# docs_fts_content

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=== Page 1 ===
From:
)"
To:
(NYPD)"
Cc:
(NY) (FBI)"
(USANYS)"
Subject: FW: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Tue, 09 Mar 2021 20:32:32 +0000
Attachments: 2021.03.08_LAM_Letter_to_USAO_re_evidence_view_(F).pdf;MM-
108062_Miami_Inventory.xlsx
Inline-Images: image001.jpg
Hi
Thanks very much for chatting this afternoon. To recap:
By tomorrow: Please check to see whether it would be possible to prepare all of the "HIGHLY CONFIDENTIAL"
nude/partially nude images and videos from the search of Epstein's devices for Maxwell and her counsel to review
at 500 Pearl by next Wednesday or Thursday. If that is not feasible, please let me know how much time you need
to prepare those materials for review.
Please confirm that the only categories of "HIGHLY CONFIDENTIAL" nude/partially nude images in our custody that
have not been produced to the defense are (1) the images seized from Epstein's NY and USVI residences, which
were already loaded onto a laptop and brought by the FBI to the MDC for Maxwell to review, and (2) the images
and videos seized from Epstein's devices.
Attached is the inventory you all provided us detailing the physical evidence items from the FBI-Florida
investigation. Please confirm that no items from the Florida case are missing from this index.
Please provide us with a similar inventory of all physical evidence items in FBI-NY custody gathered during our
investigation.
Please work with
to figure out the logistics of how to allow defense counsel and (where possible) Maxwell
at 500 Pearl Street to review the physical items in the FBI's custody.
Thanks,
From: Laura Menninger
Sent: Monday, March 8, 2021 2:03 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca
>; ; Christian R Everdell - Cohen & Gresser LLP
(
>; ; 'BOBBI C STERNHEIM'
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
EFTA00025204

=== Page 2 ===
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00025205


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=== Page 1 ===
From:
To:
Subject: FW: Jeffrey Epstein FOIA cases - time sensitive ISO
Date: Wed, 17 Mar 2021 12:52:34 +0000
Original Message
From:
Sent: Wednesday, March 17, 2021 8:44 AM
To:
Subject: Jeffrey Epstein FOIA cases - time sensitive ISO
If you have or had one, please let me know ASAP.
I already have
case before PAE.
Thanks.
Sent from my iPhone
EFTA00024025


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=== Page 1 ===
From:
"
)"
To:
"
)"
Subject: agents contact info (Epstein case)
Date: Mon, 31 Dec 2018 18:59:48 +0000
Importance: Normal
:
office:
cell:
(NYPD / FBI TFO)
office:
cell:
Assistant U.S. Attorney
Southern District of New York
EFTA00026770


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=== Page 1 ===
From
USANYS)"
To
Bec:
USANYS)"
Subject: Fwd: NYTimes.com: Jeffrey Epstein's Mystery Bank Came Alive After His Death
Date: Wed, 04 Mar 2020 14:12:25 +0000
Begin forwarded message:
From:
(USANYS)"
Date: March 3 2020 at 1:32:01 PM EST
To:
(USANYS)"
Subject: NYTimes.com: Jeffrey Epstein's Mystery Bank Came Alive After His Death
From The New York Times:
Jeffrey Epstein's Mystery Bank Came Alive After His Death
Southern Country International received millions of dollars from Mr. Epstein's estate in December.
https://www.nytimes.com/2020/02/04/business/jeffrey-epstein-estate-bank.html
EFTA00024753


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=== Page 1 ===
From: "Tyler Blint-Welsh, WSJ" <access@interactive.wsj.com>
To:
Subject: Notes on the News: Apollo's Black to Quit as CEO After Probe of Ties to Epstein
Date: Tue, 26 Jan 2021 11:02:45 +0000
Trouble viewing this email? View in web browser )
The Wall Street Journal.
EFTA00026467

=== Page 2 ===
G
ood morning and welcome to Notes on the News.
It's Tuesday, Jan. 26. Here's what you should
know today: Leon Black is stepping down, Moderna is
testing a vaccine booster shot as new virus strains
spread and Dominion Voting is suing Rudy Giuliani
for $1.3 billion.
Let us know what you think by replying to this email.
What's News
EFTA00026468

=== Page 3 ===
PHOTO: LUCY NICHOLSON/REUTERS
1. Apollo's Leon Black will exit following probe. The fund's chief executive
will cede his role by July 31 after an independent report found he had made a larger-
than-expected $148 million payment to Jeffrey Epstein for legitimate advice. Black
wasn't involved in the disgraced financier's criminal activities, the report said.
2. Senate confirms Janet Yellen as treasury secretary. The former Fed
chairwoman will spearhead President Biden's push for a $1.9 trillion economic relief
package, which provides for another round of direct stimulus payments, extended
and enhanced jobless benefits, funding for schools and first responders and the
creation of a nationwide vaccination program.
3. Article of impeachment sent to the Senate for second Trump trial. The
case is expected to highlight the rifts within the GOP over former President Donald
EFTA00026469

=== Page 4 ===
Trump's legacy and his future influence over the party. However, many aides were
skeptical that 17 Republican senators would join all Democrats and vote to convict
him.
4. Amazon continues its U.S. expansion. The tech giant is planning to add
3,000 employees in the Boston area, one of a number of expansions of technology
jobs in major American cities. The jobs will include roles in technology and software
development.
5. Saved stimulus checks are expected to help spur an economic
recovery. Many households have boosted their savings during the pandemic, and
the pent-up demand for services like travel and dining is expected to propel
economic growth once vaccines become widespread.
E WSJ NEWS EXCLUSIVE
6. Business Insider's pandemic strategy paid off. Many business leaders
responded to the Covid-19 crisis with a flurry of activity and strategy shifts, but the
business-news site chose to do nothing and let the storm pass. It generated 30%
revenue growth in 2020, benefiting from a burgeoning subscription business and a
form of automated advertising.
7. Judge approves $17 million fund for Harvey Weinstein victims. Women
who have accused the former Hollywood producer of sexual misconduct are expected
on average to receive hundreds of thousands of dollars under the deal.
Compiled by Bryony Watson in London.
Latest on the Coronavirus Pandemic
Latest: New U.S. cases stay below 200,000 for ninth day in a row.
Delays in vaccine deliveries damp the prospect of a normal summer in Europe.
Biden says the U.S. could be heading toward herd immunity by summer.
Oxygen shortages are contributing to Covid-19 deaths.
By the Numbers
EFTA00026470

=== Page 5 ===
ILLUSTRATION: TAMMY LIAN
13% - The approximate share of the U.K.'s gross domestic product that comes
from recreation, culture and hospitality spending-a higher amount than any other
G-7 economy. As the pandemic hammered in-person businesses last year, the U.K.'s
economy shrank more than all other G-7 nations-the U.S., France, Germany, Italy,
Canada and Japan.
19.2% - The rate at which National Football League teams have attempted a
fourth-down conversion this season, the highest frequency since at least 1991. In the
NFL, such conversion attempts used to be rare, but the increased use of data
analytics in the league has seen teams increasingly realize that it can sometimes be a
savvy move. The Kansas City Chiefs and the New England Patriots both recently
advanced to the Super Bowl by using that tactic.
EFTA00026471

=== Page 6 ===
$20 - The value of the bill that could soon bear the face of abolitionist Harriet
Tubman. The White House said it would restart efforts to put her face on the
currency after the Trump administration postponed those plans.
Advertisement
The Data Point
EFTA00026472

=== Page 7 ===
GameStop's stock is reaching new heights. Prompted in part by a popular
Reddit forum, individual investors are buying up the videogame retailer's stock,
facing off with those on Wall Street who were holding short positions. The rally
resulted in a short squeeze, which is when rising prices prompt investors to buy back
shares they had sold short to cut their losses, pushing the stock higher still. At its
peak on Monday, GameStop's share price surged as much as 145% to hit $159.18.
What Everyone Wants to Know
PHOTO: JEFF KOWALSKY/AGENCE FRANCE-PRESSE/GETTY IMAGES
Dominion Voting Systems is suing Rudy Giuliani for $1.3 billion.
EFTA00026473

=== Page 8 ===
The election-equipment maker claims in a defamation lawsuit that former President
Trump's personal lawyer and his allies spread false allegations against the company
that "foreseeably went viral and deceived millions of people into believing that
Dominion had stolen their votes and fixed the election." Dominion's voting machines
are used by more than 40% of U.S. voters. Since November, Trump allies, right-wing
media personalities and others have targeted the company with unsubstantiated
allegations that it rigged the vote, and the company says its employees have received
death threats. Giuliani, who led Trump's legal team during his string of failed court
challenges to states' vote counts, was among the highest-profile promoters of
allegations against Dominion. He said the lawsuit was "another act of intimidation
by the hate-filled left-wing to wipe out and censor the exercise of free speech."
The pandemic has prevented many refugees from resettling.
Nearly 1.5 million refugees were in urgent need of resettlement through the United
Nations last year, but just 22,770 people had the chance, according to the U.N.
Restrictions on international travel meant that refugees who had already waited
years for asylum requests to be granted were forced to wait months for national
borders to reopen to them. Last year saw the lowest number of refugees resettled
since at least 2003, and those entering the U.S. fell to the lowest level in the 40-year
history of its refugee program after the Trump administration capped admittances.
Moderna is developing a vaccine booster shot for the South African
coronavirus strain.
The drugmaker said its Covid-19 vaccine appeared to protect against emerging
variants of the coronavirus in lab tests. As a precaution, however, it is working to see
whether a booster shot improves immune responses, and the company said it could
develop a new vaccine targeting the strain first identified in South Africa. A variant
that also appears to be more deadly has been identified in the U.K. and the U.S. The
new strains appear to spread more easily, and if existing vaccines do produce a
weaker immune response, the virus could continue to mutate significantly as
countries inoculate more of their populations. The South African variant hasn't been
identified in the U.S., and to curb the spread of new strains, Biden restricted travel
from South Africa and re-established a ban on most travel into the U.S. from Europe,
the U.K. and Brazil.
In Case You Missed It
EFTA00026474

=== Page 9 ===
Italy's prime minister is set to resign as the country battles Covid-19 and a
recession.
AMC has secured $917 million in new financing to help it avoid bankruptcy.
The pandemic might reshape men's fashion.
Budweiser isn't running a Super Bowl ad this year.
Take a Break
PHOTO: BRANTLEY GUTIERREZ
Go listen to: "Medicine at Midnight," the Foo Fighters' newest album, out on
Feb. 5.
EFTA00026475

=== Page 10 ===
Today's newsletter was curated by Tyler Blint-Welsh in New York, in collaboration
with colleagues in New York and London.
We hope you're enjoying the daily Notes on the News. If you would prefer to receive
a different newsletter, please check out all your options to keep up with the latest on
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All Rights Reserved.
EFTA00026476


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=== Page 1 ===
From:
To:
Subject: RE: RE: for the AUSA handling the new investigation
Date: Mon, 13 Jul 2020 23:11:05 +0000
Embedded: RE:_for_the_AUSA_handling_the_new_investigation.msg RE:_Epstein.msg; Epstein.msg
Man, that spelling was not included in my searches. So the answer is that I unfortunately don't currently have an
independent memory of it. However, reconstructing the communications, it looks like at 4:50 p.m.
connected us
with
SSA of C-19, via email. At 5:15 p.m.,
sent an email to me,
and
saying it was nice
speaking with us and thanking us for offering assistance in the investigation, and copying his agents on the case
(
and
Then at 5:59 p.m., I sent an email to those agents copying you as their point person.
I don't remember whether I actually spoke with the line agents,
,
or some combination of both, but I think it's most
likely that we spoke with
given
email at 4:50,
email to the three of us at 5:15 referring having
spoken with us, and my email to
about the info from C-19 at 5:34. The originals of those emails are all attached.
Let me know if any other info would be useful? And I'm sorry I didn't recall this when we talked on the phone earlier.
From:
Sent: Monday, July 13, 2020 18:57
To:
Subject: FW: RE: for the AUSA handling the new investigation
Do you have any record/memory of who from C-19 told you this?
From:
Sent: Monday, July 13, 2020 6:52 PM
To:
Subject: FW: RE: for the AUSA handling the new investigation
From:
Sent: Saturday, August 10, 2019 5:34 PM
To:
Cc:
Subject: RE: for the AUSA handling the new investigation
We just got word from C-19 that Epstein made a phone call last night to Kristina Schuliak (ph), who is his current / latest
girlfriend, around 7:00 p.m. The agents contacted her, she said she wanted a lawyer, and the agents have now heard from
her lawyer who says she'll tell them about the content of the phone call but she wants some kind of protections. It
sounds like the girlfriend is willing to talk sooner rather than later, so whenever someone is assigned to the new
investigation, we can put him or her in touch with that agent for whatever follow-up is appropriate.
thanks,
EFTA00024495

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00024496


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: Re:
- Epstein
Date: Sun, 07 Jul 2019 22:50:40 +0000
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,
Sent from my iPhone
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza
4th Floor
Miami Florida 33129
t
f.
e.
www.crimlawfirm.com
On Jul 7, 2019, at 4:04 PM,
)
wrote:
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules may
be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for before
you meet with Ms.
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check in
tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being in
touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Saturday, July 06, 2019 22:55
To:
Subject:
- Epstein
EFTA00026628

=== Page 2 ===
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
- Epstein
Mr.
My former partner,
, represented
(now known as
), prior to his passing in
2018. Agent
served Ms.
with a grand jury subpoena earlier today, and as
former
partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet
with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am getting
up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
Miami Florida 33129
f.
e.
www.crimlawfirm.com
EFTA00026629


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=== Page 1 ===
From:
To: "Weinstein, Marc A.
Cc: Andrew Tomback
Bcc:
Subject: RE: SDNY investigation
Date: Fri, 02 Oct 2020 14:39:13 +0000
Embedded: RE:_SDNY_investigation.msg
Sender:
Subject: RE: SDNY investigation
Message-Id:
EFTA00023698


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=== Page 1 ===
SEAL
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
October 26, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No. 02879-509)
MDC Brooklyn
Metropolitan Detention Center
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the disc containing witness materials and discovery pertinent to Ghislaine
Maxwell (02879-509) is
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00024223


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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
July 8, 2019
VIA ECF
The Honorable Henry Pitman
United States District Court
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Pitman:
The Government respectfully submits this letter in advance of the bail hearing scheduled
for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should
order that the defendant be detained pending trial; he cannot meet his burden of overcoming the
presumption that there is no combination of conditions that would reasonably assure his continued
appearance in this case or protect the safety of the community were he to be released.
As set forth below, the charges in this case are exceptionally serious: the defendant is
alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years,
and he now faces a potentially massive prison sentence predicated on substantial and multifaceted
evidence of his guilt. In light of the strength of the Government's evidence and the substantial
incarceratory term the defendant would face upon conviction, there is an extraordinary risk of
flight, particularly given the defendant's exorbitant wealth, his ownership of and access to private
planes capable of international travel, and his significant international ties. Indeed, the arrest of
the defendant occurred when he arrived in the United States on his private jet after having returned
from a multi-week stay abroad.
Finally, and as detailed herein, the Government has real concerns-grounded in past
experience with this defendant-that if allowed to remain out on bail, the defendant could attempt
to pressure and intimidate witnesses and potential witnesses in this case, including victims and
their families, and otherwise attempt to obstruct justice. As a result, he poses both an acute danger
to the community, including some of its most vulnerable members, and a significant risk of flight.
The defendant thus cannot overcome the statutory presumption that detention is appropriate in this
case, and the Court should order that he be detained pending trial.
EFTA00024584

=== Page 2 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 2
BACKGROUND
A. Overview
On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed
indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors,
in violation of 18 U.S.C. $ 1591, and one count of conspiracy to commit sex trafficking of minors,
in violation of 18 U.S.C. $ 371.
As charged by the grand jury, the facts underlying the charges in the Indictment arise from
a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the
defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he
paid the victims hundreds of dollars in cash.
He undertook this activity in at least two different locations, including his mansion in
Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the
"Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in
similar ways. Victims were initially recruited to provide "massages" to the defendant, which
would be performed nude or partially nude, would become increasingly sexual in nature, and
would typically include one or more sex acts, including groping and direct or indirect contact with
victims' genitals. The defendant paid his victims hundreds of dollars in cash for each separate
encounter.
Moreover, the defendant actively encouraged certain of his victims to recruit additional
girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying
these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this
fashion, the defendant created a vast network of underage victims for him to exploit, in locations
including New York and Palm Beach.
The defendant's victims were as young as 14 years old when he abused them. Many of his
victims were, for various reasons, often particularly vulnerable to exploitation. The defendant
intentionally sought out-and knew that he was abusing-minors. Indeed, in some instances, his
victims expressly told him they were underage before or during the period in which he abused
them.
In creating and maintaining a network of minor victims whom he abused, the defendant
worked with others, including employees and associates who facilitated his exploitation of minors
by, among other things, contacting victims and scheduling their sexual encounters with the
defendant, both in New York and in Florida.
B. The Defendant
Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant
and through his direction of others, including certain of his employees, to further facilitate his
rampant abuse of underage girls.
EFTA00024585

=== Page 3 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 3
As has been widely reported, the defendant is extraordinarily wealthy, and he owns and
maintains luxury properties and residences around the world, including in Manhattan, New York;
Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a
private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary
residence in the United States. His mansion in Manhattan alone-a multi-story townhouse
reported to be one of the largest single residences in all of Manhattan, which previously housed a
school and which he owns through an LLC-has been valued at approximately $77 million.
Entities controlled by the defendant also own at least two private jets in active service, at least one
of which is capable of intercontinental travel.
As described further below, the defendant possesses three active United States passports,
and his international connections and travels are extensive. For example, in addition to
maintaining a residence in Paris, France, as described above, in the past 18 months alone, the
defendant has traveled abroad, via private jet, either into or out of the country on approximately
more than 20 occasions.
C. The Prior Florida Investigation
In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in
connection with allegations that he had committed similar sex offenses against minor girls. The
investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for
the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews
with victims based in the Palm Beach area, including some of the alleged victims relevant to Count
One of the instant Indictment.
In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in
connection with the conduct at issue in that investigation, which the non-prosecution agreement
identified as including investigations into the defendant's abuse of minor girls in the Palm Beach
area. The Southern District of New York was not a signatory to that agreement, and the defendant
was never charged federally.² In June 2008, the defendant pled guilty in state court to one count
of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation
of prostitution, a felony. As a result, the defendant was designated as a sex offender with
registration requirements under the national Sex Offender Registration and Notification Act.
1 The non-prosecution agreement, further discussed below, was entered into at the conclusion of
the SDFL investigation and did not purport to cover any victims outside of the State of Florida.
As noted above, the instant Indictment expressly alleges the existence of dozens of victims who
were abused in this District in addition to dozens of victims who were abused in Florida.
2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the
Second Circuit that absent an express provision to the contrary in the agreement, one District is
not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's
Office in another district. See page 6, infra.
EFTA00024586

