for the Court and government is an unredacted version
of the Reply Memorandum In Support of Ms. Maxwell's pending bail application.
Thank you.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main: 212-243-1100
Cell: 917-912-9698
Fax: 888-587-4737
bcsternheim@mac.com
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
EFTA00018382


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=== Page 1 ===
From:
To:
Subject: Fw: Op Stolen Globe Meeting
Date: Thu, 03 Dec 2009 17:46:17 +0000
Importance: Normal
Fyi
Sent: Thu Dec 03 12:44:32 2009
Subject: Op Stolen Globe Meeting
are meeting on Thursday, December 17th at 10:30 at the USAO in
Miami to discuss Op Stolen Globe and how we will handle a potential new investigation against Jeffrey Epstein
or others. We would like to have FBI present for the meeting. I don't know if you want the SAC to attend, or
your ASAC, or whomever, but certainly whichever agent(s) would be potentially handling such an investigation
should be there.
I am still in South Carolina and then will be in Colombia, back in West Palm Beach on the 9th. Please just let me
know whom to expect so I can let the bosses know.
Thank you.
EFTA00019172


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=== Page 1 ===
From:
To:
)"
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Date: Wed, 10 Mar 2021 23:23:55 +0000
You can send a round-robin to the Civ Div. In addition to Radar, I did an Epstein search in caseview and here are
another couple civ div matters that I think you're familiar with:
NYT V BOP, 2020V00220
Epstein victim Touhy requests, 2019V01791
FYI, FOIA litigation can be brought in the home district of the requester, or in DDC.
From:
Sent: Wednesday, March 10, 2021 5:45 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Ok thanks, that's helpful to know. How would we go about determining whether the civil division litigated any cases based
on FOIA requests to other components?
From:
Sent: Wednesday, March 10, 2021 5:44 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Oh, sorry: our FOIA Tracking Database is designed to cover FOIA requests that are directed to our Office; it
does not track FOIA requests to, e.g., the FBI, that end up in litigation in the SDNY and that our Civ Div
defends.
From:
Sent: Wednesdav. March 10. 2021 5:40 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Thanks,
could you please check your records and let us know if there are any other cases? From
S list, it
seems like at least one case is missing (there is a civil case involving a FOIA request from Radar Online).
From:
Sent: Wednesday, March 10, 2021 5:23 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
As we just discussed:
Here is what we have in our FOIA tracking database regarding Epstein FOIAs.
And also attached is the letter in PPI about discovery vs FOIA (see p. 8)
EFTA00018732

=== Page 2 ===
From:
Sent: Wednesday, March 10, 2021 5:20 PM
To:
Cc
is
>;
Subject: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Hi
Hope you're doing well.
and
and I are trying to assemble a list of every FOIA request our office has ever
received (at any point) relating to Jeffrey Epstein and/or Ghislaine Maxwell.
suggested that you'd be the
best point of contact to help us figure this out. Could you please send us the following information:
A list of all FOIA requests our office has received;
For each case, whether a production was made in response to the request; and
Who the AUSA point of contact for the request is.
That would be a big help. Please let us know if you need any information from us to run the search.
Thanks very much,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00018733


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
Subject: Fwd: [EXTERNAL] Ghislaine Maxwell Atty Likens Jail To 'Silence Of The Lambs'
Date: Thu, 04 Nov 2021 20:29:53 +0000
Seriously?
Begin forwarded message:
From: Law360 Alerts <news-q@law360.com>
Date: November 4, 2021 at 4:29:00 PM EDT
To:
(USANYS)"
Subject: [EXTERNAL] Ghislaine Maxwell Atty Likens Jail To 'Silence Of The Lambs'
Law360
In case you missed it
Ghislaine Maxwell Atty Likens Jail To 'Silence Of The Lambs'
An attorney representing Ghislaine Maxwell, former associate of Jeffrey Epstein, once again pressed a New York
federal court for her release, writing in a letter Wednesday that her prison conditions "rival scenes of Dr.
Hannibal Lecter's incarceration as portrayed in the movie, 'Silence of the Lambs."
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EFTA00018886


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=== Page 1 ===
From:
To:
)"
N. (NY) (FBI)"
Cc:
(USANYS)"
)"
Subject: Re: next steps
Date: Thu, 13 Dec 2018 21:24:28 +0000
Attachments: 301_e_66_street_DAS_search.pdf; whatsapp_search_212.533.3739.png
Attached is the negative results for whatsapp search of phone number
Additionally I've attached a DAS search for 301 E 66 Street which contains over 2000 records. Be mindful that
this is a 13 story apartment building so many of these results may be irrelevant. If we have a particular name or
apartment number I can do another search for that.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Thursday, December 13, 2018 12:35:46 PM
To:
N. (NY) (FBI)
Cc:
(USANYS);
Subject: next steps
Team,
Hope you're recovering well from yesterday! Whenever you have a moment, we were wondering if you could
take a look at the following:
Could you please send us provider information for the phone number listed in the SORNA registration? Looks
like the relevant number is
For the
number, could you please run that through WhatsApp, and take screen shots of any account that
pops up associated with that number?
In addition, could you please run database searches on 301 E. 66th Street? This is the address for a property
that appears to be owned at least in part by Epstein, and where models for Mc2 may have been provided
housing.
Thanks!
Assistant United States Attorney
EFTA00019513

=== Page 2 ===
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019514


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 16, 2019
BY EMAIL
Western Union Financial Services, Inc.
Attn: Custodian of Records
12500 E. Belford Ave, M21A2
Englewood, CO 80112
Phone Number: 866-628-5067
FBISubpoenas@westernUnion.com
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing
the existence of the subpoena to any third party. While you are under no obligation to comply
with our request, we are requesting you not to make any disclosure in order to preserve the
confidentiality of the investigation and because disclosure of the existence of this investigation
might interfere with and impede the investigation.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
Assistant United States Attorney
Southern District of New York
EFTA00019961

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Western Union Financial Services, Inc.
Attn: Custodian of Records
12500 E. Belford Ave, M21A2
Englewood, CO 80112
FBISubpoenas@westernUnion.com
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 1591, 1594(c), 2422(b), 371
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1)
produced by on or before the return date to Special Agent
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
;
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please
contact Forensic Accountant
at
or Special Agent
at
with any questions.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 16, 2019
Gilby
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
DEPARTMENT UNITED COURT
FOR
Assistant United States Attorney
THE
One St. Andrew's Plaza
RICT
YORK
New York, New York 10007
Telephone:
EFTA00019962

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Western Union, dated August 16, 2019)
For the period of inception through the present, please provide any and all available information
regarding money transfers and the purchase of money orders (including but not limited to, sender's
name and address, location of purchase, including name and address of selling agent, form of
payment used to purchase money orders, amount of money orders purchased, date and time of
purchase, the payee's name and address, the amount and currency distributed), for the following
identifiers:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
N.B.: Personal appearance is not required if the requested records are (1) produced by on or
before the return date to Special Agent
, Federal Bureau of Investigation, 26
Federal Plaza, New York, NY 10278, telephone
n
; and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records.
PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.
Please contact Forensic Accountant
at
or Special Agent
at
with any questions.
3
EFTA00019963

=== Page 4 ===
IMPORTANT: REQUEST FOR NON-DISCLOSURE
Due to the ongoing nature of the investigation, it is requested that you do not
disclose any information relating to this Grand Jury subpoena request to any third party.
4
EFTA00019964