=== Page 4 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 4
ARGUMENT
I.
Applicable Law
Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to
order a defendant's detention pending trial upon a determination that the defendant is either a
danger to the community or a risk of flight. 18 U.S.C. $ 3142(e) ("no condition or combination of
conditions would reasonably assure the appearance of the person as required and the safety of any
other person and the community"). A finding of risk of flight must be supported by a
preponderance of the evidence. See, e.g., United States V. Jackson, 823 F.2d 4, 5 (2d Cir. 1987);
United States V. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must
be supported by clear and convincing evidence. See, e.g., United States V. Ferranti, 66 F.3d 540,
542 (2d Cir. 1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if
there is "a serious risk that the [defendant] will attempt to obstruct justice, or to threaten,
injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(f)(2)(B); see also United
States V. Friedman, 837 F.2d 48 (2d Cir. 1988).
The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the
nature and circumstances of the crimes charged; (2) the weight of the evidence against the person;
(3) the history and characteristics of the defendant, including the person's "character
[and]
financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See
18 U.S.C. $ 3142(g). Evidentiary rules do not apply at detention hearings and the government is
entitled to present evidence by way of proffer, among other means. See 18 U.S.C. $ 3142(f)(2);
see also United States V. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled
to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States V.
Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same).
Where a judicial officer concludes after a hearing that "no condition or combination of
conditions will reasonably assure the appearance of the person as required and the safety of any
other person and the community, such judicial officer shall order the detention of the person before
trial." 18 U.S.C. $ 3142(e)(1). Additionally, where, as here, a defendant is charged with
committing an offense involving a minor victim under 18 U.S.C. $ 1591, it shall be presumed,
subject to rebuttal, that no condition or combination of conditions will reasonably assure the
appearance of the defendant as required and the safety of the community. 18 U.S.C.
$ 3142(e)(3)(E).
II.
Discussion
The defendant should be detained pending trial. For the reasons set forth below, it is
difficult to overstate the risk of flight and danger to the community if the defendant is released,
and for those reasons, the defendant cannot overcome the statutory presumption in favor of
detention in this case.
EFTA00024587

=== Page 5 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 5
A. The Defendant Poses an Extreme Flight Risk
Each of the relevant factors to be considered as to flight risk - the nature and circumstances
of the offense, the strength of the evidence, and the history and characteristics of the defendant -
counsel strongly in favor of detention.
1. The Nature and Circumstances of the Offense and the Strength of the Evidence
The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C.
$ 3142(g)(1) (specifically enumerating "whether the offense. involves a minor
victim"
as
a
factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a
defendant charged with that offense, there is a presumption that no condition or combination of
conditions will reasonably assure the appearance of the defendant as required and the safety of the
community. 18 U.S.C. $ 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's
conduct was committed serially, over a period of years, and affected dozens of victims.
The seriousness of the charge is also reflected in the penalties the defendant faces, which
include up to 45 years of incarceration for Counts One and Two of the Indictment. As the Second
Circuit has noted, the possibility of a severe sentence is a significant factor in assessing the risk of
flight. See Jackson, 823 F.2d at 7; see also United States V. Cisneros, 328 F.3d 610, 618 (10th Cir.
2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her
gave her a strong incentive to abscond); United States V. Townsend, 897 F.2d 989, 995 (9th Cir. 1990)
("Facing the much graver penalties possible under the present indictment, the defendants have an even
greater incentive to consider flight."). Here, the defendant is facing a statutory maximum of decades
in prison. Even in the absence of means-which, as discussed in detail below, the defendant has
in abundance-this fact alone would provide a compelling incentive for anyone to fail to appear.
It is particularly compelling for a defendant who is 66 years old and therefore faces the very real
prospect of spending the rest of his life in prison if convicted.
The likelihood of a substantial period of incarceration is buttressed by the strength of the
evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges
that the defendant sexually abused dozens of minor victims, and the conspiracy count lists
numerous overt acts committed in furtherance of the defendant's crimes.4
3 The current penalties for violations of 18 U.S.C. $ 1591 include a 10 year mandatory minimum
sentence. However, that punishment was created through an amendment to the statute in 2006.
The penalty for a violation of Section 1591 during the period charged in the Indictment, and
therefore relevant here, was a maximum of 40 years' imprisonment.
4 With respect to the evidence in this case, the Court should start its analysis by accepting that the
Indictment is sufficient, on its own, to establish probable cause that the defendant committed the
crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an
evidentiary hearing addressing the existence of probable cause required in every $ 3142(e) case in
which an indictment had been filed, the court would spend scarce judicial resources considering
that which a grand jury had already determined, and have less time to focus on the application of
EFTA00024588

=== Page 6 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 6
Multiple victims, including several specified in the Indictment, have provided information
against the defendant. That information is detailed, credible, and corroborated, in many instances,
by other witnesses and contemporaneous documents, records and other evidence-including, as
further detailed below, evidence from a search of the New York Residence on the night of the
defendant's arrest that reflects an extraordinary volume of photographs of nude and partially-nude
young women or girls. Such corroborating evidence also includes documents and other materials,
such as contemporaneous notes, messages recovered from the defendant's residence that include
names and contact information for certain victims, and call records that confirm the defendant and
his agents were repeatedly in contact with various victims during the charged period. Put simply,
all of this evidence - the voluminous and credible testimony of individuals who were sexually
abused by the defendant as minors, each of whom are backed up by other evidence - will be
devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention.
Finally, it bears noting that neither the age of the conduct nor the defendant's previous non-
prosecution agreement ("NPA") with a different federal district pose any impediment to his
conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283,
which was amended in 2003 to extend the limitations period for conduct that was timely as of the
date of the amendment, to any time during the lifetime of the minor victim. See United States V.
Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute
of limitations for sex offenses involving minors during the time the previous statute was still
running, the extension was permissible); United States V. Pierre-Louis, No. 16 Cr. 541 (CM), 2018
WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same).
Moreover, with respect to the NPA, that agreement, to which the Southern District of New
York was not a party, which by its express language pertained exclusively to the SDFL
investigation, and which did not purport to bind any other Office or District, does not preclude
prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit
that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind
another." United States V. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("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.") (citing United States
V. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the
agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis
similarly extends to a non-prosecution agreement. See United States V. Laskow, 688 F. Supp. 851,
854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement
to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States
Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit,
which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can
affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi,
771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely
the presumptions and the $ 3142(g) factors in deciding whether the defendant should be
detained.").
EFTA00024589

=== Page 7 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 7
conduct that occurred in New York. The prior NPA included a list of several dozen victims
identified in the prior investigation, all of whom were abused in the State of Florida, and none of
whom are a part of the conduct charged in Count Two of the instant Indictment.
Each of these factors-the seriousness of the allegations, the strength of the evidence, and
the possibility of lengthy incarceration-creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
2. The Characteristics of the Defendant
The history and characteristics of the defendant also strongly support detention. The
defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt
to flee. Indeed, his potential avenues of flight from justice are practically limitless.
As the defendant acknowledged in his most recent New York State sex offender
registration, he has six residences, including two in the U.S. Virgin Islands (including his own
private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and
Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion
alone is more than $77 million. The most recent tax-assessed value of the defendant's Palm Beach
estate is more than $12 million. The defendant's primary residence is a private island in the U.S.
Virgin Islands, a place where any sort of meaningful supervision would be all but impossible.
Moreover, the defendant has access to innumerable means to flee. His sex registration
documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven
Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade,
and a Hummer II. These cars are registered in various states and territories including the Virgin
Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets,
giving him the ability to leave the country secretly and on a moment's notice and to go virtually
anywhere he wants to travel. He is a very frequent international traveler and regularly travels to
and from the United States by private plane. In particular, between January 1, 2018, and the
present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which
Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport
arriving on just such a private international flight after having spent approximately three weeks
abroad. Extensive international travel of this nature further demonstrates a significant risk of
flight. See, e.g., United States V. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be
no assurance that, upon release, the defendant would suddenly lack access to such means of travel.
Finally, the defendant has no meaningful ties that would keep him in this country. The
defendant has no known immediate family. He is not married and has no children. He has friends
and associates worldwide, as demonstrated by his extensive international travel, and his
professional obligations, if any, can and seemingly are plainly capable of being handled by the
defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain
in the country, while he would have every incentive (and every resource needed) to flee.
Nor would home confinement with electronic monitoring reasonably assure the
defendant's presence as required. At best, home confinement with electronic monitoring would
EFTA00024590

=== Page 8 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 8
merely reduce his head start should he decide to flee. See United States V. Zarger, No. 00 Cr. 773,
2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application
for bail in part because home detention with electronic monitoring "at best
limits
a
fleeing
defendant's head start"); see also United States V. Casteneda, No. 18 Cr. 047, 2018 WL 888744,
at *9 (N.D. Cal. Feb. 2018) (same); United States V. Anderson, 384 F.Supp.2d 32, 41 (D.D.C.
2005) (same); United States V. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y.
Oct. 10, 2002) (same).
Finally, there can be little doubt that the defendant is in a position to abandon millions of
dollars in cash and property securing any potential bond and still live comfortably for the rest of
his life. These resources, and the ease with which the defendant could flee and live outside the
reach of law enforcement-particularly considering his vast wealth and lack of meaningful ties to
this District-make the risk of flight exceptionally high in this case, particularly when considered
in conjunction with the strength of the government's case and the lengthy sentence the defendant
could receive if convicted.
B. The Defendant Poses a Risk of Danger to the Community and of Engaging in
Obstruction of Justice
The release of the defendant, under any conditions, would pose a significant threat to the
community and to the ongoing investigation.
As described above, where there is probable cause to believe that an individual has
committed an offense under 18 U.S.C. $ 1591, it is presumed that no condition or combination of
conditions can reasonably assure the safety of the community. 18 U.S.C. $ 3142(e)(3). Here, not
only is the defendant charged with very serious sex crimes against minors, he has already
previously admitted to-and been convicted of-engaging in related conduct. Specifically, in
June 2008, the defendant pled guilty in state court to one count of procuring a person under the
age of 18 for prostitution, a felony, and he currently is a registered sex offender, under
classification level three in New York-defined as presenting a "high" risk of committing another
sex crime and harm to the community. While the conduct presently alleged does not post-date the
2008 conviction, it nevertheless underscores the risk he poses to the community if released.
Additionally, and in connection with the investigation of the defendant's offense in Florida,
there were credible allegations that the defendant engaged in witness tampering, harassment, or
other obstructive behaviors. In fact, according to publicly-filed court documents, there were
discussions between prosecutors and the defendant's then-counsel about the possibility of the
defendant pleading guilty to counts relating to "obstruction," as well as "harassment," with
reference to 18 U.S.C. $ 1512, which criminalizes "[t]ampering with a witness, victim, or
informant." For example, in a communication from the defendant's then-counsel to prosecutors
in SDFL, his counsel set forth a possible factual proffer that included statements that the defendant
had "attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an
official proceeding" and that the defendant "in particular, changed travel plans and flew with both
[redacted] to the United States Virgin Islands rather than to an airport in New Jersey in order to
attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally
EFTA00024591

=== Page 9 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 9
harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process
all in violation of 18 USC 1512(d)(1)." Doe V. United States, 08 Civ. 80736 (S.D. Fla.), Dkts.
361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. $ 1512(d), prosecutors also proposed
that the defendant could plead guilty to 18 U.S.C. $ 403, that is, a knowing or intentional violation
of the privacy protection of child victims and child witnesses, to which the defendant's then-
counsel replied: "Already thinking about the same statutes." Id. Dkt. 361-11. They also discussed
a possible obstruction plea that "could rely on the incident where Mr. Epstein's private
investigators followed [redacted] father, forcing off the road." Id. Dkt. 361-10.
The defendant's apparent previous willingness to obstruct a federal investigation, harass or
tamper with witnesses, and hire private investigators that "forc[ed] off the road" the father of an
individual relevant in the investigation is alarming. It should especially weigh on the Court's
consideration here because the defendant was apparently willing to take those steps before even
being charged and thus facing federal indictment; the incentive to interfere in the Government's
case here, where an Indictment has been returned, is exponentially greater. And as discussed
above, the defendant has nearly limitless means to do so.
Finally, despite having been previously convicted of a sex offense involving an underage
victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking
women or girls in his Manhattan mansion. In a search of the New York Residence on the night of
his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers
discovered not only specific evidence consistent with victim recollections of the inside of the
mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at
least hundreds-and perhaps thousands-of sexually suggestive photographs of fully- or partially-
nude females. While these items were only seized this weekend and are still being reviewed, some
of the nude or partially-nude photographs appear to be of underage girls, including at least one girl
who, according to her counsel, was underage at the time the relevant photographs were taken.
Additionally, some of the photographs referenced herein were discovered in a locked safe, in which
law enforcement officers also found compact discs with hand-written labels including the
following: "Young [Name] + [Name]," "Misc nudes 1," and "Girl pics nude." The defendant, a
registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a
continuing danger to the community and an individual who faces devastating evidence supporting
deeply serious charges.
5 The redactions above are contained in the publicly filed version of the quoted document.
6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator,
N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post
yesterday. 'It's the difference between a murderer and a person who steals a bagel."); Philip
Weiss, The Fantasist, New York Magazine (2007) ("It's the Icarus story, someone who flies too
close to the sun,' I said. 'Did Icarus like massages?' Epstein asked.").
EFTA00024592

=== Page 10 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 10
CONCLUSION
As set forth above, in this case, the risk of flight in this case is extraordinarily real. The
defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious
offenses that carry a potential statutory sentence of up to 45 years' imprisonment-even a fraction
of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In
sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive
international travel and ties outside the country, and his vast wealth, including his access to and
ownership of private planes, all provide the defendant with the motive and means to become a
successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated-the abuse
dozens of underage, vulnerable girls-along with his demonstrated willingness to harass,
intimidate and otherwise tamper with victims and other potential witnesses against him, render his
dangerousness readily apparent.
Accordingly, the Government respectfully submits that the defendant cannot and will not
be able to meet his burden of overcoming the strong presumption in favor of detention, that there
are no conditions of bail that would assure the defendant's presence in court proceedings in this
case or protect the safety of the community, and that any application for bail should be denied.
Very truly vours
Assistant United States Attorney
Southern District of New York
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
Hon. Richard M. Berman, United States District Judge
EFTA00024593


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=== Page 1 ===
OFFICIAL RECORD
FD-1036 (Rev. 10-16-2009)
Document
have
poules
UNCLASSIFIED
2
cortified
FEDERAL BUREAU OF INVESTIGATION
Import Form
Form Type: OTHER - Other
Date: 08/14/2020
Title: (U) Documentation of services
Approved By: A/
Drafted By:
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Synopsis: (U) To document the provision of victim services.
+
UNCLASSIFIED
EFTA00025002


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=== Page 1 ===
From:
To:
Cc:
Subject: California trip Santa Monica
Date: Thu, 07 Nov 2019 14:01:36 +0000
Attachments: Los_Angeles_Tax_exempt.pdf
The old tax exempt link seem broken to me.
https://www.google.com/search?
source=hp&ei=GSPEXd2iG6qp_QaGra_wDA&g=what+county+istsantatmonica+in&og-whattcounty+ist-santa&gs_l=psy-
ab.1.0.0170i251j019.959.12224.14884..1.0..0.110.1729.19j2...3.0...1.gws-
From:
Sent: Tuesday, November 05, 2019 4:58 PM
To:
Cc:
is
is
V.
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Nov 5, 2019, at 4:56 PM,
)
wrote:
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
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
EFTA00024307

=== Page 2 ===
and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
)
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
thanks very much,
From:
)
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
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
EFTA00024308

=== Page 3 ===
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:
)"
Cc:
]"
Subject: Re: Prince Andrew reportedly now cooperating with Jeffrey Epstein investigators
Date: Sat, 14 Mar 2020 12:50:08 +0000
I haven't. Crazy story.
Sent from my iPhone
> On Mar 14, 2020, at 12:07 AM,
)
wrote:
>
> Did anyone talk to the telegraph?
V
>
https://pagesix.com/2020/03/13/prince-andrew-reportedly-now-cooperating-with-jeffrey-epstein-investigators/
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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re: Epstein investigation
Date: Sat, 22 Feb 2020 20:35:20 +0000
On Feb 22, 2020, at 2:17 PM,
)
wrote:
Sent from my iPhone
Begin forwarded message:
From: Jill Greenfield
Date: February 22, 2020 at 1:55:06 PM EST
To:
)"
Cc: Kyle Phillips
Louise Scott
)"
,
)"
Subject: RE: Epstein investigation
Hello
Apologies for the slight delay. My client is willing to help but asks the following:
That there be a morning meeting at which introductions with a discussion as to the investigation and my clients
involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist.
In the afternoon and after a break, my client would be willing to answer questions, in so far as she can.
That a friend of hers be allowed to be present as well. However that friend is based in the US and would need
to be flown over to London. He is a US lawyer.
Perhaps you could let me know if this is possible?
Kind regards,
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
EFTA00026794

=== Page 2 ===
Fieldfisher Logo
From:
Sent: Saturday, February 15, 2020 7:08 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
Subject: RE: Epstein investigation
Understood - thanks very much.
From: Jill Greenfield
Sent: Saturday, February 15, 2020 07:22
To:
Cc: Kyle Phillips
>; Louise Scott
)
is
Subject: Re: Epstein investigation
Thanks
This is helpful. I've gone back to my client with this. I will be back in touch shortly.
Regards
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
On 14 Feb 2020, at 21:43,
)
wrote:
Jill,
Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding
some of the additional follow-up questions you asked, and to describe in more detail for your client how we would
expect to approach any discussion with your client if she were comfortable meeting with us.
The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the
decision to meet with us but also as to any topic or question-your client would be absolutely free to determine
what topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything
that would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell
EFTA00026795

=== Page 3 ===
her, as we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is
no problem at all.
In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves,
explained the status of our investigation, talked about how a discussion would proceed if your client ended up being
comfortable with that, and answered in person any questions she. We have done that previously, where we do the
talking rather than asking questions in an initial meeting, and that would of course be without any requirement for
anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are
able to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in
approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client
were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or
victimization she experienced. We wrote in our first email that we would primarily be interested in talking about
topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as
always we would be guided by her comfort level.
In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and
that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet
the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a
discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment
and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in
particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell
you in advance if there came a time when we thought that might be important to address, and how we could
facilitate that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure
you that every one of us has now spoken with dozens of victims in this case, and every one of us has extensive
experience more generally working with victims and working on cases involving sex offenses. We are proud of how
we have been able to work with victims in this case especially, given all of the circumstances, and we absolutely
would take the same sensitive approach with your client as we have with the many other victims in this case who
have spoken with us.
Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how
our process works, and answer any questions your client has in person, we would absolutely be happy to do that
with no obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could
just address the general subject of her employment, for example. But no obligation and no pressure. We continue
to appreciate your and her willingness to even broach the possibility of a discussion, and we hope this is helpful.
thank you very much,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Saturday, February 08, 2020 14:25
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
is
Subject: RE: Epstein investigation
Jill,
EFTA00026796

=== Page 4 ===
Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the
most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The
only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign
country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't
believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's
useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just
the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise
we're of course happy to travel to her.)
Regarding access to notes, it would principally be the investigative team-so again, the prosecutors and the FBI team
working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not
generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types
up those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but
I can also check on that to see if I can make a more specific representation with respect to your client.
With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our
investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other
witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't
change even for individuals who are in the position of your client, who have been widely publicly reported to have
been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of
course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any
follow-up via email.
thanks,
From: Jill Greenfield
Sent: Saturday, February 08, 2020 13:17
To:
Cc: Kyle Phillips
>; Louise Scott
is
>;
)
Subject: Re: Epstein investigation
Hi
Thanks for this. I've been asked who would be in the room and thereafter who would have access to any
notes made. Would her permission be sought before disclosing to any other parties or officials?
As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to
provide any comfort on this?
Many thanks
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
EFTA00026797

=== Page 5 ===
<image001.jpg>
Sent from my iPhone
On 6 Feb 2020, at 21:53,
wrote:
Ms. Greenfield,
Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection
with our investigation into the conduct of Jeffrey Epstein.
As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to
reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to
her trauma or causing re-victimization.
As we mentioned on the phone, your client is not a target of our investigation-it sounds like the analogue in the
U.K. may be the "suspect" category-and we currently do not have reason to believe that she has committed any
U.S. federal crime. As we discussed, our knowledge of your client specifically is somewhat limited, having never
spoken to her-and therefore knowing about her only through other witnesses and records-but it certainly has
been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey
Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble
believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we
hope to speak with her.
Separately, and as we also discussed, any discussion with our team would be entirely voluntary-and that extends
not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss
particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that
would be beneficial while we're meeting, etc.
In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein
and his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked
directly for. That would broadly include how she came to be in contact with them, the nature and scope of her
employment, any instructions she was given relating to other women or girls, and just generally her experiences
and observations in interacting with them. We ordinarily would also be interested in understanding the general
nature of the abuse she was subjected to, but I want to emphasize that we would not need to discuss with her the
specifics if she weren't comfortable with that, and in particular we often don't even broach that subject in a first
meeting.
Please let us know if you have any additional questions, and in particular whether any other information from us
would be useful, and we look forward to speaking with you again soon.
Regards,
Assistant U.S. Attorney
Southern District of New York
Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your
contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
EFTA00026798

=== Page 6 ===
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact
the sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any
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agreement.
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Lane, London EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00026799


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=== Page 1 ===
From: New York Law360 <news@law360.com>
To:
Subject: NY Bar Says Attys Can Rent Out Offices In Co-Working Biz
Date: Wed, 26 May 2021 08:08:08 +0000
Law360 New York
NEW YORK
Wednesday, May 26, 2021
Follow Law360
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NY Bar Says Attys Can Rent Out Offices In Co-Working Biz
New York-based attorneys are permitted to run a nonlegal business that
consists of renting out law office space to other lawyers, the New York State
Bar Association committee on legal ethics said in an opinion issued Tuesday.
Opinion attached I Read full article
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Gov. Andrew M. Cuomo has nominated Nassau County District Attorney
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The outcome of prosecutors' effort to force ex-Nomura trader Michael
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EFTA00025231

=== Page 2 ===
Judge OKs Epstein Guards' No-Jail Pact With Prosecutors
Greenberg Traurig
A New York federal judge on Tuesday approved a deferred prosecution
Gunster Yoakley
agreement for two correctional officers responsible for guarding Jeffrey
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guards and allowing them to skirt prison so long as they comply with the
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Letter attached
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A long-awaited program to administer more than $2 billion in federal
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pandemic rental assistance across New York will open on the morning of
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The continuing decline in COVID-19 cases and the upcoming Memorial Day
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Clearview AI Urges III. Court To Toss Biometric MDL Claims
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claims that it unlawfully collected biometric information from photos on the
internet, arguing that the allegations attack conduct that largely occurred out
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of state.
AXA XL Ltd.
Memorandum attached
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EFTA00025232

=== Page 3 ===
INTELLECTUAL PROPERTY
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Boston Properties Inc.
'Shadowy NY Hedge Fund' Jab Tainted IP Trial, Gigamon Says
CITGO Petroleum Corp.
Gigamon has asked U.S. District Judge Rodney Gilstrap for a new trial after
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a Texas jury found claims in its network data-management patents were
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Coalition
arguments that Gigamon's new owner was "a shadowy New York hedge
fund."
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Motion attached
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Equal Justice Initiative
Hair Company's Case Against Cosmo Hangs On By A Thread
GC Services Ltd. Partnership
A New York state judge on Tuesday largely dismissed a $35 million lawsuit
against Cosmopolitan magazine by a hair extension company that claimed
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the publisher reneged on a branding and advertising deal and stole its
GoFundMe Inc.
secrets to profit from a competing product.
GreenSky LLC
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Hertz Global Holdings Inc.
EMPLOYMENT
IMG Worldwide Inc.
Labor Unions Slam NY Bill To Let Gig Workers Unionize
LexisNexis Group
Worker advocacy groups and labor unions on Tuesday denounced New York
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legislation not yet introduced that would let gig workers unionize, a proposal
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the organizations said would deprive workers in the state of key labor law
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Bankrupt Hertz Reaches Settlement On $48M Overtime Suit
Microsoft Corp.
Bankrupt car rental giant Hertz Global told a New York court that it has
NAACP Legal Defense and
settled a $47.9 million potential class action claim over unpaid overtime for
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Amtrak Says Ex-Cop Can't Hide Past Conviction In Injury Suit
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for misrepresenting his work experience, saying it demonstrates the officer's
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A New York federal court granted a partial win Tuesday to AT&T in a
The Lawyers' Committee for Civil
proposed class action lodged by two retirees who say they should have been
Rights Under Law
paid retirement benefits retroactively, agreeing with the benefit plan
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Order attached Read full article
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SECURITIES & WHITE COLLAR
United Auto Workers
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GreenSky Investors Strike $27.5M Deal Over IPO Disclosures
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ahead of its initial public offering, according to documents filed in New York
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federal court.
National Railroad Passenger Corp.
EFTA00025233

=== Page 4 ===
Memorandum attached Read full article
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MERGERS & ACQUISITIONS
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Serious Fraud Office
5 Firms Lead Valens To $1.16B Valuation Via SPAC Merger
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Valens, an Israeli developer of semiconductor technology for the audiovisual
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and automotive markets, will combine with a special purpose acquisition
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vehicle at a $1.16 billion valuation, the companies said Tuesday, in an
agreement developed by five law firms.
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Eastern District of New York
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PRIVATE EQUITY
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Cooley Steers Weight Loss Co. Noom's $540M Series F Round
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million in a Cooley LLP-advised funding round led by Silver Lake Partners, as
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the digital startup seeks to help users reduce anxiety and stress, as well as
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shed pounds.
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EXPERT ANALYSIS
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New Circuit Split Complicates Domestic Securities Test
U.S. Court of Appeals for the
The First Circuit's recent holding in U.S. Securities and Exchange
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Commission V. Morrone cements a new circuit split over when a securities
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transaction is considered domestic, introducing new wrinkles to the already-
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years.
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EFTA00025234

=== Page 5 ===
3 Takeaways On COVID-19's Impact On Law School Faculty
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policing."
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GoExpedi Taps Former Andarko Atty As General Counsel
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an inaccurate abridgment of his statements.
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Accused Atty Killer Can't Appeal Wrongful Death Settlement
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challenge the deal.
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Legal services organizations warned in a Tuesday letter that the U.S.
Department of Justice was "doggedly" insisting on policies that would
frustrate a legal aid program for unrepresented immigrants in negotiations
over the program's future.
EFTA00025235

=== Page 6 ===
Read full article »
Ex-Judges Press AG To Toss Trump-Era Immigration Opinions
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Garland on Tuesday to revoke the immigration rulings of his Trump-era
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=== Page 1 ===
From:
(USANYS)"
To:
Subject: RE: Doud trial
Date: Thu, 17 Dec 2020 19:48:50 +0000
Yea that probably works. Or else sometime in the fall when covid is totally gone since Doud is old.
From:
Sent: Thursday, December 17, 2020 2:31 PM
To:
(USANYS)
Subject: RE: Doud trial
So maybe we aim for a mid-July date for Doud, if defense can do it? And assuming you can still do it.
From:
(USANYS)
Sent: Thursday, December 17, 2020 2:19 PM
To:
Subject: RE: Doud trial
Here's my chaotic summer schedule:
- 5/24: U.S. V. Steve Bannon et al (3-4 weeks probably)
- 6/21: U.S. V. Noel (MCC Epstein guards) (1 week)
- 8/16: U.S. V. Adams (MCC guard bribery) (1 week)
- U.S. V. Lev Parnas et al (2-3 weeks) = was scheduled for March but judge moving it to some times in August - October
2021. I'll know in the next week or two what the date is.
I'm not thinking I'll be able to do all of these. Doud would be top 3 trial for me but probably not #1.
From:
Sent: Thursday, December 17, 2020 1:40 PM
To:
(USANYS)
Subject: Doud trial
Hi - Remind me of your schedule this summer for trial. When are you first available?
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
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=== Page 1 ===
From:
"
)"
To:
(USANYS)
[Contractor]"
Cc:
"
(USANYS)"
)"
)"
Subject: FW: Press Question (Ghislaine Maxwell Trial)
Date: Fri, 22 Oct 2021 15:26:20 +0000
Inline-Images: image001.jpg; image002.jpg
Passing this on.
From: Thrapp, Jacklyn
Sent: Friday, October 22, 2021 11:18 AM
To:
>;
>;
is
)
is
(USANYS)
Subject: [EXTERNAL] Press Question (Ghislaine Maxwell Trial)
Hello,
I'm a reporter for the National Enquirer covering the trial of Ghislaine Maxwell. I heard
won't be called to
the stand during the trial.
Is this true? And if so, can you elaborate on why, if possible.
Thanks
JACKI THRAPP
REPORTER
THE NATIONAL ENQUIRER
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=== Page 1 ===
From: Robert Glassman
To:
)"
Cc:
)"
)"
Subject: RE: RE:
follow-up
Date: Fri, 20 Mar 2020 20:38:49 +0000
Only Maxwell would sue in the midst of a pandemic
Robert Glassman, Esq.
Panish Shea & Boyle LLP
Web: www.psblaw.com
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full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
your case or potential case.
From:
[mailto:
Sent: Friday, March 20, 2020 1:28 PM
To: Robert Glassman
Cc:
is
Subject: RE: RE:
follow-up
Robert - got it, thank you. So that wouldn't have been her first trip, then, based on the flight records (and timeline), so
we'll make that note. Thanks again.
From: Robert Glassman
Sent: Friday, March 20, 2020 16:26
To:
Cc:
is
Subject: Re: RE:
follow-up
Hey
Hope you guys are staying safe. Here was her response about the lion king:
Broadway play. Epstein bragged about being good friends with
and we had amazing first row mezzanine
seats they she had apparently given him.
From:
Date: 3/20/20, 12:26:42 PM PDT
EFTA00024529

=== Page 2 ===
To: Robert Glassman
Cc:
Subject: RE:
follow-up
Robert,
Wanted to quickly follow up on our conversation from a couple weeks ago - obviously it was before the world
imploded, so understand if you haven't gotten a chance to connect on this yet, but we were wondering about the
Lion King question? Just to briefly remind, the Lion King musical first came out in 1997, which we think would have
been well after
first trip to New York (based on her recollection as well as the flight records), while the movie
came out in 1994 and was in theaters through approximately spring 1995. So entirely possible she was referencing
the movie version, or that going to the play wasn't the first visit, or just doesn't have a specific memory, etc etc, but
wanted to check for our records and our decision-making process.
Thank you! And hope you and your family are healthy and safe in the midst of everything going on.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00024530


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=== Page 1 ===
From:
)"
To: "jocks@sondeeracine.com" <jjocks@sondeeracine.com>
Cc:
)"
,
)"
Subject: Subpoena to Interlochen Center for the Arts
Date: Thu, 06 Feb 2020 18:50:39 +0000
Attachments: 2020-02-06,_subpoena_to_Interlochen_(for_donor_records).pdf
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
EFTA00026978


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: cases
Date: Wed, 18 Nov 2020 15:28:17 +0000
Hi
I am not. My colleague
copied here, is handling the case and can answer any questions you have.
Thanks,
From:
Sent: Wednesday, November 18, 2020 10:27 AM
To
Subject: cases
Hi
Are you handling the two staff cases out of MCC arising out the Epstein suicide? If so, can I just get a very quick update on
the timeline? Trial? etc...
Thanks!
EFTA00026455


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=== Page 1 ===
Advanced Person Search
Page 1 of 2
Advanced Person Search
Coverage
Help?
Important Security Mes
MY ACCURINT
Learn more! Click here I
FORTELNI
MARIUS
Middle Name
Search
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complimentary Get Star
include similar-sounding names
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PEOPLE
include Full Address History
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PHONES
The Public Records and commercially available data
Street Address
City
State
sources used in this system have entors Data
sometimes entered poorly, processed incomectly
and 5 generally not free from defect
ZIP Code
Radius (miles)
Date First Seen
-
Date Last Seen
Bead More
ASSETS
Show Additional Subject Information Fields
ANALYTICS
COURTS
BUSINESSES
You last signed in on To
06:07 PM EDT.
LICENSES
MORE
Security Center
Results 1 to 1 of 1
Last Name: FORTELNI; First Name: MARIUS; DOB:
FURTHER RESEARCH
No Images Available
Reports for this Record
Comprehensive
Custom
Report
Comprehensive
Finder Report
Report
Contact Card Report
Address Report
Asset Report
Virtual Identity Report
Relatives
Summary Report
Associates
Neighbors
Business Link Report
Relatives Neighbors
& Associates
Relavint Visual Link
Analysis
Location Report
See report type examples
Alerts for this Record
Setup Person Alert
ALL
NAME
SSN
ADDRESS
PHONE(S)
INDICATORS
MARIUS R FORTELNI
1.
MARIUS A FORTELNI
g
MARIUS FORTELNI
criminal
MARUIS R FORTELNI
MARCUS FORTELNI
MARUIS FORTELNI
property
MARIUS R FORTEINI
MARIUS R FORTELMI
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MARIUS R FORTLENI
MARIUS R FORVELNI
people
at work
MARIUS FORTEINI
MARIUS FORTELINI
MARIUS FORTELMI
FORTELNI MARIUS
Gender Male
"View Sources (-11)
https://secure.accurint.com/app/bps/misc.
7/15/2019
EFTA00025540

=== Page 2 ===
Advanced Person Search
Page 2 of 2
ALL
NAME
SSN
ADDRESS
PHONE(S)
INDICATORS
Results 1 to 1 of 1
Last Name: FORTELNI; First Name: MARIUS; DOB:
Your DPPA Permissible Use: Court, Law Enforcement, or Government Agencies
Your GLBA Permissible Use: Law Enforcement Purposes
Your DMF Permissible Use: No Permissible Purpose
https://secure.accurint.com/app/bps/misc
7/15/2019
EFTA00025541


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Jeffrey Pop
Date: Mon, 24 Feb 2020 18:26:07 +0000
I'm prepping for
and I also have the bandwidth to prep for
but does either of you want to take that on
principally and lead the interview? Just let me know. And the
prep largely overlaps with
I think, but again
if either of you wants to focus on that, say the word.
From:
Sent: Monday, February 24, 2020 12:39
To:
)
is
Subject: Jeffrey Pop
I noticed in the DB presentation materials that there is a 6/13/17 transfer from Epstein to Jeffrey Pop, with note
"Reference Doe 43 V. Epstein et al."
was a defendant in that lawsuit (it's docket 17 Civ. 616 (JGK), so I guess not
particularly surprising, but worth being aware of I guess. I added the complaint to
witness folder.
Assistant United States Attorney
Southern District of New York
EFTA00026793


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=== Page 1 ===
From:
To: Jason Foy
Cc:
Subject: U.S. V. Noel, No. 19 Cr 830 - Discovery Production 7
Date: Wed, 14 Apr 2021 13:44:31 +0000
Attachments: SDNY_00018025-SDNY_00018025_(AEO).pdf;2021.04.14_Noel_Discovery_Letter_-
Production_7.pdf
Counsel,
Please find attached a letter regarding the Government's production in this case. We are uploading a zip file containing
the discovery materials to USAfx. Additionally, please find attached one additional page of discovery, which has been
marked attorney's eyes only. Please contact us with any questions or if you have any difficulty accessing the production.
Regards,
Paralegal Specialist
U.S. Attorney's Office I SDNY
EFTA00024017


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
)"
Cc:
"
(USANYS) 1"
(USANYS) [Contractor]"
)"
:
(USANYS)"
,
(USANYS) [Contractor]"
(USANYS)
[Contractor]"
(USANYS) 1"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Epstein priv review -- 1B72 released and update
Date: Tue, 03 Nov 2020 22:12:59 +0000
Embedded: RE:_Epstein_priv_review__IB72_released_and_update.msg
Sender:
Subject: RE: Epstein priv review -- 1B72 released and update
Message-Id:
<DM2P110MB0201FDFEF11095D381A3B92CF3110@DM2P110MB0201.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
EFTA00024804


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c3: VOL00008
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=== Page 1 ===
From:
To:
Subject: RE: article
Date: Thu, 17 Dec 2020 19:16:35 +0000
https://radaronline.com/exclusives/2015/01/jeffrey-epstein-sex-scandal-victim-hollwood-actress/
Subject: article
http://www.trunews.com/jeffrey-epstein-allegedly-targeted-well-known-actress-13/
EFTA00024476


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 364 Filed 10/22/21 Page 1 of 3
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 10/22/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
For the reasons stated on the record at yesterday's conference, the Court will implement
the following procedures for jury selection:
A screening questionnaire will be administered on November 4, 5, and 12.
The Clerk's Office will create a corresponding list of names and randomly assigned juror
numbers. The list will be provided to counsel and the Court for use throughout jury
selection. Jurors will be identified on the questionnaire and in court throughout the
process by their assigned number only.
Completed questionnaires will be copied and distributed to defense counsel by the U.S.
Attorney's Office.
After reviewing the completed questionnaires, counsel must confer in good faith and
jointly submit four lists: (1) prospective jurors that both sides agree should proceed to
voir dire; (2) prospective jurors that both sides agree should be excused; (3) prospective
jurors that the defense, but not the Government believes should be excused; and (4)
prospective jurors that the Government, but not the defense believes should be excused.
1
EFTA00026484