=== Page 5 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. $ 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 16, 2019, and signed by Assistant
United States Attorney
,
requesting specified records of the business named
below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
EFTA00019965


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=== Page 1 ===
From:
)"
To:
)"
)"
Cc:
Subject: RE: travel approval request
Date: Thu, 12 Dec 2019 23:16:06 +0000
Just to clarify, I need different travel arrangements than those contained in
email. I sent a separate email with
them, but I've copied the details below just in case:
I'd like to arrange the following travel, all with refundable tickets, please:
December 15, 2019 - 11:40 AM Delta flight from JFK to LAX
December 16, 2019 - 4:15 PM United flight from LAX to IAD
December 17, 2019 - Amtrak 6:00 PM train from DC to NYC
I'd also like to book a room in the Double Tree Santa Monica for one night, checking in December 15, 2019 and checking
out December 16, 2019 in LA, please. No need for a hotel in DC, as I'll be staying with family.
We do not need a conference room for any portion of this trip.
Thank you!
From:
Sent: Thursday, December 12, 2019 6:10 PM
To:
Cc:
>;
Subject: FW: travel approval request
Hi
In connection with this trip, could you please assist with booking the following travel? Thanks!
Hotel - same as last time, the DoubleTree in Santa Monica is fine. Checking in 12/15, checking out the next day
We do not need a conference room
Outbound flight: Sunday, 12/15, departing JFK at 11:40 am on Delta, landing at LAX at 3:01 p.m.
Inbound flight: Monday, 12/16, departing LAX at 8:32 p.m. on JetBlue, landing at JFK at 4:47 a.m.
If you could please make all flights refundable, that would be great - it's possible we'll need to rebook parts of
this if witness availability changes or we're able to stay longer and meet with an additional witness.
Thanks a bunch.
From:
Sent: Wednesday, December 11, 2019 10:01 AM
To:
EFTA00019839

=== Page 2 ===
Cc:
is
is
is
is
Subject: RE: travel approval request
Approved
From:
Sent: Wednesday, December 11, 2019 9:58 AM
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips,
we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
is
>;
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling,
respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
Sent: Tuesday, October 22, 2019 13:55
To:
Cc:
is
is
is
.Alleyne
(
Subject: RE: travel approval request
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
EFTA00019840

=== Page 3 ===
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).
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
EFTA00019841

=== Page 4 ===
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.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To: Druyan law
Subject: RE: US V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Thu, 13 May 2021 03:17:57 +0000
Hi Martin,
As an update to this, the Court has issued a scheduling order for the trial. Jury selection will occur during the week of
November 15th, and the trial will begin on November 29th.
Thanks,
From: Druyan law
Sent: Tuesday, May 4, 2021 1:39 PM
To:
)
<
Subject: Re: US V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Yes, thanks,
I read of your exploits in the Times.
Good luck
MD
Sent from my iPhone
On May 4, 2021, at 10:06 AM,
> wrote:
Martin,
I hope all is well. We wanted to let you know that the Court has adjourned the trial date to the fall of 2021. We will
update you when we have more information.
Best,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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=== Page 1 ===
STATE
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 11, 2021
VIA 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 are witness materials and discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
Assistant United States Attorneys
Enclosure
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c6: pdf
c7: images
c0:
=== Page 1 ===
From: Nathan NYSD Chambers
To: Jeff Pagliuca <jpagliuca@hmflaw.com>, Laura Menninger <Imenninger@hmflaw.com>,
bcsternheim mac.com <bcsternheim@mac.com>,
"
)"
(USANYS)"
,
)"
"CEverdell@CohenGresser.com" <CEverdell@CohenGresser.com>,
)"
Subject: 20cr330, US V. Maxwell
Date: Mon, 01 Nov 2021 21:44:31 +0000
Attachments: 20cr330_Order_11.1.21.pdf
Counsel:
Attached please find an Order issued by Judge Nathan, which will be docketed tomorrow morning.
Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00019056


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=== Page 1 ===
Event: Proffer:
Organizer:
Class: X-PERSONAL
Date Created: 2025-11-26 15:25:49 +0000
Date Modified: 2025-11-26 15:25:49 +0000
Priority: 5
Attendee:
(NY) (FBI)
EFTA00019845


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Fri, 19 Nov 2021 04:06:42 +0000
Attachments:
Attached please find
The Government submits
this letter motion temporarily under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00019437


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c3: VOL00008
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c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Subject: 050D-NY-3027571_0000239.pdf
Date: Wed, 11 Nov 2020 21:47:28 +0000
Attachments: 050D-NY-3027571_0000239.pdf
Hi all,
In reviewing FBI reports from the Epstein tip line,
came across the attached report. We wanted to share this
with you in connection with the MCC guards case.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00019894


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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Call notes w/
re cellmate policy
Date: Sun, 11 Aug 2019 16:30:59 +0000
According to Lt.
who spoke with
Lt.
transferred the call to the warden.
asked if he was required to have a cellmate:
Discretionary matter;
Epstein was supposed to have a cellmate at all time per the warden.
When his cellmate was released, Epstein was in the attorney visiting area.
As a general practice, prior to the shift, the officers are briefed. The people in the SHU were supposed to
be briefed down that Epstein was supposed to have a cellmate at all time. Officers have the authority to
move cellmates. Captain was supposed to brief the Lt. who is supposed to brief down to the officers.
Don't yet know whether the captain briefed the officers.
We asked for follow-up materials relating the cellmate policy and whether this direction was committed to
writing.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00019341


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c0:
=== Page 1 ===
From:
To:
)"
)"
Cc:
)"
Subject: RE: Application for Amended SW
Date: Thu, 22 Oct 2020 17:46:06 +0000
Thanks
for the quick turnaround - looking now.
From:
Sent: Thursday, October 22, 2020 1:07 PM
To:
Cc:
is
Subject: Application for Amended SW
Chiefs,
Thanks very much for talking this morning. As discussed, attached is a draft application for an amended search warrant
correcting the FBI barcode numbers for 3 devices that were seized from Epstein's NY residence. In case it's useful, I'm also
attaching the exhibits that are referenced in the draft application.
Thanks,
EFTA00017801


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=== Page 1 ===
From:
(USANYS)"
To:
,
(USANYS)"
Subject: RE: Epstein
Date: Fri, 26 Apr 2019 20:29:19 +0000
Importance: Normal
Attachments: 2019-03-13_JE_status_memo_for_AG,_DAG.docx
Actually, I apologize - I sent you the wrong draft of memo. Please use this version instead.
From:
(USANYS)
Sent: Friday, April 26, 2019 4:13 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: Epstein
- Attached is a copy of the memo we sent down about five weeks ago along with the NPA from the Florida
prosecution which is discussed in that memo.
We'll send you later this afternoon a memo with updates in our investigation since March.
EFTA00020321