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 364 Filed 10/22/21 Page 2 of 3
Lists for questionnaires completed on November 4 and 5 will be due to the Court
via email by November 7.
Lists for questionnaires completed on November 12 will be due to the Court via
email by November 13.
If necessary, there will be an in-person conference on November 15 at 9:30 a.m.
to resolve any disputes.
Voir dire will proceed on November 16-19. The Court will conduct one-on-one voir dire
with each prospective juror in the presence of the parties and with public access to the
proceeding. At the conference, both sides indicated the potential need for additional
procedures during voir dire under certain circumstances. See Transcript at 10-11. As
the Court indicated, it will consider proposed narrowly tailored measures that may be
necessary during voir dire on a case-by-case basis. See id. at 12.
The Court will decide in due course whether the exercise of peremptory strikes will
proceed on November 19 or November 29.
The Court implements these procedures taking into account the significant publicity this case has
garnered, the nature of the charges, and the District's COVID-19 protocols. These procedures are
carefully balanced and tailored to ensure the safety of the parties and prospective jurors in light
of the continuing pandemic; to ensure juror candor, impartiality, and privacy; and to ensure the
First Amendment right to public access of criminal proceedings.
Also for the reasons stated on the record at yesterday's conference, the request to seal the
parties' proposed questionnaire and voir dire and the Court's draft questionnaire and voir dire
until after jury selection is completed is denied. Although the Court has and will continue to
implement tailored measures to ensure a fair trial despite significant media interest, see Dkt. Nos.
2
EFTA00026485

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 364 Filed 10/22/21 Page 3 of 3
28, 81, 95, 99, 101, 232, 241, 284, 301, 315, the defense did not justify sealing the entirety of the
proposed and draft questionnaires and voir dire. See Lugosch V. Pyramid Co. of Onondaga, 435
F.3d 110 (2d Cir. 2006). The Court's planned individual voir dire process is designed to
carefully probe the prior exposure to and the potential influence of any pre-trial media. As noted
at the conference, the parties may continue to propose for the Court's consideration, any
appropriate and tailored procedures in light of the specific factors related to this case and
upcoming trial.
so ORDERED.
Dated: October 22, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
3
EFTA00026486


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=== Page 1 ===
From:
"
)"
To:
)"
)"
Cc:
)"
(USANYS)"
Subject: RE: Discovery questions
Date: Wed, 19 Aug 2020 23:24:08 +0000
Sure no problem. I can bring those over tomorrow as well.
From:
Sent: Wednesday, August 19, 2020 7:22 PM
To:
>;
is
Cc:
>;
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Perfect, thanks! Yes, I think we should take the vhs tapes and microcassettes to get them converted, if that's ok.
From:
Sent: Wednesday, August 19, 2020 7:20 PM
To:
is
>;
)
Cc:
is
(USANYS)
Subject: RE: Discovery questions
That sounds great. Thank you. We are definitely open to them scheduling a time if need be.
I will check in with CART again and get back to you.
As far as the paper evidence and case file, we can drop that off to your office sometime tomorrow evening. Just working
on putting it all on a disk/thumbdrive for you. Also, FYI, included in the boxes from Reiter are vhs tapes and
microcassettes. Would you like us to turn these over to you as well? Let me know your thoughts on this.
Thanks!
From:
Sent: Wednesday, August 19, 2020 7:01 PM
To:
i
i
Cc:
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thank you so much for these-very helpful (and sorry I didn't realize the message pad scans also had the same pages
without post-its!)
On these:
EFTA00023957

=== Page 2 ===
Yes, please send over the copy of the gj transcript disc when you can.
Found the original scans from the FL file-thank you!
Yes, please get us the paper evidence from NY, VI, and Reiter as soon as you can.
We'll take the FBI file whenever you can get it to our office.
My understanding from past FBI cases is that CART completes some sort of paperwork documenting the dates on
which they conduct data extractions. We need that for all of the extractions in this case, please (It may not be
302s).
On the evidence from disks, understood. In order to give you more time, we are going to tell the defense attorneys
that the materials are available for them to review in-person if they want to schedule a time to come down to the
FBI office, but that in the meantime we are still working on getting copies of non-nude images to produce to them.
From:
Sent: Wednesday, August 19, 2020 2:21 PM
To:
)
is
is
Cc:
is
(USANYS)
Subject: RE: Discovery questions
Hey all, below is a summary of the discovery items you've requested.
Message Pad Scans: The message pads were scanned with the post it notes on them and the very next page is the page
without the post it note, so the pages are back to back.
Papers from Miami case file (grand jury testimony): This is a disk - I can copy it and send it over to you.
Evidence scans: Are you referring to the scans from the FL file? We sent those over with the original message pad scans
last year. If you need that again, let us know and we can get another copy over to you. As far as paper evidence from the
NY and VI searches, and the paper provided by Reiter, we can get that over to you by the end of the week.
FBI file: We have that ready for you.
CART: There are no 302s regarding the extraction of devices.
Evidence from disks: This is a large volume and we've been working on this and removing nude/semi nude images. This is
the only thing that would be difficult to complete by Friday. If we could have a little more time to pull this together, that
would be very helpful.
If it's helpful to talk through some of this via phone, we are happy to do that as well.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
EFTA00023958

=== Page 3 ===
From:
Sent: Tuesday, August 18, 2020 6:41 PM
To:
is
Cc:
is
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thanks so much,
Really appreciate all the work you and
are putting in on this. Let's touch base tomorrow to
figure out the timeline for the discovery issues.
From:
Sent: Tuesday, August 18, 2020 6:40 PM
To:
is
Cc:
i
>;
(USANYS)
Subject: Re: Discovery questions
Hey guys,
Apologies but today I was out In the field on surveillance and
was also out of the office so we've not
been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into
this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best to
get on this list. That being said I don't want to make you any promises that everything will be compiled by
tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if you
like to square some of this away.
I did receive your "pages from Miami_case_docs" PDF.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Tuesday, August 18, 2020 6:03 PM
To:
is
Cc:
is
is
(USANYS)
Subject: RE: Discovery questions
EFTA00023959

=== Page 4 ===
Hi
and
Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these
materials tomorrow or Thursday?
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:41 PM
To:
is
Cc:
is
>;
(USANYS)
Subject: RE: Discovery questions
Hi
and
The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a
larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to
provide us with all of those scans this week?
With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes on
them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:45 AM
To:
Cc:
is
>;
is
(USANYS)
Subject: RE: Discovery questions
Sorry, got a bounceback for
too. I'm just attaching the one page I referenced in my email below. Hopefully that
will go through.
From:
Sent: Tuesday, August 18, 2020 4:40 AM
To:
Cc:
is
>;
>;
(USANYS)
Subject: FW: Discovery questions
I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went
through for
so she can see it. If not, please let me know.
Thanks,
EFTA00023960

=== Page 5 ===
From:
Sent: Tuesday, August 18, 2020 4:33 AM
To:
Cc:
is
>;
(USANYS)
Subject: Discovery questions
Hi
and
Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent
batch you provided, and wanted to check in on the longer term tasks we discussed last month.
Below are some questions regarding the discovery
dropped off a few days ago with requests for additional items:
The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it
contains grand jury transcripts. Have you given us those transcripts?
The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think
mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad-and those
copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad
scans" folder. Would you please get us a scans of these without post-its on them?
It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant. Would
you please get us copies of those returns?
Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you
please be able to get us these this week?
Full FBI sentinel file
CART paperwork regarding the extraction of data from all devices seized during the investigation
All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard
copy) seized during the investigation, including from Epstein's properties.
Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials
Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been scanned,
including anything seized during any searches. Please produce to SDNY all of those scans, except any nude or
partially nude images. For nude or partially nude images, please provide us with a log detailing how many such
images were scanned, where they were from, and where they are being stored.
Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform
for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude images.
For nude or partially nude images, please provide us with a log detailing how many such images were located,
where they were from, and where they are being stored.
Please let me know if you have any questions or if it would be useful to hop on a call.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00023961


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=== Page 1 ===
90A-NY-3151227 Serial 35
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027708
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027708: One (1) Seagate Desktop
1000GB HDD, ST100DM003, S/N Z4Y00Q48, containing the Clone Copy of 1B9
hard drive (Western Digital 500GB HDD, WD5000AAKX- 60U6AA0, S/N
WCC2EJUC34CJ), collected via Tableau TD3-B S/N 01D3B08D-1331. Request ID
112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027708: One (1) Seagate Desktop 1000GB HDD,
ST100DM003, S/N Z4Y00Q48, containing the Clone Copy of
1B9 hard drive (Western Digital 500GB HDD, WD5000AAKX-
60U6AA0, S/N WCC2EJUC34CJ), collected via Tableau TD3-B
S/N 01D3B08D-1331. Request ID 112048. Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Derivative
Number of Devices Collected: 1
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.
EFTA00025418

=== Page 2 ===
90A-NY-3151227 Serial 35
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027708
Re: 90A-NY-3151227, 08/16/2019
UNCLASSIFIED
2
EFTA00025419


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=== Page 1 ===
From: "Kathleen E. Cassidy"
To:
Cc: Susan Necheles
>, , Samidh Guha
Subject: RE:
Date: Tue, 31 Mar 2020 01:46:00 +0000
Attachments: 2020.03.30
2020.03.30
I forgot to attach the Exhibits. They are attached here.
Thanks,
Kate
From: Kathleen E. Cassidy
Sent: Monday, March 30, 2020 9:40 PM
Cc: Susan Necheles <
>; ; Samidh Guha
Subject:
Attached is our submission on behalf of our client
Please let us know if you have any questions. Take care and stay healthy.
Best,
Kate
Kate Cassidy
Hafetz & Necheles LLP
EFTA00024258


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=== Page 1 ===
From:
To:
Subject:
Checks
Date: Tue, 02 Jul 2019 00:53:17 +0000
Attachments: accurint_phone.xps; accurint.xps; whitepages.JPG
See attached phone records for
-
As per our conversation her cell phone number may be
relevant to her recent travels with Epstein.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00026666


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From:
)"
To: Sigrid McCawley
Cc:
)"
Subject: RE:
follow-up request
Date: Fri, 08 May 2020 19:57:03 +0000
I'm having trouble sending a calendar invite outside our systems, but here's the dial-in info:
Call-in number:
Conference ID:
From:
Sent: Friday, May 08, 2020 15:55
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
Sigrid,
Tomorrow morning would actually be fine - we'll send you a calendar invite for 11:00 a.m. Eastern time, including a
conference line number, and we'll plan to talk with you then. And just as a heads up, not that I particularly expect this will
be necessary, but similar to how we always tell witnesses that if they want to talk with their counsel privately during an in-
person meeting, we'll let her know that the same thing holds true for over the phone as well, that you two can always
have a side call at any point! And otherwise I think it will be the usual awkwardness of phone but hopefully not too bad.
thanks again,
From: Sigrid McCawley
Sent: Friday, May 08, 2020 14:46
To:
Cc:
Subject: RE:
follow-up request
If that does not work she also said she could do it this Monday morning - 10:00 Eastern (9:00 Texas) if that is better for
your team.
Just let me know.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
EFTA00025312

=== Page 2 ===
From:
[mailto:
Sent: Friday, May 8, 2020 1:59 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
Sigrid,
Thanks for getting back to us so quickly. Goes without saying that we of course would be happy for you to be on the call
as well-I should have mentioned that in my initial email. On timing, let us just check with the agents on the case to see if
that works for them, and we hope to be able to confirm with you in the next couple hours.
thanks,
From: Sigrid McCawley
Sent: Friday, May 08, 2020 13:27
To:
Cc:
Subject: RE:
follow-up request
Hello
-
said she has time tomorrow if that would work for you team. She is in Texas so an hour behind us. I
would like to be on the call as well. Would it work to do something tomorrow at 11:00 EST? Let me know. If that does not
work I can try to get other times.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 11:02 AM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
EFTA00025313

=== Page 3 ===
I unfortunately was on trial during the previous interview, but I think somewhat less time than how long it went last time.
Ordinarily we try not to go longer than about 90 minutes in any event, so I think if she is able to block out that amount of
time, that would be great - and we'll try to be as efficient as possible and hopefully take less than that. If that sounds
alright?
thanks,
From: Sigrid McCawley
Sent: Thursday, May 07, 2020 18:57
To:
Cc:
Subject: RE:
follow-up request
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - - just so she can plan?
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi Sigrid,
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day-whatever you and she would prefer.
EFTA00025314

=== Page 4 ===
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
From:
Sent: Thursday, January 16, 2020 14:35
To: Sigrid McCawley
Cc:
is
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 2:29 PM
To:
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
EFTA00025315

=== Page 5 ===
Thank you very much, Sigrid.
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To: Sigrid McCawley
EFTA00025316

=== Page 6 ===
Cc:
i
)
Subject: RE:
follow-up request
Thanks very much, Sigrid. Yes, we received the photographs from
,
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Friday, January 10, 2020 3:59 PM
To:
Cc:
)
;
)
Subject: RE:
follow-up request
Hello
,
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
) [mailto:
Sent: Friday, January 10, 2020 3:30 PM
To: Sigrid McCawley
Cc:
)
i
)
EFTA00025317

=== Page 7 ===
Subject:
follow-up request
Hi Sigrid,
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication
in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
EFTA00025318


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=== Page 1 ===
From:
To:
Subject: The Sun article
Date: Sun, 07 Jun 2020 22:47:56 +0000
https://www.thesun.co.uk/news/11805488/prince-andrew-quizzed-over-jeffrey-epstein-links/
Assistant United States Attorney
Southern District of New York
New York, NY 10007
Tel.:
Fax:
EFTA00026571


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 49 Filed 08/25/20 Page 1 of 4
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 8/25/20
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
MEMORANDUM
Defendant.
OPINION AND ORDER
ALISON J. NATHAN, District Judge:
On August 10, 2020, the Defendant filed a letter motion related to two issues. Dkt. No.
38. First, the Defendant seeks an order directing the Government to disclose to defense counsel
immediately the identities of the three alleged victims referenced in the indictment. Second, the
Defendant seeks an order directing the Bureau of Prisons ("BOP") to release the Defendant into
the general population and to provide her with increased access to the discovery materials. For
the reasons that follow, Defendant's requests are DENIED without prejudice.
I.
The Disclosure of Alleged Victims' Identities
The Defendant first seeks an order directing the Government to disclose to defense
counsel immediately the identities of the three alleged victims referenced in the indictment. Dkt.
No. 38 at 1. Her request is premature. Production of discovery, which may itself identify
alleged victims and relevant witnesses to the defense, has just begun. Moreover, the parties have
not yet engaged in discussions regarding an appropriate schedule for pretrial disclosures,
including witness lists and $ 3500 material. The Court is mindful of the factors pointed to by the
Defendant-in particular the fact that charges in this matter relate to conduct that allegedly took
place many years ago-and anticipates that such a schedule would require the disclosure of
1
EFTA00025464

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 49 Filed 08/25/20 Page 2 of 4
alleged victims and witnesses substantially in advance of trial. But that alone does not justify
such relief at this very early stage. Following the close of discovery, the parties should meet and
confer on an appropriate schedule in light of all relevant factors. If the parties are unable to
reach agreement as to a pretrial disclosure schedule, the Defendant may renew her request. The
denial is therefore without prejudice.
II.
The Defendant's Conditions of Confinement
In her August 10, 2020 letter motion, the Defendant also sought "an order directing
[BOP] to release Ms. Maxwell into the general population and provide Ms. Maxwell with
increased access to the discovery materials while she is detained so that she can meaningfully
participate in the preparation of her defense." Dkt. No. 38 at 1. The Government responded that
the BOP has modified the conditions of Ms. Maxwell's confinement so that she has access to
discovery materials thirteen hours a day, seven days a week. Dkt. No. 41 at 5. The Defendant's
reply credited the BOP's change in policy but nonetheless asked the Court to "confirm these
changes in an order to the BOP" and "that the Court order the BOP to grant Ms. Maxwell the
same privileges given to other detainees." Dkt. No. 42 at 4-5.
The Court denies this request. The BOP is providing the Defendant with conditions that
allow her access to discovery materials so that she can meaningfully participate in the
preparation of her defense. Further action by the Court as this juncture is therefore unnecessary.
Should facts on the ground change such that the Defendant is not being provided sufficient
access to her legal materials, defense counsel may seek intervention by the Court.
The Defendant also requests that the Court order BOP that Ms. Maxwell "be monitored
in the same manner as other pretrial detainees and that the Court order the BOP to grant Ms.
2
EFTA00025465

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 49 Filed 08/25/20 Page 3 of 4
Maxwell the same privileges given to other detainees." Dkt. No. 42 at 5. In a footnote, the
defense clarifies that "[a]s long as Ms. Maxwell is monitored in the same manner, and receives
the same privileges as other pretrial detainees, it is not necessary to move her to the general
population." Dkt. No. 42 at 5 n.4.
The Court sees no basis for granting the Defendant's request for an order directed to
BOP. First, the Government has assured the Court that "[a]s with all inmates, the defendant is
able to speak to her counsel behind a closed door, in an area that is visible-but not audible-to
MDC staff," thereby ensuring that Ms. Maxwell's ability to communicate with her counsel is in
no way interfered. Dkt. No. 41 at 4 n.5. And as to the more general implementation of
surveillance procedures, the Court credits BOP's duty to ensure the safety and security of the
Defendant as justifying the measures BOP has adopted. See Bell V. Wolfish, 441 U.S. 520, 547
(1979) ("Prison administrators
should be accorded wide-ranging deference in the adoption
and execution of policies and practices that in their judgment are needed to preserve internal
order and discipline and to maintain institutional security."). Nor does the Defendant provide
any basis for the Court to conclude that the level of surveillance is punitive. Dkt. No. 42 at 5.
Though pretrial detainees "may not be punished prior to an adjudication of guilt in accordance
with due process of law," Wolfish, 441 U.S. at 535, it does not follow that surveillance measures
are punitive just because the Defendant deems them "onerous." Dkt. No. 42 at 4. The
Defendant has provided the Court with no evidence, and no reason to believe, that the
surveillance measures are motivated by improper purposes.
As a result, Defendant's request is denied. To ensure that Ms. Maxwell is able to
continue to adequately participate in her defense, however, the Court hereby ORDERS the
Government to provide written status updates every 90 days detailing any material changes to the
3
EFTA00025466

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 49 Filed 08/25/20 Page 4 of 4
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal
materials and ability to communicate with defense counsel.
III. Conclusion
For the reasons stated above, Defendant's requests contained in Dkt. No. 38 are DENIED
without prejudice. Following the close of discovery, the parties shall meet and confer on an
appropriate schedule for pre-trial disclosures, including the disclosure of $ 3500 material, exhibit
lists, and witness lists, taking into account all relevant factors. The Government is hereby
ORDERED to submit written status updates every 90 days detailing any material changes to the
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal
materials and ability to communicate with defense counsel.
SO ORDERED.
Alim D. Netto
Dated: August 25, 2020
New York, New York
ALISON J. NATHAN
United States District Judge
4
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Media Inquiry: Ghislaine Maxwell
Date: Tue, 07 Jul 2020 19:15:51 +0000
Thanks, will respond.
Sent from my iPhone
On Jul 7, 2020, at 2:22 PM,
wrote:
FYI
From:
Sent: Tuesday, July 07, 2020 14:21
To:
Subject: Media Inquiry: Ghislaine Maxwell
Howdy counselors,
Could you please provide me with the defendant's mugshot as soon as it is available?
Thanks!!
Yours,
EFTA00024583


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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
October 26, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No. 02879-509)
MDC Brooklyn
Metropolitan Detention Center
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: s/
Assistant United States Attorneys
Enclosure
EFTA00024224


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=== Page 1 ===
OFFICIAL RECORD
FD-1036 (Rev. 10-16-2009)
Document
powers
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Import Form
Form Type: OTHER - Other
Date: 11/24/2020
Title: (U) Victim Services Division - Case Support Unit Assistance
Approved By:
Drafted By:
Case ID #:
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Synopsis: (U) To document victim outreach support efforts for the
November 11, 2020 ODAG briefing of the OPR findings.
Enclosure (s) : Enclosed are the following items:
1. (U) Updated Contact Information as of 11/18/2020
UNCLASSIFIED
EFTA00025005


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=== Page 1 ===
From:
)"
To:
)"
Bcc:
"
Subject: just in case
Date: Fri, 09 Oct 2020 18:29:03 +0000
Embedded: just_in_case.msg
Sender:
Subject: just in case
Message-Id:
<CY1P110MB0488A11CE04D153F6B5281D3ED080@CY1P110MB0488.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00026829


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=== Page 1 ===
SECURITY
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
April 14, 2021
BY USAfx
Jason E. Foy
Foy & Seplowitz LLC
105 Main Street
Hackensack, NJ 07601
Re: United States V. Tova Noel No. 19 Cr. 830
Dear Counsel:
This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of
Criminal Procedure. This letter and the materials identified herein are subject to the protective
order entered in this case on December 16, 2019, and have been designated as "Protected
Materials" as defined in the order where noted below. Accordingly, the materials and information
identified herein shall not be disclosed to any third party or referenced publicly except as set forth
in the protective order.
Description
Bates Numbers
Classification Pursuant
to Protective Order
Arrest documentation and signed
SDNY_00017773 -
Confidential
warrants
SDNY_00017775
Documents from the MCC including
SDNY_00017776 -
Confidential
quarters, maps, and rosters
SDNY_00017782
SDNY_00017783 -
Confidential
FBI import forms
SDNY_00017822
SDNY_00017823 -
Confidential
FBI Laboratory examination requests
SDNY_00017825
SDNY_00017826 -
Confidential
FBI process reports
SDNY_00017991
SDNY_00017992 -
Confidential
Witness statements
Anonymized index
SDNY_00018025
Attorney's Eyes Only
Additionally, the Government is producing the following materials only to your client:
06.20.2018
EFTA00024019

=== Page 2 ===
Page 2
Description
Bates Numbers
Classification Pursuant
to Protective Order
US Marshals Service Intake and Personal
SDNY_TN_00020912 —
History
Finally, while we do not agree these materials are required to be produced pursuant to Rule
16, based on your prior request for information, the Government is providing the following
information from the Bureau of Prisons ("BOP"):
Since approximately January 1, 2019, in BOP matters that resulted in sustained
administrative charges of falsification with regard to log entries, the following disciplinary
actions were taken: 2 letters of reprimand; 50 suspensions; 1 demotion; 3 terminations; and
6 resignations/retirements prior to discipline.
The BOP has records of the following inmate deaths over the last ten years at the MCC and
MDC:
Inmate Name
Register Num
DOD
Institution
Death Location
Cause of Death
Tony McClam
79490-054
9/24/2020
MCC
Housing Unit
Cardiac
Kenneth Houck
06743-015
5/19/2020
MDC
Special Housing Unit
Hanging
Eric Manson
01558-112
10/23/2019
MCC
Community Hospital
Drug Overdose
Jeffrey Epstein
76318-054
8/10/2019
MCC
Community Hospital
Hanging
Oscar Reynoso
60240-019
10/23/2015
MDC
Community Hospital
Hanging
Fang Xin He
79018-053
7/19/2012
MDC
Mental Health Unit
Hanging
The foregoing information is subject to the protective order. Please contact us with any questions.
Very truly yours,
AUDREY STRAUSS
United States Attorney for the
Southern District of New York
By:
/s/
Assistant United States Attorneys
06.20.2018
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=== Page 1 ===
From:
To: Montell Figgins
Cc:
(
Subject: U.S. V. Thomas, No. 19 Cr. 830 - Discovery Production
Date: Tue, 31 Dec 2019 17:31:41 +0000
Attachments: 2019.12.31 Letter - Production_1.pdf; SDNY_00008123_(AEO).pdf.
Counsel:
Please find attached a letter regarding the Government's discovery production in this case. We are sending a hard drive
containing the discovery materials to you. The password on the drive is
Additionally, please find
attached one additional page of discovery, which has been marked attorney's eyes only. Please contact us with any
questions. Thank you.
Regards,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
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=== Page 1 ===
From:
To:
)"
(USANYS)"
Subject: Re: Epstein
Date: Thu, 16 Jul 2020 18:47:15 +0000
Thanks
Ma'am, I'm available anytime most convenient for you via my cell
Special Agent
Diplomatic Security Service I New York Field Office
Mobile:
Follow DSS: Facebook I Flickr
I
Twitter
This email is UNCLASSIFIED in accordance with Executive Order (EO) 13526.
From:
(USANYS)
Sent: Thursday, July 16, 2020 2:25:25 PM
To:
Cc:
Subject: Epstein
- as discussed, I got a call from S/A
from State Department regarding information they received of
a person claiming to be an Epstein victim.
is copied on this email so you can coordinate next steps.
- thanks
again for reaching out.
Co-Chief, Narcotics Unit
O:
EFTA00024478


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=== Page 1 ===
From:
"
)"
To:
"
,
)
[Contractor]"
Cc:
)"
,
)"
Subject: FW:
notes
Date: Thu, 19 Dec 2019 22:14:08 +0000
Attachments: I
notes_12.17.19142818.pdf
For the Epstein share, thanks!
From:
^
Sent: Thursday, December 19, 2019 3:42 PM
To:
)
is
N. (NY) (FBI)
Subject: Re:
notes
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
)
Sent: Wednesday, December 18, 2019 10:51 PM
To:
N. (NY) (FBI)
is
;
Subject:
notes
Hi guys, would one of you please send me the notes from the
interview when you have the chance?
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
To: Sigrid McCawley
Cc:
Subject: RE: Interviews - 10/22 and 10/23
Date: Thu, 17 Oct 2019 17:04:54 +0000
Thanks very much, Sigrid. We'll keep holding that slot fo
Happy to do a video conference with
Could you please propose some dates/times that would work for you and for
her to do the conference?
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, October 17, 2019 10:08 AM
To:
Cc:
is
is
Subject: RE: Interviews - 10/22 and 10/23
Just a quick update -
has been working feverishly to try to secure her passport/visa so she can get here and I
know that
has been making efforts to help her but she doesn't have it yet. I know you are holding a slot
for her interview for Tuesday but that will depend on whether she can actually travel here.
Also -
has decided its best that she not travel but she is willing to do something via a video conference if that would
work.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
EFTA00024287

=== Page 2 ===
From:
)
[mailto:
Sent: Tuesday, October 15, 2019 4:48 PM
To: Sigrid McCawley
Cc:
is
Subject: RE: Interviews - 10/22 and 10/23
Thanks very much, Sigrid. If those times can't end up working, we can try to do some reshuffling of our own. Please let
us know, and hopefully we can work out the scheduling.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Tuesday, October 15, 2019 4:31 PM
To:
Cc:
is
is
Subject: RE: Interviews - 10/22 and 10/23
is driving in for the meeting and she said she needs to be back before the evening on 10/23 but I believe her
commute is about an hour so we may be able to set her for a different date to come into the city and meet with you.
Let me see what I can do about getting there earlier on 10/22 so you can meet with
before 2:00 on 10/22. I may be
able to have one of my partners go with her and then I could join when I arrive. Let me see what I can work out.
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Tuesday, October 15, 2019 4:05 PM
EFTA00024288

=== Page 3 ===
To: Sigrid McCawley
Cc:
is
Subject: RE: Interviews - 10/22 and 10/23
Hi Sigrid,
Thanks very much for helping us coordinate these meetings.
Meeting with
from 2pm to 4pm will work for us, thank you. We'll plan to meet with her at our office (1 St.
Andrews Plaza) on 10/22 at 2pm.
Unfortunately, our schedules are a bit tight from 4pm to 6pm on 10/22 and for most of the day on 10/23. Would
and/or
be available on 10/22 before 2pm, on 10/22 after 6pm, or on 10/23 after
5pm?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Tuesday, October 15, 2019 10:34 AM
To:
Cc:
>;
is
Subject: RE: Interviews - 10/22 and 10/23
Hello
- sorry for the delay but I have been trying to get a handle on who is coming for the meeting etc.
is a victim that I think will be helpful to your continuing investigation. She is working hard with your
victims' coordinator to see if she can get here for the meeting. If she gets her passport/visa clearance and gets to the US
then we could do an interview on the afternoon of Tuesday October 22ʳᵈ starting at 2:00 if that works. I think she will
probably take a bit longer because she was brought to the US by Epstein a number of times so maybe a lot 2 hours for the
interview (from 2-4).
is going to be attending the meeting and she said she could interview with you right after the
meeting. I believe the notice says the meeting starts at 10:00 on October 23ʳᵈ so maybe we plan to meet you at 12:00
depending on the length of the victims' meeting.
also wanted to come to the meeting. I know you met with her for a short while. If you would like to meet
with her for a more detailed interview we could do that on the afternoon of October 22nd from 4 - 6 if that works.
EFTA00024289

=== Page 4 ===
is
She would like to try to attend via skype or some kind of conference line.
I know you interviewed her sister
If you would like to also interview
I can set something up.
Let me know if that works.
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Thursday, October 10, 2019 3:39 PM
To: Sigrid McCawley
Cc:
is
is
Subject: Interviews - 10/22 and 10/23
Hi Sigrid,
Hope you're doing well. Mandy mentioned that some of your clients might be interested in being interviewed while they
are in New York on 10/22 and 10/23. We'd be happy to get times on the calendar. Would you please let us know who
would be available for interviews and what dates and times work for each client?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
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=== Page 1 ===
From:
To:
Subject: RE: Binder
Date: Mon, 22 Nov 2021 20:35:17 +0000
Attachments:
[unredacted].pdf; Exhibit_A.pdf;
Exhibit_B_[proposed_under_seal].pdf;
2021.11.19 Response to Gov Motion_to_Preclude_Expert_Testimony.pdf;
Ex._C.pdf;
final_[unredacted].pdf;
2021.11.01_JSP_Letter_to_USAO_re_Rul6_16_Disclosures.pdf; 2021-11-
21_GM_proposed_edits_to_limiting_instructions_[final].pdf;
20cr330_Temp_Sealed_Mem._Op._&_Order_11.19.21,pdf; 2021-11-
12_GM_letter_re_GX_52.unredacted.pdf;_2021-11-20_GM_reply_re_GX-52_final.p
2021.11.15_JSP_Ltr_re._EX._52.pdf;_2021.11.18_Mot_to_quash_[final].pdf;
2021.11.22_JSP_Letter_Response_to_Motions_to_Quash.pdf
Thanks! The documents are attached. It's about (1) our daubert motion, (2) GX-52, (3) Judge Nathan's opinion with some
limiting instructions and our letter response, and (4) a motion to quash a subpoena.
From:
Sent: Monday, November 22, 2021 3:23 PM
To:
Subject: RE: Binder
Hey
Happy to help, just let me know what you need.
Thanks,
From:
Sent: Monday, November 22, 2021 3:20 PM
To:
Subject: Binder
Hey
Can you help make another binder for tomorrow, or point me to a para who can
(
?)?
Thank you!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00024952

=== Page 2 ===
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=== Page 1 ===
From:
To:
Bcc:
Subject: Re: Epstein -- travel approval form
Date: Tue, 04 Feb 2020 19:11:44 +0000
Got it. I'm so sorry - tied up with Geoff.
Sent from my iPhone
On Feb 4, 2020, at 2:10 PM,
wrote:
I'm going to make some calls so if I don't pick up when you call, that's why, but I'm here and will get off the phone
and come down whenever you're available.
thanks,
From:
Sent: Tuesday, February 04, 2020 13:02
To:
Subject: Re: Epstein -- travel approval form
No problem, I'm around whenever you're back.
On Feb 4, 2020, at 12:44,
wrote:
I may run late. Don't come till I call!
Sent from my iPhone
On Feb 3, 2020, at 5:45 PM,
wrote:
That works, thanks - just let me know if your schedule changes, otherwise l'll come by at 1:00 tomorrow. Thanks
again and looking forward to it.
From:
Sent: Monday, February 03, 2020 16:07
To:
Subject: RE: Epstein -- travel approval form
Right now 1 p.m. looks open.
EFTA00026971

=== Page 2 ===
From:
Sent: Monday, February 3, 2020 1:33 PM
To:
Subject: RE: Epstein -- travel approval form
No problem at all, and I'm very flexible tomorrow afternoon - whatever time is good for you I can make work, so just
let me know and l'll put it in the calendar.
From:
Sent: Monday, February 03, 2020 13:31
To:
Subject: RE: Epstein -- travel approval form
So sorry for the delay. Maybe tomorrow? I have time in the afternoon.
From:
Sent: Friday, January 31, 2020 1:09 PM
To:
Subject: RE: Epstein -- travel approval form
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise l'll touch
base midweek if we haven't connected by then.
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right
now it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA
approval, but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final
DOJ approval this afternoon. Thank you!
And separately, if you still wanted to meet up today, l'll be around until about 3:00, but I'm also flexible next week if
that's easier.
thanks again,
EFTA00026972

=== Page 3 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00026973


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=== Page 1 ===
Event: Declined: Epstein Meeting (Please hold the time)
Start Date: 2020-01-16 19:00:00 +0000
End Date: 2020-01-16 20:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-01-11 02:42:05 +0000
Date Modified: 2020-01-11 02:42:05 +0000
Priority: 5
DTSTAMP: 2020-01-10 19:06:00 +0000
Attendee:
EFTA00024256


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=== Page 1 ===
From:
)"
To: Brian Burns
Patrick Smith
,
Cc:
)"
)"
,
(USANYS)"
Subject: Opposition to motions to quash
Date: Mon, 22 Nov 2021 23:01:25 +0000
Attachments: 2021.11.22_JSP_Letter_Response_to_Motions_to_Quash.pdf
Brian,
Attached is the defense's response to the motions to quash. The defense filed this letter temporarily under seal, and so
you're aware, we anticipate seeking redactions of the victims' private and identifying information in this letter.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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=== Page 1 ===
90A-NY-3151227 Serial 39
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027712
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027712: One (1) Western Digital
1000GB HDD, WD1003FZEX-00MK2A0, S/N WCC3F2783519, containing the Clone
Copy of 1B15 hard drive (Seagate Barracuda 500GB HDD, ST3500320NS, S/N
9QM8MT6D), collected via Tableau TX-1, S/N 000ECC58017156. Request ID
112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027712: One (1) Western Digital 1000GB HDD,
WD1003FZEX-00MK2A0, S/N WCC3F2783519, containing the
Clone Copy of 1B15 hard drive (Seagate Barracuda 500GB
HDD, ST3500320NS, S/N 9QM8MT6D), collected via Tableau
TX-1, S/N 000ECC58017156. Request ID 112048. Derivative
Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Derivative
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00025416

=== Page 2 ===
90A-NY-3151227 Serial 39
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027712
Re: 90A-NY-3151227, 08/16/2019
Number of Devices Collected: 1
UNCLASSIFIED
2
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=== Page 1 ===
From:
)"
To:
)"
Subject: FW:
follow-up request
Date: Fri, 08 May 2020 14:45:47 +0000
What do you think? Hour and a half or so??
From: Sigrid McCawley
Sent: Thursday, May 07, 2020 18:57
To:
Cc:
Subject: RE:
follow-up request
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - just so she can plan?
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi Sigrid,
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
EFTA00025295

=== Page 2 ===
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day-whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
From:
Sent: Thursday, January 16, 2020 14:35
To: Sigrid McCawley
Cc:
is
)
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 2:29 PM
To:
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
EFTA00025296

=== Page 3 ===
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much, Sigrid.
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
)
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
EFTA00025297

=== Page 4 ===
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To: Sigrid McCawley
Cc:
)
)
Subject: RE:
follow-up request
Thanks very much, Sigrid. Yes, we received the photographs from
,
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Friday, January 10, 2020 3:59 PM
To:
Cc:
)
i
)
Subject: RE:
follow-up request
Hello
,
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
EFTA00025298

=== Page 5 ===
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To: Sigrid McCawley
Cc:
Subject:
follow-up request
Hi Sigrid,
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication
in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: 2020.09.14 Debevoise SDNY Matters - FINAL.pdf updated
Date: Tue, 15 Sep 2020 22:26:46 +0000
Attachments: 2020.09.14_Debevoise_SDNY_Matters_-_FINAL.pdf
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=== Page 1 ===
From: "
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
"
(USANYS)"
Subject: RE: Briefings
Date: Tue, 19 Feb 2019 23:24:42 +0000
Importance: Normal
From:
(USANYS)
Sent: Tuesday, February 19, 2019 6:24 PM
To:
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
Subject: FW: Briefings
From:
(USANYS)
Sent: Tuesday, February 19, 2019 6:24 PM
To: Berman, Geoffrey (USANYS)
i
(USANYS)
>;
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: Briefings
I have asked the teams to get
detailed briefing memos by tomorrow, and will turn them to you by Thursday
morning, on the following:
-
Epstein
If there's anything else you'd like to include
let us know.
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re: New Case Opening
Date: Tue, 13 Aug 2019 12:30:01 +0000
Thanks.
On Aug 13, 2019, at 8:07 AM,
(USANYS)
wrote:
Good Morning
The case has been opened as follows:
1. Case: In Re: Epstein Death Investigation
USAO Number: 2019R01059
Thank you,
Legal Assistant - Criminal Clerk
United States Attorney's Office
Southern District of New York
1 St. Andrew's Plaza
New York, New York 10007
Telephone:
Cell Phone:
Fax:
EFTA00024404


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=== Page 1 ===
From:
To:
Cc:
Subject: Draft SW
Date: Mon, 01 Jul 2019 23:44:01 +0000
Importance: Normal
Attachments: New_York_Residence_SW_v3.docx
Hi
Attached please find a draft search warrant for the NY residence. I have
as the affiant, but let me know if I should
switch that to
or someone else. Also, please give me a call if you have any revisions or would like to discuss. Plan is
to swear this out on the same day as the arrest.
Thanks,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
)"
Cc:
"
)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: SDNY investigation
Date: Wed, 30 Sep 2020 15:16:10 +0000
Embedded: RE:_SDNY_investigation.msg
Sender:
Subject: RE: SDNY investigation
Message-Id:
To:
Cc:
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=== Page 1 ===
From:
Subject: FW: Requests
Date: Thu, 09 Jul 2020 14:30:49 +0000
Attachments: Hot_lists.pdf
The attached is what BOP provided in response to our request for "hot lists." What do you think about producing? It
seems to have a lot of confidential information about other inmates, and Epstein was never placed on this list. One
possible response is just to say that Epstein was never placed on the list.
From:
Sent: Wednesday, June 24, 2020 9:08 AM
To:
Subject: FW: Requests
fyi
From:
Sent: Wednesday, June 24, 2020 8:44 AM
To:
Cc:
Subject: RE: Requests
Here are a few more things from your request. I have been unable to locate any watch calls or SROs from the requested
time frame. I will continue to look for those documents. I have been told SROs were likely not completed during that time
and also that most of the Control Center paperwork (originals), to include watch call sheets, were seized by the FBI and/or
OIG shortly after the incident, and therefore are no longer in the institution.
Please let me know if you have any questions or if I can be of any further assistance.
06/23/20 3:55 PM
Thank you, my brother!
From:
Sent: Tuesday, June 23, 2020 3:53 PM
To:
Cc:
Subject: Re: Requests
I've attached all the documentation I have pertaining to the below request. I am waiting for a few things from HR and
Psychology but wanted to send you what I have right now. I highlighted the items below that are attached in this email.
Let me know if you have any questions.
EFTA00027028