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c3: VOL00008
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=== Page 1 ===
From:
Jo" </O=FBI/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AGCJPRYO>
To: "Adele Thonn" <athonn@jeffersoncompanies.com>
Subject: RE: Conference Information
Date: Fri, 15 Apr 2011 17:19:56 +0000
Importance: Normal
Inline-Images: image001.jpg
Ms. Thonn,
Thank you for the information below on the hotels. I realize records from 12 or 13 years ago may be difficult to track
down. I appreciate you checking into to this.
I have two other quick questions, if you wouldn't mind.
Is your conference always held the same time of year? I see this year it's in late October. Also, what hotels did the
conference use in 2001?
Thank you again and have a good weekend,
SA
FBI Miami Division
505 Flagler Dr. Ste. 500
West Palm Beach, FL 33401
(561) 833-7517
(561) 650-6951 fax
From: Adele Thonn [mailto:athonn@jeffersoncompanies.com]
Sent: Friday, April 15, 2011 11:27 AM
To:
Jo
Subject: Re: Conference Information
Good morning, Ms.
For the moment I can verify for you which hotel was utilized for the Conferences
listed below. Regarding these two individuals participating, however, I'll have to get back with you. We've
transitioned through several computer databases since then and all of our paper records were destroyed at our
storage facility several years ago. I'll do some checking and get back with you hopefully early next week.
1998: Event located at Hyatt Regency, New Orleans; also used Windsor Court for sleeping rooms
1999: Event and sleeping rooms at Hyatt Regency, New Orleans
2000: Event located at Sheraton New Orleans; also used Windsor Court for sleeping rooms
On Apr 14, 2011, at 3:00 PM,
Jo wrote:
Good afternoon,
After calling 1-800-648-8411 for general conference information, the young lady there suggested that I email you as the
conference coordinator.
I am a special agent with the Miami Division/West Palm Beach Office of the FBI. The phone number below, 561-833-7517,
is the main office number in West Palm Beach, and Miami's office number is 305-944-9101. (The switchboard operators at
either number can verify my identity.)
EFTA00019163

=== Page 2 ===
I am trying to locate the financial and /or investment conference that two individuals attended in New Orleans between
approximately 1998-2000 and what hotels your conference would have used during those time periods. I believe your
conference may be the one I am looking for.
I am trying to determine if the following two individuals attended the New Orleans Investment Conference between 1998-
2000;
1. Jeffrey Epstein
2.
Any information or assistance you could provide would be greatly appreciated.
Thank you,
SA
FBI Miami Division
505 Flagler Dr. Ste. 500
West Palm Beach, FL 33401
(561) 833-7517
(561) 650-6951 fax
Adele A. Thonn
Conference Director
Jefferson Financial, Inc.
111 Veterans Boulevard, Suite 1555
Metairie, LA 70005
Direct Phone: (504) 832-3278
Main Phone: (504) 837-3033
Fax: (504) 837-4885
E-mail: athonn@jeffersoncompanies.com
Conference website: www.neworleansconference.com
Find us on
f
Facebook
Click here for New Orleans Investment Conference Facebook Page
EFTA00019164


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=== Page 1 ===
MINISTÈRE
DE LA JUSTICE
Direction des affaires criminelles et des grâces
Liberté
Égalité
Fraternité
Sous-direction de la justice pénale spécialisée
Bureau de l'entraide pénale internationale
Paris, le 9 mars 2021
Monsieur le garde des Sceaux, ministre de la Justice
à
Department of Justice (D.O.J)
Par l'intermédiaire d'Andrew FINKELMAN, magistrat de liaison
Ambassade des Etats-Unis d'Amérique à Paris
J'ai l'honneur de porter à votre connaissance que la procédure et les conditions
d'extradition sont régies en France par les articles 696 et suivants du code de procédure pénale.
L'article 696-2 de ce code prévoit ainsi que « le gouvernement français peut remettre, sur leur
demande, aux gouvernements étrangers, toute personne n'ayant pas la nationalité française qui, étant l'objet d'une
poursuite intentée au nom de l'Etat requérant ou d'une condamnation prononcée par ses tribunaux, est trouvée sur
le territoire de la République. »
L'article 694-4 précise expressément que
« L'extradition n'est pas accordée
1° Lorsque la personne réclamée a la nationalité française, cette dernière étant appréciée à
l'époque de l'infraction pour laquelle l'extradition est requise ».
Ainsi, le fait que la personne recherchée ait la nationalité française constitue un obstacle
insurmontable à son extradition. Dès lors que cette nationalité s'apprécie au moment de la
commission de l'infraction, la perte de la nationalité, postérieurement à la commission de cette
dernière, est sans incidence sur la procédure d'extradition, et ne permet pas de lever cet obstacle.
Le Chef du Bureau de l'Entraide Pénale Internationale
Philippe IAEGLÉ
Téléphone
www.justice.gouv.fr
EFTA00018723


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Ghislaine Maxwell (02879-509)
Date: Mon, 02 Nov 2020 16:21:40 +0000
Embedded: RE:_Ghislaine_Maxwell_(02879-509).msg
Sender:
Subject: RE: Ghislaine Maxwell (02879-509)
Message-Id:
To:
To:
Cc:
Cc:
EFTA00018084


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c3: VOL00008
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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Subject: RE: Daubert motion
Date: Mon, 08 Nov 2021 03:03:42 +0000
Attachments: Motion_to_preclude_Dietz_and_Loftus_v5.docx
Hi all,
Here's a version that incorporates the Loftus section. The plan is to have a draft in the chiefs' inbox when they wake up,
so if folks are still up, would love comments as you can.
I'm going to write the Rocchio section now, so that will come later.
Thanks,
From:
Sent: Sunday, November 7, 2021 8:00 PM
To:
Subject: Daubert motion
Hi team,
In the interest of expediency, here is the Daubert motion for your comments. I still need to write my section, and I'm
doing some significant revisions to the Loftus section, but the Dietz section is done -
crushed it. That's the bulk of
the motion, so feel free to read that over, and I'll send you the rest in a second round later.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00018897


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
Subject: Fwd: Epstein
Date: Thu, 25 Jul 2019 02:32:35 +0000
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: July 24, 2019 at 10:25:31 PM EDT
To:
(USANYS)"
,
(USANYS)"
Cc: "Margolin, James (USANYS) [Contractor]"
, "Biase, Nicholas (USANYS)"
Subject: Epstein
NBC 4 will run a story about Epstein tonight at 11-that he was either attacked or attempted to hurt himself.
National NBC will pick it up tonight/tomorrow. I declined to comment and didn't confirm anything.
EFTA00018393


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject: FW: Subpoena to Interlochen Center for the Arts
Date: Fri, 30 Oct 2020 13:57:26 +0000
Do you still want a call with him? This seems to answer the question we had, but Jeff has generally been very helpful, so
I'm sure he'd be happy to have a call.
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 9:06 AM
To:
)
Cc:
>;
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
H
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be available
for a call with our team next week to discuss, please?
EFTA00018434

=== Page 2 ===
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still be
grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Maurene -
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or determine.
Hope you are staying safe and healthy.
EFTA00018435

=== Page 3 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would you
please confirm that your production included all records of any tuition payments that Epstein (or his entities) made for
any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow and
will have limited availability this week, but my colleagues
and
(both cc'd) should be able to
coordinate with you as needed.
Best,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
Cc:
is
)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00018436

=== Page 4 ===
Maurene -
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein and
Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00018437