=== Page 2 ===
Special Investigative Agent
MCC New York
150 Park Row
New York, NY 10007
06/12/20 1:54 PM >>>
Hi
:
Hope you and fam have been well, as well as MCC staff.
Can you please provide the following information concerning the Epstein suicide investigation:
The BOP and MCC Employee Code of Conduct, Code of Ethics, and corresponding employee acknowledgement
forms for Defendant Noel.
The MCC institutional familiarization training outline.
The BOP and MCC policy on cellmates and local Institutional Supplement on Special Housing Unit Regulations,
including Institutional Supplement/Program Statement Number P.S. NYM 5270.10.
The BOP and MCC policy on SHU quarterly training.
The Inmate Accountability Institutional Supplement/Program Statement, Number I.S. NYM 5511.08.
The Security Inspections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13.
SHU Watch Call Logs from August 9, 2019 and August 10, 2019.
All SHU Watch Call Logs completed during Defendant
assignment to the SHU post which began on June 26,
2019.
All SHU Control Center Logs completed during Defendant
assignment to the SHU post which began on
June 26, 2019.
All SHU Operations Lieutenant Log Books completed during Defendant
assignment to the SHU post which
began on June 26, 2019.
All High Risk Lists reviewed during weekly SHU meetings during Defendant
assignment to the SHU post
which began on June 26, 2019.
All SHU reports and SRO reviews completed by the SHU Lieutenant during Defendant
assignment to the SHU
post which began on June 26, 2019.
Many thx!
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c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023557.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
0166
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
2
CASE NO. 08-CIV-80119-
3
4
JANE DOE NO. 2,
5
Plaintiff,
6
-vs-
VOLUME II OF II
7
JEFFREY EPSTEIN,
8
Defendant.
/
9
10
Related cases:
11
08-80232, 08-08380, 08-80381, 08-80994
08-80993, 08-80811, 08-80893, 09-80469
12
09-80591, 09-80656, 09-80802, 09-81092
13
/
14
15
VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF
16
17
18
December 4, 2009
10:25 - 5:00 p.m.
19
20
21
22
23
Reported By:
24
Notary Public, State of Florida
Prose Court Reporting
25
0167
1
APPEARANCES:
2
On behalf of
3
JACK SCAROLA, ESQUIRE
SEARCY, DENNEY, SCAROLA,
4
BARNHART & SHIPLEY, P.A.
5
Phone:
6
7
8
On behalf of the Defendant, Jeffrey Epstein:
9
ROBERT D. CRITTON, JR., ESQUIRE
MARK T. LUTTIER, ESQUIRE
10
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
11
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12
Phone:
13
14
15
ALSO PRESENT:
16
Jeffrey Epstein, via video conference
17
Danchuk, Paralegal,
Richard H. Willits, P.A.
18
19
Stan Sanders, Videographer
Visual Evidence, Incorporated
20
21
22
23
24
25
0168
1
-
2
INDEX VOLUME II
3
-
4
5
WITNESS: DIRECT CROSS REDIRECT RECROSS
6
7 CONTINUED
8
BY MR. LUTTIER 170
9
10
11
12
EXHIBITS
13
14
15
EXHIBIT DESCRIPTION
PAGE
16
DEFENDANT'S NO. 1
11
17
Plaintiff's Notice of Serving Second
Amended Answers to Interrogatories
18
DEFENDANT'S NO. 2
29
19
Answers of Interrogatories
20
DEFENDANT'S NO. 3
119
First Amended Complaint
21
DEFENDANT'S NO. 4
254
22
Plaintiff's Notice of Serving Third
Amended Answers to Defendant's First
23
Interrogatories
24
25
0169
1
*****
2
THE VIDEOGRAPHER: We're going back on the
3
record at 2:42.
4
BY MR. LUTTIER:
5
Q. Mom -- ma'am, at the break we had just
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6
been discussing your relationship with a
You used the phrase in your testimony
8
earlier, you used the phrase "eat out." Could you
9
describe what that phrase means in the context that
10
you were using it?
11
MR. SCAROLA: We will stipulate that what
12
it means is cunnilingus.
13
BY MR. LUTTIER:
14
Q. Okay. Do you know what a sex toy is?
15
MR. SCAROLA: Could you explain what
16
relevance or materiality your understanding of
17
that line
18
MR. LUTTIER: Sure. It was
19
MR. SCAROLA: of questioning might have
20
since there is no allegation that sex toys were
21
ever employed in encounters between
and
22
Mr. Epstein?
23
MR. LUTTIER: Well, I dispute that for
24
sure. I just tell you if you read the record
25
carefully, you will find out that is not at all
0170
1
true, and that's why it is relevant. Come up
2
many a time.
3
MR. SCAROLA: In connection with
4
allegations from
?
5
MR. LUTTIER: There and in the IME.
6
MR. SCAROLA: Okay. Well, if you
7
represent, if you represent that that's the
8
case, then proceed.
9
BY MR. LUTTIER:
10
Q. Do you know what a sex toy is?
11
A. Yes.
12
Q. Okay. And what is your understanding of
13
that term so that we are understanding each other
14
when I ask you these questions?
15
A. I guess toys used doing sexual things.
16
Q. Okay. And that would include, for
17
example, vibrators?
18
A. Yes.
19
Q. Dildos?
20
A. Yes.
21
Q. Have you used sex toys in the past?
22
A. No.
23
Q. Never?
24
A. Never.
25
Q. Either -- how about with
?
0171
1
A. No.
2
Q. Did you ever tell anybody you had?
3
A. No.
4
Q. Did you, did you ever use any sex toy with
5
Jeffrey Epstein?
6
A. He tried to use a massage thing and I told him
7
no.
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8
Q. What did you mean by "massage thing"?
9
A. Whatever it was in the hell that he had.
10
Q. Well, what describe what you are
11
talking about.
12
A. I just told you.
13
Q. Well, massage thing doesn't tell me
14
anything. What are you talking about?
15
A. I don't know what it was called. I don't know
16
what it is.
17
Q. What did it look like?
18
A. It looked it was I don't know. It
19
vibrated. It looked like it was a neck massager.
20
Q. But do you know, do you know can you
21
describe, physically describe how big it was, what
22
color it was, what it looked like? Can you describe
23
anything about it?
24
A. It was gray and do you want me to draw you a
25
picture because I don't know how to describe what it
0172
1
looked like.
2
Q. How large was it?
3
A. It was like this big (indicating).
4
Q. Okay.
5
A. It was like a neck massager.
6
Q. You know like you know what Brookstone
7
is, a store?
8
A. Yeah.
9
Q. Have you ever been in there and they have
10
these massages that, like you can reach behind your
11
back and stuff like that. Are we talking about
12
something you know, like that?
13
A. Yeah, but it didn't have a wire, an electrical
14
wire.
15
Q. Okay.
16
A. It was like battery operated.
17
Q. And you say that Mr. Epstein tried to use
18
this on you and you said no?
19
A. Yeah.
20
Q. And then he
21
A. That was the end of that.
22
Q. didn't use it?
23
A. He did not, and he's never, it never was
24
brought up again.
25
Q. Have you ever desired to use any kind of
0173
1
sex toy?
2
A. No.
3
Q. And, and then not done it for some reason?
4
A. No.
5
Q. Okay. Back to
How many
6
sexual encounters would you estimate you had with
7
?
8
A. I don't know.
9
Q. What's your best estimate with what degree
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10
of frequency did you and she have a sexual
11
relationship?
12
MR. SCAROLA: Those are two different
13
questions, compound.
14
THE WITNESS: What does this
15
MR. LUTTIER: With what
16
THE WITNESS: What does this have to do
17
with me and Mr. Epstein?
18
BY MR. LUTTIER:
19
Q. With what degree of frequency did you and
20
have sexual relations?
21
MR. SCAROLA: That's the second part of
22
the question that you asked.
23
MR. LUTTIER: That's the question. I will
24
break it up then.
25
0174
1
BY MR. LUTTIER:
2
Q. You've testified earlier that you and
3
had sexual relations?
4
MR. SCAROLA: We'll stipulate that that
5
occurred on multiple occasions.
6
BY MR. LUTTIER:
7
Q. All right. Tell me with what degree --
8
MR. SCAROLA: And beyond that an inquiry
9
is intended for no other purpose except to
10
annoy, harass, and embarrass.
11
MR. LUTTIER: With all due respect, I
12
disagree. So, I am going to ask my question.
13
MR. SCAROLA: And I disagree with your
14
disagreement. And I will instruct her not to
15
answer.
16
MR. LUTTIER: Okay. Let me get the
17
question out.
18
BY MR. LUTTIER:
19
Q. On how many occasions did you and
20
have sexual relations?
21
MR. SCAROLA: And the stipulation is that
22
it occurred on multiple occasions and beyond
23
that no relevant inquiry can be made.
24
BY MR. LUTTIER:
25
Q. And when, when your lawyer stipulates that
0175
1
it's multiple occasions, if you had a relationship
2
with her for 12 months, can you estimate how many
3
times it was?
4
A. I refuse
5
MR. SCAROLA: Don't answer that question.
6
THE WITNESS: to answer.
7
MR. LUTTIER: And you refuse to answer
8
MR. SCAROLA: Because her lawyer has
9
instructed her not to answer because the
10
question is obviously intended, after the
11
stipulation, for no other purpose except to
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12
annoy, embarrass, and harass the witness.
13
MR. LUTTIER: It's, it's not intended to
14
be annoying. I believe the degree of frequency
15
is absolutely relevant in the case.
16
MR. SCAROLA: To what to which element?
17
MR. LUTTIER: Arguable well
18
MR. SCAROLA: To which element?
19
MR. LUTTIER: I don't want to
20
MR. SCAROLA: To which element of the
21
offense?
22
MR. LUTTIER: I am not going to argue my
23
case to you, but it absolutely has an effect on
24
the alleged claim of damages. Beyond that I
25
don't need to tell you the theory of my case
0176
1
but
2
MR. SCAROLA: I disagree.
3
MR. LUTTIER: Okay.
4
BY MR. LUTTIER:
5
Q. Do you, do you how did your
6
relationship with
end?
7
A. I met my son's father.
8
Q. Who is
?
9
A. Yeah.
10
Q. Did your relationship with
11
end on an amicable basis?
12
A. What does that mean?
13
Q. Well, did you she and she both agree you
14
were going to go your separate ways
15
A. Yeah.
16
Q. or did you just cut it off?
17
A. We agreed we would go separate ways.
18
Q. Did you have
name or any
19
portion of her name tattooed on your body?
20
A. Yes, I did.
21
Q. And what did you have tattooed on your
22
body?
23
A.
24
Q. And when did you have that done?
25
A. While we were when I turned 18.
0177
1
Q. So, it would have been about six years,
2
five years after your relationship ended?
3
A. Yeah.
4
Q. And why did you have her name tattooed on
5
your body five years after you ended your
6
relationship with her?
7
A. Because I felt like it.
8
Q. Did you ever rekindle your relationship
9
with
10
A. No.
11
Q. after you, after your 13th birthday?
12
A. No.
13
Q. Did you maintain contact with
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14
after you and she broke off your relationship when
15
you met
?
16
A. No.
17
Q. With respect to the incident that you were
18
describing earlier when you were at Mr. Epstein's
19
house and you said there was another woman present
20
who was nude, do you recall that testimony?
21
A. Yeah.
22
Q. And was there any discussion between you
23
and she before she began to
on you?
24
A. And I told you no.
25
Q. No words at all exchanged?
0178
1
A. No.
2
Q. So you were just standing there and
3
this
4
A. Yeah.
5
Q. And what, if anything, did you say when
6
this person began to
on you?
7
A. I didn't say anything. I just felt really
8
weird and I just stood there.
9
Q. And this is a person you had never seen
10
before?
11
A. Yes.
12
Q. And for how long a period did this person
13
on you?
14
A. I don't know.
15
Q. And this is while you were standing?
16
A. Yeah.
17
Q. Did, did it, when you say you don't know,
18
are we talking about this went on for 15 or 20
19
minutes or this went on for three minutes?
20
A. Like 15, 20 minutes.
21
Q. Okay. Did you, did you move from where
22
you were standing to some other location while she
23
was doing this?
24
A. I just said no.
25
Q. Did you have an
0179
1
A. No.
2
Q. as a result of her performing? Did you
3
at any time during the 15 or 20 minutes that she was
4
on you say anything to her?
5
A. Yeah, I told her to stop.
6
Q. And when did you tell her to stop?
7
A. After like 15 minutes, I told her to stop and
8
that I felt uncomfortable.
9
Q. And what did she do?
10
A. She stopped. And I told Jeffrey I wanted to
11
leave, and he gave me $300 and I left.
12
Q. So, the first time you told this lady to
13
stop, she stopped?
14
A. Yeah.
15
Q. And you told Jeff you wanted to leave and
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16
he didn't try to stop you?
17
A. No.
18
Q. Did you perform any sexual act on this
19
woman?
20
A. No.
21
Q. Did you touch her in any way?
22
A. No.
23
Q. And at the time that you were standing
24
there and this lady was
on you,
25
I assume she was kneeling or something?
0180
1
A. Yes.
2
Q. And where was Mr. Epstein during this?
3
A. Behind her having sex with her.
4
Q. While she was kneeling?
5
A. Yeah.
6
Q. Did you say anything to Mr. Epstein?
7
A. Besides that I wanted to leave, no.
8
Q. Which you said after 15 minutes, right?
9
A. Yeah.
10
Q. How about during the first 15 minutes, did
11
you say anything at all?
12
A. No.
13
Q. Did you say, you know, I am uncomfortable
14
with the set-up; I want to leave?
15
A. I just said no.
16
(Interruption at the door.)
17
MR. LUTTIER: At the time
18
THE WITNESS: Can you not ask me questions
19
with somebody in the room?
20
BY MR. LUTTIER:
21
Q. What do you mean not ask you questions --
22
A. That man was in here.
23
Q. Had you had any sexual relationship
24
between any other woman other than
before this
25
incident that you have described that occurred at
0181
1
Mr. Epstein's?
2
A. No.
3
Q. Have you since the incident that occurred
4
at Mr. Epstein's that you've described, where this
5
lady
on you, had any sexual
6
contact with any other female?
7
A. No.
8
Q. Did you ever have any discussion with
9
anyone else at any time with respect to your sexual
10
relationship with
11
A. What?
12
Q. Did you ever have any discussion with
13
anyone at any time about your sexual relationship
14
with
15
A. My mother.
16
Q. And when did you discuss it with your
17
mother?
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18
A. When I was with
What does
19
have to do with Mr. Epstein? This is why I am here,
20
because of Mr. Epstein.
21
Q. So, if I understand your testimony
22
correct, you would have discussions with your mother
23
about your relationship with
sometime while
24
you were 12 years of age; is that right?
25
A. Yes.
0182
1
Q. What was your mother's reaction?
2
A. She didn't have one.
3
Q. Did she say anything at all to you about
4
it?
5
A. No.
6
Q. Did you ever seek any type of counseling
7
with respect to your relationship with
?
8
A. For what?
9
Q. For anything. Did you ever discuss--
10
A. No.
11
Q. Did you ever tell any of your mental
12
health counselors about your relationship with
13
?
14
A. No.
15
Q. Is there any reason why you didn't tell
16
your mental health counselors?
17
A. Because it
18
Q. About your relationship with
?
19
A. Because it, it wasn't a problem. What is a
20
problem is you asking me about
when I am here
21
about what Mr. Epstein did to me. So, I refuse to
22
answer any more questions that you have about
23
So, move on, please.
24
Q. What is the most traumatic event that
25
occurred in your life prior to late May or June of
0183
1
2002 when you met Mr. Epstein?
2
A. There wasn't one.
3
Q. So, if I recall your testimony this
4
morning, you were raped before you met Mr. Epstein?
5
A. I have no recollection of it so if
6
Q. Wait. You were raped before you met
7
Mr. Epstein?
8
A. Yes, but I don't remember it happening, so I
9
mean
10
Q. Were you molested by a relative
11
A. Yes.
12
Q. before you met Mr. Epstein?
13
A. Yes.
14
Q. And that was your grandfather?
15
A. Yes.
16
Q. And over what period of time were you
17
molested by your grandfather?
18
A. I was a kid, a child, a baby child.
19
Q. Roughly over what period of time?
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20
A. I don't know the period of time. I was under
21
the age of six.
22
Q. And it went on for an extended period of
23
time?
24
A. I don't know how long it went on for.
25
Q. Was that a disturbing event to you?
0184
1
A. A disturbing, yes.
2
Q. Did you talk to your mental health
3
counselors and advisers about it?
4
A. I told
when I was 13.
5
Q. Were you molested by another relative of
6
yours
7
A. Yes.
8
Q. at any time? And who else were you
9
molested by?
10
A. My cousin.
11
Q. And approximately how old were you when
12
that occurred?
13
A. I don't know.
14
Q. Did you bring any, or was any action
15
brought on your behalf, lawsuit, against your
16
grandfather
17
A. No.
18
Q. as a result of him molesting you?
19
A. No.
20
Q. Did you sue the individual that raped you?
21
A. I don't know who raped me.
22
Q. Well, did you tell
in your
23
meeting with him that you called the police after
24
the rape and had the individual arrested?
25
A. No, I did not. So if he wrote that, then he
0185
1
lied.
2
Q. Okay. Well, fortunately it is videotaped.
3
MR. SCAROLA: Fortunately it is, because
4
you have not accurately reflected what is in
5
notes.
6
BY MR. LUTTIER:
7
Q. Okay. Did, did you bring a lawsuit
8
against anyone as a result of your rape?
9
A. No. How can you sue somebody for raping you
10
if you don't know who did it?
11
Q. Well, presumably at some point you went to
12
the beach with this male, correct?
13
A. Yeah.
14
Q. You got there under your own power; that
15
is you walked out there?
16
A. Yes, but I don't remember the person's name.
17
Q. And when you walked down there with this
18
person, you knew who that person was at that time?
19
A. Yes.
20
Q. And you went there with a girlfriend of
21
yours as well, did you not?
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22
A. Yes.
23
Q. And she had somebody with her?
24
A. Yes. They were her friend.
25
Q. So, you had a girlfriend who knew the name
0186
1
of this person
2
A. Yes.
3
Q. that went with you?
4
A. But I don't know where that friend is now.
5
Q. And the day or the time that you woke up
6
after this rape, the girlfriend that you went to the
7
beach with was there?
8
A. Yes.
9
Q. And presumably you could have asked her
10
what the name of this boy was?
11
A. Well, I was scared.
12
Q. Did you ask her what the name of the boy
13
was?
14
A. No, I didn't. I was scared. I was confused.
15
Q. Did she call the police?
16
A. I don't know what she did.
17
Q. But in your presence at no time
18
A. She did not.
19
Q. You represented earlier, I believe, that
20
you were in some type of car accident?
21
A. Yes.
22
Q. How many car accidents have you been in?
23
A. One.
24
Q. And in what year was that?
25
A. '08.
0187
1
Q. And did, did you bring a claim against
2
anyone as a result of any injury you suffered in
3
that accident?
4
A. I think my, I think my mom, we did, yeah.
5
Q. Well, if you did it in '08, it would have
6
been when you were an adult. You were already 18
7
years of age?
8
A. Yeah, I had just had my daughter.
9
Q. Okay. Then if, if you were an adult, you
10
would have been the one to bring the claim?
11
A. Well, my mom did it. We were at a dead stop
12
and somebody hit us and then we were hit again.
13
Q. Okay. Did you, did, did you and your mom
14
assert a claim against an insurance company or the
15
person that hit you?
16
A. Yeah.
17
Q. Did that result in getting some kind of
18
settlement?
19
A. I don't know.
20
Q. Did
21
A. I think my case is still pending with it.
22
Q. Did you, did you have a lawyer
23
representing you in that action?
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=== Page 12 ===
24
A. Yes.
25
Q. Who was the lawyer?
0188
1
A. John Carroll I think.
2
Q. And your recollection is you think there
3
is currently a lawsuit pending?
4
A. Yeah. I am not sure.
5
Q. In your answers to interrogatories you
6
were asked if you had ever been a party to a lawsuit
7
and you responded no. Has the lawsuit
8
A. Because my mom is the one that is doing it. I
9
was a passenger in her car, so I don't understand. I
10
don't know.
11
Q. Other than this lawsuit arising out of the
12
automobile accident, is there any other lawsuit in
13
which
14
A. No.
15
Q. you have ever been a party?
16
A. No.
17
Q. Was your deposition taken in the lawsuit
18
arising out of the car accident?
19
A. Something like this?
20
Q. Yes.
21
A. No.
22
Q. And is the lawsuit pending in Palm Beach
23
County?
24
A. I guess.
25
Q. In this case you've got a couple of
0189
1
lawyers. One is Mr. Willits?
2
A. Right.
3
Q. Let me see if I have got right here.
4
Yeah, Willits. And how did you get to Mr. Willits?
5
Did you know him before this action?
6
A. No.
7
Q. How was it that you got to Mr. Willits?
8
A. I looked him up.
9
Q. Where did you look him up?
10
A. In the phone book.
11
Q. Yellow Pages?
12
A. Yes, I did.
13
Q. And you were looking up what? What
14
subject matter were you looking up?
15
A. Civil attorneys.
16
Q. Had you ever met Mr. Willits before you
17
employed him to undertake your representation in
18
this matter?
19
A. Wouldn't that still fall under if I have known
20
him before this?
21
Q. I don't know. So, the first time you ever
22
laid eyes on him or communicated with him is with
23
respect to this suit?
24
A. Obviously, yes.
25
Q. Do you know an individual by the name of
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=== Page 13 ===
0190
1
Brad Edwards?
2
A. No.
3
Q. Have you ever heard his name before?
4
A. No.
5
Q. Do you know other women that have brought
6
claims against Mr. Epstein?
7
A. Yes.
8
Q. What other women do you know that have
9
brought claims against Mr. Epstein?
10
A. That's not my information to give you.
11
Q. My question stands.
12
A. I don't feel comfortable telling him.
13
MR. SCAROLA: Well, if you know the names
14
of other women who you know have brought
15
claims.
16
THE WITNESS: I know
has. I don't
17
know her last name. And I found out after I
18
filed my suit.
19
BY MR. LUTTIER:
20
Q. Anyone else?
21
A. Not that I know of, that are my friends.
22
Q. Well, my question
23
A. Me and
haven't talked since this accident
24
just for the record.
25
Q. My question wasn't limited to your
0191
1
friends. My question was did you know other women,
2
do you know other women that have brought claims to,
3
against Mr. Epstein?
4
A. Personally, no.
5
Q. Well, how would you know them if you
6
didn't know them personally?
7
A. I said no.
8
Q. Well, I'm, I'm getting the impression that
9
you're, you're being --
10
A.
is the only person that I know that has.
11
Q. And what did you mean when you answered
12
earlier to my question when I asked you if you knew
13
other women that had brought claims against
14
Mr. Epstein, you answered yes?
15
A. And you wrote down
, did you not?
16
Q. That's the only person that you were
17
referring to?
18
A. Yes.
19
Q. Have you ever heard of a lady by name of
20
?
21
A. No.
22
Q. Jane Doe?
23
A. No.
24
Q. Who all right. This person,
, how
25
do you know this person,
?
0192
1
A. She was a friend of mine.
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=== Page 14 ===
2
Q. And she was a friend of yours commencing
3
when? When did you first meet her?
4
A. I don't remember. Years ago.
5
Q. Before you went to see Mr. Epstein?
6
A. No. She, I met her through my friend
7
Q. Who - what's
's name?
8
A.
9
Q. Do you know any other girls that claim to
10
have gone to Mr. Epstein's house to perform massages
11
on him?
12
A. Do what?
13
Q. Do you know any other girls that have gone
14
to Mr. Epstein's house and claimed to have performed
15
massages on him?
16
A. Me,
, and
, those are the only girls
17
that I know.
18
Q. And how is it that you met
through
19
?
20
A. How do you meet your friends through friends?
21
Q. I have no idea. I mean, were you guys at
22
a party together, did you get on the phone with each
23
other? What did you do?
24
A. We were hanging out.
25
Q. "Hanging out," what's that mean?
0193
1
A. When you hang out.
2
Q. Were you at a function and all three of
3
you were there, for example?
4
A. Obviously we were at something hanging out.
5
Q. And did there come a time that you took
6
anyone to Mr. Epstein's house?
7
A. Yes.
8
Q. When was that?
9
A. I don't remember the times and dates but I
10
took
and
11
Q. And which did you take first?
12
A.
13
Q. And in respect to when you went to
14
Mr. Epstein's between May and June of '02 and August
15
of '03, when was it that you took
?
16
A. Bro, I don't know. I just told you I don't
17
know times and dates.
18
Q. I realize you don't know the exact time.
19
But was it in '02 or was it in '03?
20
A. If I, if you know that I don't know the dates,
21
how would you ask me if it was in '02 or '03?
22
Q. Well, what's your best estimate of how
23
many visits you had made to Mr. Epstein's before you
24
took
?
25
A. I have no idea.
0194
1
Q. More than ten?
2
A. Probably.
3
Q. How long had you known
before you
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=== Page 15 ===
4
took her to Mr. Epstein's?
5
A. I have known
for years. I met
I
6
don't know. Ask me the question again, please.
7
Q. How long had you known
before you
8
took her to Mr. Epstein's?
9
A. For about a year.
10
Q. And how did you meet
?
11
A. She lived down the street from me.
12
Q. Was she a close friend?
13
A. Yes, she was. She was my best.
14
Q. You wouldn't do anything to harm her,
15
correct?
16
A. Correct.
17
Q. By the time you took
to
18
Mr. Epstein's, you had performed massages for
19
Mr. Epstein in the total nude; is that correct?
20
A. Uh-huh.
21
THE COURT REPORTER: Is that a yes?
22
THE WITNESS: Yes.
23
BY MR. LUTTIER:
24
Q. You had already had this sexual
25
relationship with this woman that you described
0195
1
earlier at Mr. Epstein's?
2
A. Yes.
3
Q. You mentioned earlier that on these
4
occasions when you gave Mr. Epstein a massage, he
5
would masturbate I believe you said; is that right?
6
A. Yes.
7
Q. Did that occur, that is Mr. Epstein
8
masturbating, on each and every occasion when you
9
went to Mr. Epstein's from the first occasion to the
10
last occasion?
11
A. Yes.
12
Q. Did you physically see him masturbating?
13
A. Yes.
14
Q. That is there was no towel covering his
15
genitalia or anything like that?
16
A. No.
17
Q. Before you went to Mr. Epstein's for the
18
first time, you had had sexual relations with other
19
males, had you not?
20
A. Yes.
21
Q. And you'd had sexual relations with how
22
many males before you went to Mr. Epstein's for the
23
first time?
24
A. Three.
25
Q. And what did those sexual relationships
0196
1
consist of that you had had before you went
2
Mr. Epstein's?
3
A. Intercourse.
4
Q. Did had you, other than with
5
had you had any oral sex with any individual
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=== Page 16 ===
6
other -
7
A. No.
8
Q. than
before you went to
9
Mr. Epstein's for the first time?
10
A. No.
11
Q. Before you went to Mr. Epstein's for the
12
first time, had you seen any, either these males
13
that you had previous relationships with or any
14
other male masturbate?
15
A. No.
16
Q. Had you seen any pornographic materials
17
before you went to Mr. Epstein's for the first time?
18
A. No. I don't watch porn.
19
Q. Had, have you ever been photographed in
20
the nude?
21
A. No. At Mr. Epstein's, yes.
22
Q. How about any place other than
23
Mr. Epstein's?
24
A. No.
25
Q. And who photographed you in the nude at
0197
1
Epstein's?
2
A.
3
Q.
who?
4
A.
5
Q. And when in this time period that you went
6
to Mr. Epstein's did
photograph you in the
7
nude?
8
A. It had to have been in the summer. It was in
9
the summer.
10
Q. And why do you know it was in the summer?
11
A. Because it was summertime.
12
Q. And where did this photographing occur?
13
A. In Mr. Epstein's house.
14
Q. Where in the house?
15
A. Everywhere in the house, outside by the pool,
16
and outside off the dock by the Intracoastal.
17
Q. Were you photographed on more than one
18
occasion?
19
A. No.
20
Q. Let me rephrase the question. You
21
mentioned that you were photographed everywhere in
22
the house?
23
A. Yes.
24
Q. Was there
25
A. It was in the same day.
0198
1
Q. But more than one picture was taken?
2
A. Yes.
3
Q. All right. And what type of, do you know
4
what type of camera was used? Was it a digital
5
camera or a
6
A. A digital camera.
7
Q. All right.
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=== Page 17 ===
8
A. It was digital it wasn't like a digital
9
camera like, it was like a photography digital camera
10
like a professional camera, a professional digital
11
photography camera.
12
Q. Are you, are you
13
A. Not like one you buy at Wal-Mart.
14
Q. When you're describing it as a
15
professional digital camera, are you talking about a
16
camera that's got a big lens on it?
17
A. Yes.
18
Q. And did this
19
A. And there, and there was a regular digital
20
camera. She used two different cameras.
21
Q. And you say this was, in addition to being
22
in the house, was that on a dock?
23
A. Yes.
24
Q. And, and were you completely nude for all
25
of these photographs?
0199
1
A. Yes.
2
Q. So this happened in the daytime?
3
A. Yes.
4
Q. I assume the dock is out somewhere near
5
the Intracoastal?
6
A. Yes.
7
Q. Out in plain view?
8
A. But there was nobody outside. I made sure
9
there was nobody that could see me.
10
Q. Had anyone before that occasion ever
11
photographed you in the complete nude?
12
A. And I already said no.
13
Q. And how many photographs would you
14
estimate were taken?
15
A. I don't know. At least ten.
16
Q. Did you how, how is it that it well,
17
strike that.
18
Did, did
ask you if she could take
19
photographs of you in the nude?
20
A. She called me and told me that Mr. Epstein
21
would pay me $500 if there could be nude pictures taken
22
of me. And my words to her were only if you take them;
23
I will not let Mr. Epstein take them of me.
24
Q. All right. So you set the conditions
25
under which the photographs were to be taken?
0200
1
A. Yes.
2
Q. And the photographs were taken with your
3
knowledge and consent, correct?
4
A. (Witness nods head.)
5
Q. Did you ever see the photographs?
6
A. Since that day, no. I saw them on the camera.
7
I've never seen the actual photographs.
8
Q. Did you make any comment to
about
9
the photographs?
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=== Page 18 ===
10
A. Yeah, I asked them what would happen with
11
them, and she told me that they were for Mr. Epstein's
12
personal enjoyment.
13
Q. Was Mr. Epstein present when these
14
photographs were taken?
15
A. No, not to my awareness.
16
Q. You that is on the occasion that you
17
went to the house when these photographs were taken,
18
you never saw Mr. Epstein?
19
A. Yes, I didn't see Mr. Epstein. No.
20
Q. Have you ever been photographed in any
21
kind of sexual act?
22
A. No.
23
Q. Have you ever been filmed in the nude
24
A. Yes.
25
Q. -- as supposed to still pictures. When
0201
1
were you filmed in the nude?
2
A. With one of my boyfriends.
3
Q. And which one was that?
4
A.
5
Q. And when was he your boyfriend?
6
A. I was 13.
7
Q. Excuse me?
8
A. When I was 13.
9
Q. And how did you know
?
10
A. He was my boyfriend.
11
Q. Did you, what did you grow up in the
12
community with you?
13
A. We went to school together.
14
Q. Was this before or after the point in time
15
that you had your relationship with
?
16
A. It was after. Well, it was before. I
17
don't it was like during type of thing. Even though
18
she was my girlfriend, we still had boyfriends if that
19
helps you.
20
Q. Who was anyone filmed with you in the
21
nude?
22
A. No, just me and him.
23
Q. But the film was of the two of you
24
together as supposed to just you alone?
25
A. Yes.
0202
1
Q. And what were you and he doing in the
2
film?
3
A. Having sex.
4
Q. Just intercourse?
5
A. Yeah.
6
Q. And who was doing the filming?
7
A. The camera.
8
Q. So, it was placed on a tripod or
9
something?
10
A. Yeah.
11
Q. And where did the filming take place?
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=== Page 19 ===
12
A. In the privacy of our bedroom.
13
Q. At your house?
14
A. Yes.
15
Q. And when I say your house, I mean the
16
house that you were living in at the time.
17
A. No, it was his house.
18
Q. And did, obviously you were aware of the
19
fact you were being filmed?
20
A. Yes.
21
Q. Did, did
(phonetic) ask you
22
A. His name is
23
Q. Did
ask you if he could do that
24
beforehand?
25
A. Yes.
0203
1
Q. Did you indicate to him that you had any
2
reservations about it?
3
A. Did I indicate -
4
Q. Did you tell him it was okay to do it?
5
A. Yes.
6
Q. Did you guys watch the film after you did
7
it?
8
A. Yes.
9
Q. Was the film
10
A. And we laughed about it.
11
Q. Was the film ever shown to anyone else?
12
A. No. The tape was destroyed.
13
Q. For what period of time did you have a
14
sexual relationship with
?
15
A. I don't know. For as long as we dated.
16
Q. Are we talking about a year?
17
A. No. Less than that. Couple of months.
18
Q. Less than a year. How, roughly on how
19
many occasions would you estimate you had sex with
20
?
21
A. I don't know.
22
Q. Did you have it with any degree of
23
regularity? I mean, once a week, twice a week?
24
A. Once or twice a week.
25
Q. Did - when you had sex with
0204
1
when you were 13 once or twice a week, did you take
2
any precautions about getting pregnant?
3
A. Yeah.
4
Q. And what precautions did you use?
5
A. A condom.
6
Q. Have you ever had any abortions?
7
A. No.
8
Q. You have two children?
9
A. Yes, I do.
10
Q. And when was your first child born?
11
A. When I was 17.
12
Q. Do you know your child's birthday?
13
A. Yeah,
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=== Page 20 ===
14
Q. And that's the child with
?
15
A. Yes.
16
Q. And then you had a daughter with
17
?
18
A. Yes.
19
Q. And what's your daughter's birthdate?
20
A.
21
Q. And where was your child with
22
born?
23
A. Good Samaritan Hospital.
24
Q. Where was the child with
25
A. Good Samaritan hospital.
0205
1
I planned both my children.
2
Q. Did you, have you at any time lost a
3
pregnancy; that is been pregnant
4
A. Yes, I have.
5
Q. Okay. And when did that occur?
6
A. April of '08.
7
Q. Literally a month, less than a month after
8
you had
9
A. Before.
10
Q. Your child okay. Let's go back because
11
you, if I got your testimony right --
12
A. Oh, not '08. I'm sorry.
13
Q. Yeah.
14
A. My daughter was born in
It was '07.
15
Q. Okay. April of '07 is when you lost a
16
child?
17
A. Uh-huh.
18
Q. And who was the father of that child?
19
A. That's irrelevant.
20
Q. Was it someone other than
?
21
A. Yes.
22
Q. Was it
?
23
A. No, it was not.
24
Q. Was it
?
25
A. Yes.
0206
1
Q. Had, had that been a planned pregnancy?
2
A. No.
3
Q. Was that, that is the loss of the child
4
that you had with
, a traumatic event to
5
you?
6
A. No.
7
Q. And by traumatic I mean were you upset
8
about it?
9
A. No.
10
Q. And do you know why you weren't upset
11
about it?
12
A. Because it obviously wasn't meant to happen
13
because I didn't do anything for my child to die. It
14
just died inside me, so obviously it wasn't meant to be.
15
Q. And where were you at the time that that
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=== Page 21 ===
16
occurred?
17
A. That, that I was hospitalized for?
18
Q. No, when you first lost the child.
19
A. I was in New Jersey.
20
Q. Were you living in New Jersey at sometime?
21
A. Yes, I was.
22
Q. When did you live in New Jersey?
23
A. Earlier that year in 2007.
24
Q. And obviously then there had come a time
25
sometime in early 2007 when you changed your
0207
1
residency from Florida and moved to New Jersey?
2
A. Yes. And then I moved back to Florida and
3
started having a miscarriage. And I had to have an
4
operation. And the baby was dead inside me, and I was
5
five months pregnant.
6
Q. When you moved to New Jersey, did you move
7
with this
?
8
A. Yes.
9
Q. And when did you first meet
?
10
A. In '06.
11
Q. When?
12
A. '06.
13
Q. Had how would you characterize your
14
relationship with
?
15
A. Great.
16
Q. Any domestic violence?
17
A. Nope.
18
Q. Had he ever threatened you?
19
A. Nope.
20
Q. When did you first meet
?
21
A. When I was 13.
22
Q. Did you, did you meet him before you first
23
went to Mr. Epstein's?
24
A. Yes.
25
Q. Had you had a sexual relationship with
0208
1
obviously?
2
A. Yes.
3
Q. Had you had sex with
before you
4
went to Mr. Epstein's the first time?
5
A. Yes.
6
Q.
And what sexual acts had you engaged in
7
with
before you went to Mr. Epstein's?
8
A. Intercourse.
9
Q. And did you consider
to be your
10
boyfriend?
11
A. Yeah.
12
Q. And were you dating him during the entire