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=== Page 1 ===
From:
)"
To: Joe Nascimento
Cc:
(USANYS)"
)"
Subject: RE:
)
- Epstein
Date: Wed, 04 Aug 2021 00:48:46 +0000
Hi Joe,
Thanks so much for the quick response. Those dates work for me, but l'll confirm with the agents and get back to you
quickly to confirm the timing and make travel arrangements.
Best,
From: Joe Nascimento
Sent: Tuesday, August 3, 2021 7:46 PM
To:
Cc:
(USANYS)
is
Subject: Re:
)
- Epstein
Hi
,
I spoke with
and she hopes we can schedule the meeting for the 19th or 20th.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 3, 2021, at 10:03 AM, Joe Nascimento
wrote:
Of course, what time works best for you?
Sent from my iPhone
EFTA00018055

=== Page 2 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 3, 2021, at 10:02 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a brief call this afternoon?
Thanks,
From: Joe Nascimento
Sent: Monday, April 26, 2021 9:53 AM
To:
Cc:
(USANYS)
is
)
Subject: Re:
- Epstein
Perfect, I received the invite with the link. Unfortunately (or fortunately sometimes) WebEx has been a part a
daily part of my life the past year, so we should be OK. See you all then, let me know if you need anything
further from us in the meantime.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 26, 2021, at 9:31 AM,
)
wrote:
EFTA00018056

=== Page 3 ===
Hi Joe,
Thanks very much. Let's plan for May 14th at 12 p.m., if that works for you. I'll send a WebEx link for the
videoconference shortly. Please let us know if you have any tech issues/questions about WebEx.
Thanks,
From: Joe Nascimento
Sent: Wednesday, April 21, 2021 1:53 PM
To:
Cc:
(USANYS)
is
Subject: Re:
)
- Epstein
Good afternoon,
I spoke with
and she can make herself available the following dates:
May 3, 4 (before 2pm), 5, 6, 12, 13 or 14.
She is going to take the day off of work, so no need to do it after-hours (thank you for the offer). Let me know if you
need additional availability.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
<image001.jpg>
From:
Date: Friday, April 16, 2021 at 1:31 PM
To: Joe Nascimento
Cc:
(USANYS)
)
Subject: RE:
)
- Epstein
Thanks very much - let's plan for 9:30 a.m. on Monday, if that works for you. Should I just call your desk line, or
would you prefer a different number?
Thanks,
EFTA00018057

=== Page 4 ===
From: Joe Nascimento
Sent: Friday, April 16, 2021 1:00 PM
To:
Cc:
(USANYS)
i
)
Subject: Re:
- Epstein
Hi
,
Yes, I'm free Monday morning between 9:30 and 12 or Tuesday between 11-3. If that doesn't work for you,
I can try to move something around. Let me know.
Have a nice weekend,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 16, 2021, at 11:58 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a call sometime early next week? Nothing urgent, but we wanted to
talk with you about potentially scheduling an interview (by video conference) with your client for sometime in early
May.
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:54 PM
To:
Cc:
is
Subject: Re:
- Epstein
EFTA00018058

=== Page 5 ===
Yes, 10:30 works for me. Thank you!
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3ʳᵈ Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
From:
Date: Monday, March 8, 2021 at 1:32 PM
To: Joe Nascimento
Cc:
)
i
)
Subject: RE:
)
- Epstein
Hi Joe,
Thanks, hope all is well with you. We're free for a call at 10:30 tomorrow morning, would that work for you?
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:24 PM
To:
Cc:
>;
Subject: Re:
- Epstein
Hi
,
I hope you are well. Please let me know if you have 5 min for a quick call.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
EFTA00018059

=== Page 6 ===
t.
f.
e.
www.crimlawfirm.com
On Jul 2, 2020, at 11:09 AM,
)
wrote:
Hi Joe,
Thanks for reaching out, we were planning to email you. We continue to appreciate your client's cooperation with
our investigation, and her status from our perspective has not changed. We'll be in touch going forward, and
All the best,
From: Joe Nascimento
>
Sent: Thursday, July 2, 2020 11:07 AM
To:
Cc:
)
>;
)
Subject: Re:
- Epstein
Good morning,
Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
If you need anything
from us, let us know.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00018060

=== Page 7 ===
On Feb 21, 2020, at 3:53 PM,
)
wrote:
Joe,
We very much appreciated that, and we just wanted to let you know that the lack of communication separate
from that discussion shouldn't be interpreted in any way negatively. We'll certainly be in touch again when
we're able.
thanks again,
From: Joe Nascimento
Sent: Wednesday, February 19, 2020 15:03
To:
Cc:
>;
)
Subject: Re:
- Epstein
We really appreciate this email. I was able to speak with
a few weeks ago and gave the green light to
share
name and information provided with anyone necessary in your investigation. We will wait to
hear from you if you need anything further.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Monday, February 17, 2020 at 3:40 PM
To: Joe Nascimento
Cc:
)"
)"
EFTA00018061

=== Page 8 ===
Subject: RE:
)
- Epstein
Joe,
We just wanted to check in very briefly-we had been hopeful that we'd be able to circle back with you earlier,
but our investigation is currently still ongoing, so at the very least we wanted to let you know that we continue
to appreciate both your client's prior assistance and her willingness to assist in the future. Nothing in our
investigation since we were last substantively in touch has changed our view of your client, and we hope to be
able to be in touch with you in the coming weeks with an update. In the interim, we do continue to view her
status as we've previously conveyed, and please let us know if any issues arise on your end.
thank you,
From:
Sent: Saturday, November 30, 2019 14:42
To: Joe Nascimento
Cc:
is
Subject: Re:
- Epstein
Hi Joe,
Thanks for checking in
so no issues on our end, but we
appreciate your following up.
Thanks,
Sent from my iPhone
On Nov 30, 2019, at 8:54 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check-in as
Please let us know if you need anything from us.
Thanks,
Joe
Sent from my iPhone
EFTA00018062

=== Page 9 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 9, 2019, at 9:47 PM,
)
wrote:
Joe,
We will meet tomorrow at the same place as last time- the Hilton in West Palm Beach, on
Okeechobee Blvd. My cell is
when you arrive. My colleague,
will
be joining us, and he can be reached at
Thanks,
Sent from my iPhone
On Sep 4, 2019, at 10:46 PM, Joe Nascimento
wrote:
Yes, we will be there.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
EFTA00018063

=== Page 10 ===
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi Joe,
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
Cc:
is
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or
13th work best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this
afternoon. I'll plan to reach out then to discuss scheduling, if that's okay.
EFTA00018064

=== Page 11 ===
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check in to see if you still planned to travel south given the storm. Current
estimates show a landing (somewhere) Tuesday with very bad weather on Wednesday.
Airports might close (which will answer my question), but that's a guess.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a
hotel in West Palm Beach, and l'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
EFTA00018065

=== Page 12 ===
Both the time and date work for us. Let me know the location when you have it confirmed.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
Following up on scheduling, we were wondering if your client is available for a proffer on
September 4th. We're flexible on timing that day, but we would propose meeting at 12:30 p.m., if
that works.
Thanks,
From: Joe Nascimento
Sent: Wednesday, August 7, 2019 4:53 PM
To:
Cc:
is
^
Subject: Re:
- Epstein
Hi
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early afternoon
(anytime after 1)? I have proactive cooperation ongoing in another case involving multiple
jurisdictions, and they are looking to meet the morning of 8/14. I understand if your schedule is
already set, and will work around it.
EFTA00018066

=== Page 13 ===
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a meeting, and
we'll follow up to firm up plans as we get closer. If there are any conflicts with that date, please let
us know, we're happy to be flexible.
Thanks,
From: Joe Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
I do not have any travel plans during the month of August, nor does
September is a busy
month with two trials set, and I will be traveling out of the country from Sept 17-30, but I will do
everything to be as flexible as possible.
EFTA00018067

=== Page 14 ===
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
, "
)"
Subject: RE:
)
- Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if you
could please let us know if there are any particular weeks that would not work for you or your
client for a meeting in Florida (in particular, we don't want to interfere with anyone's summer
vacation plans).
We will of course be in touch to talk about a next meeting in more detail, but in the first instance it
would be helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
EFTA00018068

=== Page 15 ===
That works for me. Please call me on my cell
(
). Thanks.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
Following up, we were wondering if you were available for a call to discuss next steps. We're
available on Friday at 2:30, if that works, but let us know if there are other times that would be
more convenient for you.
Thanks,
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
is
;
Subject: Re:
- Epstein
Good afternoon,
It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
As always, feel free to contact me at any time if we can be of further assistance. Look forward to
meeting again.
EFTA00018069

=== Page 16 ===
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
>, ,
)"
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you
are here, and we will meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
EFTA00018070

=== Page 17 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still coordinating
logistics, and we will let you know that morning the address where we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for any
reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-
data-detectors://2/0><x-apple-data-detectors.//2/0> Avenue<x-apple-data-
detectors://2/0>
<x-apple-data-detectors.//2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
<mailto:
V
wrote:
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
EFTA00018071

=== Page 18 ===
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer
letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-
data-detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-
detectors://2/0>
<x-apple-data-detectors:/2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com http://www.crimlawfirm.com<http://www.crimlawfirm.com/
On Jul 9, 2019, at 4:56 PM,
)
<mailto:
<mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for
sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
EFTA00018072

=== Page 19 ===
Subject: Re:
)
- Epstein
Hi
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. B<x-apple-data-detectors://2/0>rd<x-apple-data-detectors.//2/0> Avenue<x-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com-htp://www.crimlawfirm.com/
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
<mailto:
<mailto:
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com http://www.crimlawfirm.com-http://www.crimlawfirm.com
From:
)"
<mailto:
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
Cc:
)"
<mailto:
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
EFTA00018073

=== Page 20 ===
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m.
on Tuesday - you can reach us at
, or we can also call you then if that's
easier, whatever you prefer.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's
set a time for Tuesday morning (the earlier the better for me). Let me know what works
for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors.//2/0>Avenuex-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com><http//www.crimlawfirm.com/
On Jul 7, 2019, at 4:04 PM,
)
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with
EFTA00018074

=== Page 21 ===
you. I expect our schedules may be somewhat unpredictable tomorrow; would it work
to set a time to talk on Tuesday? We can schedule it for before you meet with
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or
check in tomorrow about a possible afternoon discussion. Please let us know what you
prefer, and we look forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
mailto:
Subject:
)
- Epstein
My former partner, Alan Ross, represented
prior
to his passing in 2018. Agent
served
with a grand jury subpoena
earlier today, and as Alan's former partner and FL Bar appointed inventory attorney, she
has contacted me. Unfortunately, I am unable to meet with her until Tuesday, but I
would appreciate a few minutes of your time at your convenience as I am getting up to
speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
EFTA00018075

=== Page 22 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com http://www.crimlawfirm.com<http://www.crimlawfirm.com/
EFTA00018076


c1: EFTA00019615
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019615.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
tu
TransUnion
Tel (312) 985-3978
Fax (312) 985-2030
September 1, 2020
Federal Bureau of Investigation
New York, New York 10278
RE:
et al
Attached are all credit reports responsive to your request.
I certify that I am employed by TransUnion and am authorized to make this declaration on behalf
of TransUnion LLC. Attached hereto are credit report(s) identified in your request (also
attached), for individuals listed in the subpoena/court order. This information was derived from
information contained in TransUnion's computer records as of the date indicated on the report(s).
The information contained in the credit report(s) was compiled by TransUnion from various
sources in the ordinary course of TransUnion's business operations, and it is customary and
routine for TransUnion to prepare such reports in the ordinary course of business. The report(s)
were obtained from TransUnion's computer records, using the consumers identifying information
provided in the subpoena/court order and are the originals or exact copies thereof.
If you have any questions or need additional clarification regarding the information enclosed,
please review the attached subpoena guidelines. If you have any further questions, please contact
the TransUnion Subpoena Hotline at (312) 985-3978 or email
and reference the date of this letter and the information in the subject line.
Sincerely,
Litigation Support Department
Enclosure(s)
EFTA00019615

=== Page 2 ===
tu
TransUnion
Subpoena Guidelines
TransUnion Accepts the Following Documentation:
US Federal Grand Jury Subpoenas
ALL OTHER SUBPOENAS - only if so ordered by a Judge or Magistrate and stamped by the Clerk
Court Orders - must be signed by a Judge or Magistrate
Search Warrants - must be signed by a Judge or Magistrate
Summons - issued by the IRS
Authorizations - must be signed by the subject of the credit report or subject consumer's legal representative (e.g. Attorney)
Please submit the above to the attention of the TransUnion Subpoena Processing Team using ONE of the following:
Email:
Fax: (312) 985-2030 Mail: TransUnion 555 West Adams St. Chicago, IL 60661
REQUIRED INFORMATION on ALL
Requests:
Instructions for delivery of documents
First, middle & last name of consumer(s)
whose credit report is being requested (alias
Name of person to receive requested
names if applicable)
Date of birth
documents
Social security number(s) (alias #'s if
Name of agency/firm
applicable)
Address
Current and/or last known address(s)
City, state and zip code
City, state and zip code
E-mail, Fax number, or mailing address
Requests that do not contain the above
information will be automatically rejected and
will result in processing delays.
If we are unable to complete your request(s) and you
have included a check, it will be destroyed.
TransUnion does not maintain credit information on
businesses.
The consumer report information provided pursuant to your
REQUEST for FULL ACCOUNT
request may not include all information in TransUnion's
NUMBER(S):
database(s), such as prescreening inquiries, inquiries for
account review purposes and inquiries relating to medical,
utility or insurance services. If such information is required,
If requesting the "full account number(s)" for a
please specify that "ALL inquiry information, including but
consumer's account(s), please be aware that due to
not limited to prescreening inquiries, inquiries for account
security requirements and evolving industry
review purposes and inquiries relating to medical, utility or
insurance services, found in the consumer's file must be
standards for treatment of highly sensitive
returned."
Payment Card Information ("PCI"), full account
numbers may not be displayed on TransUnion
We may respond to your request via e-mail, fax, or US mail.
credit reports or disclosures, but may have one or
Please be sure to include an e-mail address, fax number, or
more digits truncated, masked or obscured.
mailing address with your request.
Further, where full account numbers do appear,
these may be scrambled or encrypted by the card
If sending via fax, hard copy is not required!
issuer, furnisher of information, and otherwise may
not reflect the actual account number.
Revised 8/8/19
EFTA00019616

=== Page 3 ===
Good afternoon,
Please find attached a grand jury subpoena. Feel free to reach out should you have any questions.
Regards,
Paralegal Specialist
U.S. Attorneyâ€™s Office I SDNY
1 St. Andrewâ€™s Plaza
New York, NY 10007
Office:
Cell:
EFTA00019617

=== Page 4 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 25, 2020
VIA EMAIL
Trans Union
Custodian of Records
555 West Adam Street
Chicago, Illinois, 60661
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing
the existence of the subpoena to any third party. While you are under no obligation to comply
with our request, we are requesting you not to make any disclosure in order to preserve the
confidentiality of the investigation and because disclosure of the existence of this investigation
might interfere with and impede the investigation.
If you intend to disclose the existence of this Grand Jury Subpoena request to a third party,
please let me know before making any such disclosure.
Thank you for your cooperation in this matter.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
By:
, Esq.
Assistant United States Attorney
EFTA00019618

=== Page 5 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Trans Union
Custodian of Records
555 West Adam Street
Chicago, Illinois, 60661
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 500 Pearl Street, Room 480 (via North elevators), in the Borough of Manhattan, City of New York,
New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
September 7, 2020
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 371, 1343, 1346
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1) produced
by on or before the return date to Special Agent
at: Federal Bureau of Investigation,
26 Federal Plaza, Squad C-4, New York, NY 10278, telephone:
or via email at
,
; and (2) accompanied by an executed copy of the attached Declaration of Custodian
of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 25, 2020
andry
AUDREY STRAUSS
Acting United States Attorney for the
Southern District of New York
HOMELAND UNITED COURT
FOR
THE
Assistant United States Attorney
RICT
YORK
One St. Andrew's Plaza
New York, New York 10007
Telephone:
EFTA00019619

=== Page 6 ===
RIDER
(Grand Jury Subpoena to Trans Union, dated August 25, 2020)
Please provide any and all credit reports, fraud alerts, and related documents pertaining to the
following individuals listed, including all known accounts and lines of credit, addresses and
personal identifying information, and all credit inquiries regarding the individuals and the
addresses provided at the time of said inquiry regardless of whether accounts were open.
1. Name:
Date of Birth:
SSN:
2. Name:
Date of Birth:
SSN:
3. Name:
Date of Birth:
SSN:
Please forward the above requested information in electronic format to:
Special Agent
Federal Bureau of Investigation
26 Federal Plaza, New York, NY 10278
Tel:
Points of contact for this request:
FBI Special Agent
FBI Special Agent
EFTA00019620

=== Page 7 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. $ 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 25, 2020, and signed by Assistant
United States Attorney
,
requesting specified records of the business named
below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
EFTA00019621

=== Page 8 ===
Subscriber Name:
INHOUSE LAW
Subscriber Code/Market:
Z 0005290 17 03
TransUnion
Results Issued:
8/31/20 15:21 CT
INPUT PARAMETERS FOR PRIMARY SUBJECT
Reference ID:
TRANSUNION CONSUMER CREDIT REPORT
SSN:
Name:
Current Address:
EFTA00019622

=== Page 9 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:21 CT
Page: 2 of 5
EFTA00019623

=== Page 10 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:21 CT
Page: 3 of 5
EFTA00019624

=== Page 11 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:21 CT
Page: 4 of 5
EFTA00019625

=== Page 12 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:21 CT
Page: 5 of 5
REPORT SERVICED BY
TRANSUNION
(800) 888-4213
P.O. BOX 1000, CHESTER, PA 19022
CONSUMER DISCLOSURES CAN BE OBTAINED ONLINE THROUGH TRANSUNION AT:
HTTP://WWW.TRANSUNION.COM
END OF TRANSUNION REPORT
Achieve more™ with TransUnion
EFTA00019626

=== Page 13 ===
Subscriber Name:
INHOUSE LAW
Subscriber Code/Market:
Z 0005290 17 03
TransUnion™
Results Issued:
8/31/20 15:24 CT
INPUT PARAMETERS FOR PRIMARY SUBJECT
Reference ID:
TRANSUNION CONSUMER CREDIT REPORT
SSN:
Name:
Current Address:
EFTA00019627

=== Page 14 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:24 CT
Page: 2 of 6
EFTA00019628

=== Page 15 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:24 CT
Page: 3 of 6
EFTA00019629

=== Page 16 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:24 CT
EFTA00019630

=== Page 17 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:24 CT
Page: 5 of 6
EFTA00019631

=== Page 18 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:24 CT
Page: 6 of 6
REPORT SERVICED BY
TRANSUNION
(800) 888-4213
P.O. BOX 1000, CHESTER, PA 19022
CONSUMER DISCLOSURES CAN BE OBTAINED ONLINE THROUGH TRANSUNION AT:
HTTP://WWW.TRANSUNION.COM
END OF TRANSUNION REPORT
Achieve moreᵀ with TransUnion
EFTA00019632

=== Page 19 ===
Subscriber Name:
INHOUSE LAW
Subscriber Code/Market:
Z 0005290 17 03
TransUnion
Results Issued:
8/31/20 15:27 CT
INPUT PARAMETERS FOR PRIMARY SUBJECT
Reference ID:
TRANSUNION CONSUMER CREDIT REPORT
SSN:
Name:
Current Address:
EFTA00019633

=== Page 20 ===
TRANSUNION CONSUMER CREDIT REPORT
Results Issued: 8/31/20 15:27 CT
Page: 2 of 2
REF ORT DT
TRANSUNION
(800) 888-4213
P.O. BOX 1000, CHESTER, PA 19022
CONSUMER DISCLOSURES CAN BE OBTAINED ONLINE THROUGH TRANSUNION AT:
HTTP://WWW.TRANSUNION.COM
END OF TRANSUNION REPORT
Achieve moreᵀ with TransUnion
EFTA00019634

=== Page 21 ===
IN THE MATTER OF
ET AL
STATE OF Pennsylvania
)
COUNTY OF Delaware
)
CERTIFICATION AND WAIVER
My name is
I am over 18 (eighteen) years of age, of sound mind, capable of
making this affirmation, and am personally acquainted with the facts herein stated:
I am currently employed as a Representative II in the Litigation Support Department of Trans
Union LLC, located at 1510 Chester Pike, Crum Lynne, PA 19022, and I am authorized to make this
declaration on behalf of Trans Union LLC. I understand that I have an absolute right to appear personally
before the Grand Jury in response to the subpoena, with expenses paid as provided by U.S. statutes, to
testify under oath, and to produce the records called for by the subpoena. Nonetheless, I choose to waive
that right.
Attached hereto are TransUnion credit reports for the individual(s) identified in your request
attached hereto, as derived from information contained in TransUnion's computer records as of the date
of the credit report(s). The information contained in the credit report(s) was compiled by TransUnion
from various sources in the ordinary course of TransUnion's business operations, and it is customary and
routine for TransUnion to prepare such reports in the ordinary course of its business. The report(s)
was/were obtained from TransUnion's computer records as of the date on the credit report(s), using the
consumer's identifying information provided in your request attached hereto. The documents attached
hereto are the originals or exact copies of the originals.
AFFIANT
September 1, 2020
DATE
EFTA00019635


c1: EFTA00017810
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017810.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Attorney who slammed Prince Andrew will 'ruthlessly pursue all leads' in Epstein probe
Date: Sun, 02 Feb 2020 01:04:44 +0000
Someone still needs to carry the podium, so we're not out of business yet.
Sent from my iPhone
On Feb 1, 2020, at 7:52 PM,
wrote:
Yeah. Pretty wild.
On Feb 1, 2020, at 7:29 PM,
wrote:
I feel like you're doing our job for us. We should have seen this and flagged it for you! It's actually a really
good piece. And you didn't contribute to it, which makes it even better. Chuck Rhoades never had a prince
ducking him!
On Feb 1, 2020, at 7:09 PM,
wrote:
https://www.dailymail.co.uk/news/article-7956539/Attorney-slammed-Prince-Andrew-ruthlessly-pursue-
leads-Epstein-probe.html
EFTA00017810


c1: EFTA00019885
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019885.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
"Strauss, Audrey (USANYS)"
Cc:
(USANYS)"
Subject: FW: DOJ ongoing Investigation.
Date: Fri, 14 Feb 2020 17:32:18 +0000
Inline-Images: image543915.jpg; image517195.jpg
From:
Sent: Friday, February 14, 2020 12:17 PM
To:
(USANYS)
i
(USANYS)
Cc:
is
Subject: FW: DOJ ongoing Investigation.
FYI
From: Gary Bloxsome
Sent: Friday, February 14, 2020 12:00
To:
is
-
>; Daniel
Cundy
; ; Jennifer Richardson
;
Subject: DOJ ongoing Investigation.
Dear
We and the Duke of York set out to assist your investigation when the DOJ asked for his help in January 2020.
However, we regret to say that we have reached the conclusion that the DOJ's dealings with the Duke of York
have not been designed to seek his assistance in investigating and prosecuting the targets of the investigation but
instead have been used only to gather publicity for Mr Geoffrey S. Berman, the United States Attorney for the
Southern District of New York.
It is essential, if justice is to be done for Epstein's victims, that a proper and thorough criminal investigation is
carried out. Although the public record indicates your office (SDNY) has been actively investigating Mr. Epstein
and other targets for more than 2 years, the first time you ever attempted to make contact and request The Duke
of York's help was on 2 January 2020.
The Duke instructed my firm to make contact with you pertaining to this request. When we made contact, you
confirmed that the Duke of York was not and is not a target of the US criminal investigation.
EFTA00019885

=== Page 2 ===
Due to the publicity surrounding the investigation, we asked you to confirm that our discussions and any
interview arrangements would remain confidential, in accordance with your rules. The Duke did not want to add
to the media circus that has now surrounded the investigation. On 10 January 2020 you confirmed
that any arrangements would indeed be kept confidential.
We indicated that we would refer back to you once we had dealt with the various issues and procedures, which
would need to be addressed to enable the Duke to cooperate to the fullest extent possible, including the need to
obtain all the information that you might need to consider. It was at that time that we informed you, by email
dated 20 January, that such preliminary issues would be dealt with within 14 days. It was also in that email that
we confirmed that The Duke has a strong desire to cooperate with the ongoing investigation by the DOJ.
Instead of waiting to hear from us (as you indicated on 22 January 2020), Mr Geoffrey S. Berman, the United
States Attorney for the Southern District of New York, chose to make a public statement about the Duke on 27
January 2020. This led to press reports that there had been "a wall of silence" and that there had been "zero co-
operation" by the Duke. These statements were not true. They should not have been made.
Quite apart from your promise of confidentiality, in England it would not be thought to be in the interests of
justice for any prosecutor or investigator to make public statements about witnesses who may be willing, in
confidence, to assist their investigation.
In England, prosecutors and investigators try to make sure that the investigation and trial of serious criminal
cases take place in court and not in press conferences or publicity battles.
When we complained about the way the Duke (and we) had been treated by the DOJ, you refused to
apologise and you have now also gone back on your promise that any arrangements for the interview will be
confidential.
We cannot advise the Duke to speak to prosecutors who cannot be trusted to deal with him fairly nor to treat
what he says or does confidentially. He has reluctantly accepted our advice that, in those circumstances, there is
no purpose to be served in continuing to try to assist further.
Finally we have no wish to engage in any further publicity battle about the DOJ's conduct and for that reason we
ask that you treat this email as private and confidential.
Regards
Gary
Gary Bloxsome
Partner
Blackfords LLP 15 Old Bailey London EC4M 7EF
DX 161400 Old Bailey 5 020 3427 3343 I www.blackfords.com
EFTA00019886

=== Page 3 ===
RANKED IN
Chambers
LEGAL
UK
500
UNITED
2020
TOP TIER
Leading Firm
2020
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint
Walk, Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00019887


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018962.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Automatic reply: Epstein update
Date: Sat, 10 Aug 2019 13:29:40 +0000
Okay, thanks. Keep us posted.
Sent from my iPhone
On Aug 10, 2019, at 9:24 AM,
wrote:
I spoke with him, and he wasn't able to provide me with any additional information beyond what we knew. He
said he was on his way to MCC to learn more and would call me with updates throughout the day.
Sent from my iPhone
On Aug 10, 2019, at 9:22 AM,
wrote:
Can you give one of us a call when you get off with
? Thanks
Sent from my iPhone
On Aug 10, 2019, at 8:45 AM,
wrote:
FYI. This is all the information I have- trying to find out more. Will keep you updated.
Sent from my iPhone
Begin forwarded message:
From:
Date: August 10, 2019 at 8:17:53 AM EDT
To:
Subject: FW: Automatic reply: Epstein update
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
EFTA00018962

=== Page 2 ===
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
> wrote:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00018963


c1: EFTA00018171
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018171.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: defendant bail submission
Date: Thu, 11 Jul 2019 16:38:37 +0000
Importance: Normal
Attachments: Epstein_bail_memo_and_attachments.pdf
I just got back to my desk from court and now have to go back (swearing out the latest warrant at 12:45) so I haven't read
it yet, but attached here.
Assistant U.S. Attorney
Southern District of New York
EFTA00018171


c1: EFTA00019096
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019096.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Financial Times <info@stories-features.ft.com>
To:
Subject: Your personalised recommended reads
Date: Thu, 13 Feb 2020 11:38:42 +0000
FINANCIAL TIMES
To view online click here.
Your recommended reads
Breaking News
China reports sharp rise in coronavirus cases
Brussels takes aim at 'black box' of online political adverts
US attorney-general called to testify on political interference claims
Salvini loses immunity and faces trial for blocking migrant boat
World News
EFTA00019096

=== Page 2 ===
Barclays' Jes Staley probed over links to Jeffrey Epstein
Can the world kick its oil habit?
Markets
Greek 10-year bond yield falls below 1% for first time
Trader Anil Prasad to shut Silver Ridge hedge fund
Want to receive different headlines?
If these regional and business headlines are not your preferred news items, you can
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EFTA00019097

=== Page 3 ===
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This email was sent by a company owned by Financial Times Group Limited (FT Group), registered office at Bracken
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EFTA00019098


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c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019047.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Fedex
Date: Fri, 30 Jul 2021 13:14:32 +0000
Inline-Images: image001.jpg
Gave her a quick call. Shipping information only goes back five years, but she isn't sure whether other types of records
(billing, etc.) might go back earlier in time. She said she would check and get back to us.
From:
Sent: Friday, July 30, 2021 8:43 AM
To:
Cc:
Subject: RE: Fedex
Good morning!
I am available now until 1pm CST. Feel free to call anytime before 1pm.
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx®
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Thursday, July 29, 2021 5:02 PM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Hi
I hope all's well. Do you have a few minutes to talk tomorrow? We'd like to follow up on something with you.
Thanks,
From:
Sent: Friday, July 16, 2021 10:11 AM
To:
)
Subject: RE: Fedex
Good morning,
Sorry for my late response. I have been out of the office all week. I can testify if need be. Let me know if you need
anything further.
Thank you,
Senior Paralegal
EFTA00019047

=== Page 2 ===
Federal Express Corporation
FedEx®
Express
Legal Department
Fed
Memphis, TN 38125
(t)
From:
)
Sent: Tuesday, July 13, 2021 2:34 PM
To:
Cc:
)
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Thanks,
We'd like to identify a records custodian who could testify, in the event that it would be necessary.
We found the attached cover letter and certification from FedEx in 2008, in case they are helpful in finding the specific
production on your end.
Thanks,
From:
Sent: Wednesday, July 7, 2021 11:07 AM
To:
Cc:
Subject: RE: Fedex
Good morning,
Please see attached. Let me know if you need anything further.
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx®
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Tuesday, July 6, 2021 12:33 PM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Hi
We'd like someone to sign an affidavit for now, but we'd also like to identify someone who could testify at trial if need be.
The trial is for Ghislaine Maxwell, scheduled to start in New York in November.
I've attached a proposed declaration, though if FedEx has its own standard format, that will likely work too.
Thanks,
From:
Sent: Tuesday, July 6, 2021 10:49 AM
To:
Cc:
Subject: RE: Fedex
Good morning,
EFTA00019048

=== Page 3 ===
I have reviewed the records and they seem to be our records. Are you needing someone to sign an affidavit or appear in
person at trial? (is this "the" Jeffrey Epstein?)
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx
Express
Legal Department
Memphis, TN 38125
(t)
From:
)
Sent: Tuesday, July 6, 2021 9:25 AM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious
origin.
Hi
I hope you had a nice weekend, and thanks again for the call last week. I've attached the FedEx records for which we are
looking for a records custodian. According to a log, the U.S. Attorney's Office for the Southern District of Florida sent
FedEx a subpoena in February 2008, and the FedEx point of contact was Tracy Ferrara. If we find any front matter, like an
internal tracking number, we'll let you know.
Thanks again for your assistance with this. Please let me know if you have any questions.
Assistant United States Attorney
Southern District of New York
New York, New York 10007
From:
)
Sent: Friday, July 2, 2021 11:08 AM
To: Markevitch, Erin (CTR)
Subject: RE: Fedex
Thanks, Erin!
would you mind giving me a call when you have a chance? My number is
Thanks,
Andrew
From: Markevitch, Erin (CTR)
Sent: Friday, July 2, 2021 11:05 AM
To:
-
Subject: Fedex
Hi
You have been extremely helpful in the past with me I was hoping you can lend assistance to the assistant United States
attorney,
I'm working with.
is ccd on this email, if you want to reply and see what she can help
with.
Thank you in advance for al your help,
Erin
EFTA00019049

=== Page 4 ===
Sent with BlackBerry Work
(www.blackberry.com)
EFTA00019050


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c0:
=== Page 1 ===
Event: Meet re: Epstein Investigation
Start Date: 2018-12-06 21:30:00 +0000
End Date: 2018-12-06 22:30:00 +0000
Organizer:
Location: Conference Room 646
Class: X-PERSONAL
Date Created: 2018-12-05 00:29:41 +0000
Date Modified: 2018-12-05 00:29:41 +0000
Priority: 5
DTSTAMP: 2018-12-05 00:22:07 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00019426


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c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York - concession by
Epstein's attorney that NPA only applies in Florida
Date: Wed, 07 Aug 2019 19:15:58 +0000
Thanks very much for sending this along - we had seen it in the filings in the CVRA case, but given the volume of materials
involved in that and other related proceedings, we're always on the lookout for (and appreciate being directed toward)
additional relevant information. So thank you again, and I'm sure we'll continue to be in touch.
regards,
From:
Sent: Wednesday, August 07, 2019 15:07
To:
Cc:
in
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York - concession by Epstein's attorney
that NPA only applies in Florida
Hi
You and the team there may have already seen this, but in view of the importance of the issue, I wanted to pass it along.
Attached is the transcript of the hearing from Florida state court in 2008, in which Epstein pled guilty to Florida state
charges. During the course of questioning by the judge, Epstein's Florida attorney (Jack Goldberger) stated (on Epstein's
behalf) that the NPA contained an obligation by the U.S. Attorney's Office for the Southern District of Florida "not [to]
prosecute Mr. Epstein in the Southern District of Florida See page 38 (emphasis added). I wanted you to be sure to
have this information, as the subject is likely to be important.
for Jane Doe 1
(phone)
(fax)
You can access my publications on
CONFIDENTIAL: This electronic message along with any/all attachments - is confidential. This message is intended only for the use of the
addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this
message in error, please immediately notify the sender by reply electronic mail and delete the original message.
is admitted to the
Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own.
From:
Sent: Thursday, July 25, 2019 8:25 PM
EFTA00019854

=== Page 2 ===
To:
Cc:
is
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York
Will do.
From:
Sent: Thursday, July 25, 2019 22:24
To:
Cc:
is
)
Subject: Re: Briefing in Florida regarding whether the Florida NPA extends to New York
Perfect - call my cell - -
- sent from my iPhone - please excuse brevity and errors.
On Jul 25, 2019, at 8:21 PM,
)
wrote:
Thanks very much. Would 10:00 a.m. tomorrow your time (noon our time) work? If so, we can call you then at
or if not, we could also do 2:00 p.m. your time.
thanks,
From:
Sent: Thursday, July 25, 2019 22:13
To:
Cc:
is
)
Subject: Re: Briefing in Florida regarding whether the Florida NPA extends to New York
Happy to chat tomorrow. Name your time that's convenient for you.
- sent from my iPhone - please excuse brevity and errors.
On Jul 25, 2019, at 8:07 PM,
)
<
wrote:
Thank you for sending us these materials, we appreciate being able to stay up to date, and we'll continue to keep an
eye on the docket for submissions that may be relevant for our investigation.
Separately, might you be available for a quick call sometime tomorrow (Friday) or next week? No rush or emergency,
but we wanted to talk with you about a question in connection with your expertise on the CVRA generally. At your
convenience.
thanks,
From:
Sent: Thursday, July 25, 2019 13:01
To:
Cc:
is
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York
EFTA00019855

=== Page 3 ===
Hi
I wanted to make you aware of a recent filing (on Tuesday) by Jane Doe 1 and 2 in the Florida CVRA case. See
attached. You may find interesting our argument at pp. 3-6, in which we explain why Judge Marra must craft remedies
in the case that relate solely to Florida crimes and Florida victims because the NPA only covers Florida.
We filed our reply brief on remedies on Tuesday - and that should have brought all briefing on remedies for the CVRA
violation to a close. But yesterday Epstein's lawyer (Marty Weinberg) filed a motion for a sur-reply. See attached. In
point (a) on page 2, he argues that he should have an opportunity to file a sur-reply discussing, among other things,
the scope of the NPA. On Monday, we will be filing an opposition to Weinberg extending the briefing further. It
appears that Judge Marra is poised to rule rapidly on the motion for a sur-reply, as he asked for us to respond quickly.
I wanted to make you aware of these developments. My clients were told back in 2013 that the NPA did not extend to
New York or other jurisdictions - and that is the point we are making to Judge Marra.
for Jane Doe 1 and 2
(phone)
(fax)
You can access my publications on
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the
addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this
message in error, please immediately notify the sender by reply electronic mail and delete the original message.
is admitted to
the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own.
EFTA00019856