13
period of time that you went to Mr. Epstein's?
14
A. Yeah.
15
Q. And did
ever physically bring
16
you to Mr. Epstein's house?
17
A. Yes.
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=== Page 22 ===
18
Q. Did you ever pay
any money for
19
bringing you to Mr. Epstein's house?
20
A. No.
21
Q. Did
ever bring anyone else to
22
Mr. Epstein's house?
23
A. My brother came with us but he didn't bring
24
any other females, no.
25
Q. How about
?
0209
1
A. Oh,
and
, when I went with them. He
2
didn't bring them there by themselves.
3
Q. Let me go back and make sure my question
4
is clear. Was there, was there ever an occasion
5
that
drove a vehicle in which there were
6
other girls that were delivered to Mr. Epstein's
7
house other than just yourself?
8
A. You say delivered like we're a bunch of
9
flowers for him.
10
Q. Pick whatever, what word would you prefer,
11
dropped off?
12
A. Yes, that sounds a lot more better than
13
delivered.
14
Q. Fine. Whatever you want. Ever any
15
occasion where
brought any females that
16
he dropped off at Mr. Epstein's other than
17
A. Yes, me and
and me and
18
Q. Did
or
ever pay
any
19
money for bringing them?
20
A. No.
21
Q. Did you ever receive any money from
22
Mr. Epstein for bringing
?
23
A. Yes.
24
Q. How much did you get?
25
A. An extra $100.
0210
1
Q. And did you tell
that you were paid
2
$100 by Mr. Epstein to bring her to him?
3
A. Yes.
4
Q. And what was her response?
5
A. I want half.
6
Q. And what did you say to that?
7
A. Okay.
8
Q. So, you gave her 50 of the $100?
9
A. Yeah.
10
Q. And everybody was happy?
11
A. Yeah.
12
Q. Did you bring
on more than one
13
occasion?
14
A. Yes.
15
Q. Did you get paid $100 on each occasion
16
A. Yes.
17
Q. that you brought
? Did you tell
18
on each occasion when you got paid $100 to
19
bring her?
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=== Page 23 ===
20
A. Yes.
21
Q. And did you give her half the 100 or $50
22
every time
23
A. Yes.
24
Q. that you were paid? On how many
25
occasions did bring
and get paid $100?
0211
1
A. Three or four times.
2
Q. How much did
get paid to come to
3
Mr. Epstein's?
4
A. 200, sometimes three. I'm not sure which
5
times. Probably the times when she went there herself.
6
Q. Did
go to Mr. Epstein's on occasions
7
other than when she went with you?
8
A. Yes.
9
Q. But she had never been there until you
10
took her the first time?
11
A. Yes.
12
Q. Were you the individual that first
13
suggested to
that she go to Mr. Epstein's?
14
A. Obviously if I'm the one who brought her there
15
for the first time.
16
Q. Well, it would be possible that she could
17
have heard of Mr. Epstein from someplace else.
18
A. No.
19
Q. So the first time she heard the name
20
Jeffrey Epstein was from you?
21
A. Yes.
22
Q. And on the first occasion when you told
23
about Jeffrey Epstein, what did you tell her?
24
A. That we would go there and give him a massage
25
and he might ask you to get topless.
0212
1
Q. Did you tell her at the time that you
2
first discussed it with her everything that you had
3
experienced in going to Mr. Epstein's?
4
A. No.
5
Q. Why not?
6
A. Because I knew she wouldn't be exposed to it.
7
Q. And this was your best friend?
8
A. Yes.
9
Q. And you say you knew what?
10
A. I knew that she wouldn't be exposed to it.
11
Q. What do you mean she wouldn't be exposed
12
to it?
13
A. Because I knew that I felt uncomfortable with
14
the thing with the girl. And I told Jeffrey if he did
15
it to my friends, I would not bring them.
16
Q. Okay.
17
A. So I knew that she wouldn't have been exposed
18
to it.
19
Q. So, in your, you had some conversation at
20
some point in time with Jeffrey Epstein about
21
A. I took when he asked me to bring some girls
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22
my age, I told him that I would not bring my friend if,
23
if that situation was to occur with her because I didn't
24
like it. I felt uncomfortable, and I would not subject
25
my friend to it.
0213
1
Q. Is that the only thing that had occurred
2
when you were at Mr. Epstein's that you did not tell
3
about?
4
A. Yes.
5
Q. So, you had told
that Mr. Epstein
6
might masturbate while she was there?
7
A. Yes.
8
Q. Did you tell her that he might ejaculate
9
while she was there?
10
A. Not on her but yes.
11
Q. Well, did Mr. Epstein ever ejaculate on
12
you?
13
A. No.
14
Q. All right. What did you tell
before
15
you took her there for the first time about what the
16
state of dress that she would be in?
17
A. I just told her to wear clothes.
18
Q. Did you tell her that she may be asked to
19
be totally nude?
20
A. I said that she, she might ask to take off
21
some of her clothes. I didn't specifically say you're
22
going to have to get naked.
23
Q. But you had been, at that point in time
24
that you first took
there, you had been totally
25
nude for months while performing massages for
0214
1
Mr. Epstein, correct?
2
A. So.
3
Q. Correct?
4
A. Yes.
5
Q. But you didn't tell your best friend that?
6
A. No, because if he was going ask her, that
7
would be him asking her and that would be her own
8
decision.
9
Q. You didn't consider there to be anything
10
dangerous about going to Mr. Epstein, did you?
11
A. No.
12
Q. I mean, you never felt like you were in
13
danger when you went to Mr. Epstein's did you?
14
A. No.
15
Q. You never felt that any harm was going to
16
come to you?
17
A. No.
18
Q. And you really never had any fear about
19
going there, correct?
20
A. Correct. May I take a break to go to the
21
bathroom?
22
MR. LUTTIER: Sure.
23
THE VIDEOGRAPHER: Off the record at 3:30.
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=== Page 25 ===
24
(A brief recess was held.)
25
THE VIDEOGRAPHER: We're back on the
0215
1
record at 3:43.
2
BY MR. LUTTIER:
3
Q. You mentioned earlier that you had seen a
4
Is that
?
5
A. Yes,
6
Q. Have you consulted with any other, what we
7
call expert witness in this case, that is someone
8
that's been hired to assist you in your case, not
9
your lawyers but
10
A. No.
11
Q. Okay. Do you, have you spoken with anyone
12
else about the possibility of testifying in this
13
case?
14
A. Like who?
15
Q. Anybody.
16
A. No. Probably my son's father because he took
17
me there.
18
Q. That would be --
19
A. My mother.
20
Q. --
?
21
A. Yes. And my mother.
22
Q. And, and when did your relationship with
23
end, if it ended?
24
A. When I was 18.
25
Q. That's '05?
0216
1
A. Yeah.
2
Q. So you were with him from what did you
3
tell me, 0
4
A. '01.
5
Q. '01 to '05, correct?
6
A. Yes.
7
Q. Did there there obviously came a time
8
that you got pregnant with
?
9
A. Obviously.
10
Q. Did you and
leave the State of
11
Florida together at some point in time?
12
A. Yes.
13
Q. And approximately when was that?
14
A. It was in July when I was 16.
15
Q. '03?
16
A. Yeah.
17
Q. Is that the same time that you stopped
18
going to Mr. Epstein's?
19
A. Uh-huh.
20
Q. And is that, in fact
21
MR. LUTTIER: Did you get that answer?
22
THE COURT REPORTER: Uh-huh.
23
BY MR. LUTTIER:
24
Q. -- is that in fact why you stopped going
25
to Mr. Epstein's, because you and
were
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0217
1
leaving?
2
A. Yes.
3
Q. And where did you and
go?
4
A. To Rome, Georgia.
5
Q. And when I said, when I say that you went
6
there, did you physically move your residency to
7
start living there?
8
A. Obviously.
9
Q. And did you live with some relatives or
10
friends or something in Rome?
11
A. His relatives.
12
Q. And who would that have been?
13
A. His father and his aunt and uncle.
14
Q. When you left to go to Rome, Georgia, with
15
in July of '03, did you know you were
16
pregnant?
17
A. No.
18
Q. When did you first learn you were
19
pregnant?
20
A. In August.
21
Q. Of '03?
22
A. Yes.
23
Q. And when you learned you were pregnant in
24
August of '03 for how long had you been pregnant?
25
A. I, actually I think we left in June because in
0218
1
August I had already been three months pregnant.
2
Q. Had you and Mr., not Mr. -- had you used
3
any drugs, nonprescription drugs between June of '03
4
and August of '03?
5
A. No.
6
Q. When was the last time you had used any
7
drug for which you didn't have a prescription?
8
That's a bad question.
9
A. I don't know.
10
Q. Starting in August of '03 and going back
11
in time, when was the last time?
12
A. Probably in the beginning of '03.
13
Q. Beginning of '03--
14
A. We left, we left
15
Q. You mean January of '03?
16
A. No, if you would let me finish. We left the
17
State of Florida because we had a bad cocaine habit by
18
that point. With all the money that I received from
19
Mr. Epstein I could afford it. So, we had made a
20
decision to leave the State of Florida and I had been
21
clean for about a month and we couldn't handle it. So
22
we decided to leave the State of Florida so we wouldn't
23
have to worry about it anymore.
24
Q. So, if you left in June of '03 that means
25
your last use of cocaine would have been in May of
0219
1
'03?
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=== Page 27 ===
2
A. May, June, yeah.
3
Q. And at that point in time, that is in May
4
of '03, what form of cocaine were you using?
5
A. Powder.
6
Q. As of May of 03, had you, had you ever
7
used crack cocaine?
8
A. No.
9
Q. From May of '03, or I should say after May
10
of '03, when you became aware that you were pregnant
11
in August of '03, did you use any drugs at all
12
during your pregnancy?
13
A. No. Other than nicotine.
14
Q. Say what?
15
A. Other than nicotine.
16
Q. And you had a healthy child born
?
18
A. Yes, I did.
19
Q. Born where, at what state, Florida or
20
Georgia?
21
A. In Florida.
22
Q. Was there a point in time that you and
23
returned to Florida?
24
A. Yes.
25
Q. When was that?
0220
1
A. When I was eight months pregnant. So, in
2
February.
3
Q. Of '04?
4
A. Yeah.
5
Q. And, and why did you return to Florida?
6
A. Because it was too cold for my mother.
7
Q. And what did your mother have do with it?
8
A. My mother moved to Georgia with me when she
9
found out I was pregnant.
10
Q. And that would have been when?
11
A. Obviously
12
Q. You, you found out you were pregnant in
13
August?
14
A. I was pregnant in August.
15
Q. Did you tell her that?
16
A. Yes. And she moved up there immediately. My
17
mom had moved up there because I thought I was pregnant
18
and she was there the day I took the pregnancy test.
19
Q. And did she live, literally live with you
20
and
or live in a separate place?
21
A. She had boughten (sic) her own place.
22
Q. And she stayed there from August of '03 to
23
February of '04
24
A. Yes.
25
Q. -- continuously?
0221
1
A. Yes.
2
Q. Were you, after
, did you
3
remain -- strike that. Did you use any drugs,
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=== Page 28 ===
4
illegal drugs after
?
5
A. Yes, I did.
6
Q. When was the first time you used an
7
illegal drug after March of '04?
8
A. When I turned 18.
9
Q. Which would have been --
10
A. January.
11
Q. January of
12
A. '05.
13
Q. So, you were absolutely drug free, that is
14
you didn't use any illegal drug whatsoever from May
15
of '03 to January of '05?
16
A. Yes.
17
Q. Did you, during that period from May of
18
'03 to January '05 go to any kind of a drug
19
rehabilitation
20
A. No.
21
Q. clinic? Did you have to seek any kind
22
of
23
A. No.
24
Q. medical assistance to stop using drugs?
25
A. No.
0222
1
Q. Did you, did you use anything, patches or
2
any of the products that are available in the
3
general public to try to get off of drugs?
4
A. No.
5
Q. So, you were able on just strictly on your
6
own will
7
A. Yeah.
8
Q. -- to stop using all drugs from May of '03
9
to January of '05?
10
A. Yes.
11
Q. How would you describe your life from July
12
of '03 when you, approximately when you moved to
13
Georgia through February of '04?
14
A. Frustrating.
15
Q. And why was it frustrating?
16
A. Because I had a lot of secrets that I had held
17
from
about Mr. Epstein, and I was just felt like I
18
was losing my mind.
19
Q. Did you seek any medical attention through
20
the period from July 3rd to February '04. July of
21
'03 to February '04?
22
A. Yes, when I was pregnant, yes, I did. I went
23
to a baby doctor.
24
Q. Did you seek any mental health treatment?
25
A. No.
0223
1
Q. You say you held secrets from
What
2
secrets did you hold from
?
3
A. What exactly was happening at Mr. Epstein's
4
house.
5
Q. Well, you indicated that
took you to
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=== Page 29 ===
6
Mr. Epstein's on more than one occasion?
7
A. But he didn't know what I was doing.
8
Q. When was the first time
took you to
9
Mr. Epstein's?
10
A. I don't know.
11
Q. But we know it wasn't the first or second
12
time, right?
13
A. Yeah.
14
Q. Because on those occasions you went with
15
Jane Doe No. 102?
16
A. He only, he only took me sometimes because
17
Mr. Epstein paid for either his drivers to pick me up
18
and drop me off or a Yellow Cab.
19
Q. Well, do you recall the first, the
20
incident the first time
took you?
21
A. What do you mean the incident?
22
Q. Well, do you recall what you told him
23
first time when you had him take you?
24
A. That I was going to clean his house.
25
Q. And what did
say in response?
0224
1
A. Okay.
2
Q. Did you, the next time that he took you,
3
did you tell him anything different?
4
A. No.
5
Q. Did there ever come a time that when
6
took you to Mr. Epstein's you told him anything
7
other than you were going there to clean the house?
8
A. No.
9
Q. Did
ever ask you or, or strike
10
that. When
took you to Mr. Epstein's, did he
11
wait for you or did he come back?
12
A. He waited for me.
13
Q. And where did he wait?
14
A. Outside by the Intracoastal. It was in front
15
of the house the FBI was at.
16
Q. So, he didn't come in the house?
17
A. No.
18
Q. Did he ever meet Mr. Epstein?
19
A. Yes, he has.
20
Q. Did he ever have any discussions with
21
Mr. Epstein?
22
A. Yeah, about the Shelby Cobra that Mr. Epstein
23
has. My wires
24
THE COURT REPORTER: The what?
25
THE WITNESS: Shelby Cobra. My wire is
0225
1
stuck in this chair.
2
MR. DANCHUK: Hold on.
3
MR. SCAROLA: Let's go off the record for
4
just a second, please.
5
(A brief recess was held.)
6
BY MR. LUTTIER:
7
Q. Were you present for any discussions
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=== Page 30 ===
8
between
and Mr. Epstein?
9
A. Yes, I was.
10
Q. And where did they take place?
11
A. Outside in the driveway in front of the garage
12
that had all the cars.
13
Q. When was the last time you had contact
14
with
?
15
A. Thanksgiving.
16
Q. Of this year?
17
A. Yeah.
18
Q. And what did that contact consist of?
19
A. Eating turkey.
20
Q. Did you-all celebrate Thanksgiving
21
together?
22
A. Yes.
23
Q. You do.
24
A. We do. We celebrate every holiday together.
25
Q. And where was that?
0226
1
A. At my mother's house.
2
Q. Did you discuss with
this case?
3
A. Absolutely not.
4
Q. Has
ever discussed with you his
5
contact or discussions with Mr. Epstein?
6
A. Yes. He told me that you guys tried to hire
7
him.
8
Q. Who do you mean by "you guys"?
9
A. Mr. Epstein's law firms.
10
Q. Which firms are you talking about?
11
A. The ones that defend Mr. Epstein.
12
Q. Did you know how many law firms that is?
13
A. I have no idea. All I know is that his law
14
firms tried to hire my son's father.
15
Q. And when did he tell you that?
16
A. Last year.
17
Q. Meaning calendar year '08?
18
A. Yep.
19
Q. And was
incarcerated recently?
20
A. Yes, he was.
21
Q. And when was he incarcerated?
22
A. I believe it was was it I think it was
23
last year.
24
Q. That would be '08?
25
A. Yes.
0227
1
Q. When did he get released from
2
incarceration?
3
A. I don't know the date.
4
Q. So, did these lawyers that were trying to
5
hire him go meet him in jail? Is that what you are
6
saying?
7
A. I don't know. Mr. Epstein was in jail with
8
him.
9
Q. So, Mr. Epstein and
met each
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=== Page 31 ===
10
other while they were both incarcerated in the same
11
institution?
12
A. No. Mr.
and Mr. Epstein, or
13
and Mr. Epstein met each other while I was still going
14
to Mr. Epstein's house, but then again met while they
15
were incarcerated together.
16
Q. Did
ever share with you what he told
17
Mr. Epstein about you?
18
A. No.
19
Q. Did he ever tell you that he discussed you
20
with Mr. Epstein?
21
A. Yes.
22
Q. But he didn't tell you what he said?
23
A. No.
24
Q. Did he ever tell you what he said about
25
what information you knew about Mr. Epstein before
0228
1
you went
2
A. No.
3
Q. to see him the first time? Did he ever
4
tell you about what you told the other girls before
5
you took them to Mr. Epstein's?
6
A. No.
7
Q. Did he ever tell you that he attempted to
8
get employment from Mr. Epstein?
9
A. Yes.
10
Q. And what did he tell you Mr. Epstein said
11
in response to that?
12
A. I have no idea. But if you would like to let
13
me know, go ahead.
14
Q. Is
, as far as you know, an
15
honest person?
16
A. No.
17
Q. He is not honest?
18
A. Absolutely not.
19
Q. So you wouldn't believe what he says?
20
A. No. Would you?
21
Q. No meaning that my statement is correct,
22
you would not believe what he says?
23
A. That's what I am saying.
24
Q. So, you don't really believe the statement
25
he made to you that, what somebody tried to hire --
0229
1
A. No, I believe that you guys tried to hire him.
2
Q. How do you decide which statements he
3
makes you believe and which you don't?
4
A. He showed me the address.
5
Q. The address of what?
6
A. Your guys's law firm.
7
Q. Well, you keep saying, you guys. What
8
firm is that?
9
A. The attorneys on Mr. Epstein's side off of
10
Flagler Drive.
11
Q. And did he tell you, did
tell
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=== Page 32 ===
12
you that he came to meet with those lawyers?
13
A. Yes, he did.
14
Q. Did he tell you whether or not every
15
single word he said had been recorded?
16
A. I have no idea. He didn't tell me anything
17
about it.
18
Q. Did he tell you who-all was present at the
19
meeting?
20
A. No, he didn't.
21
Q. He didn't tell you anything about what he
22
said at that meeting, did he?
23
A. No.
24
Q. And in particular he didn't say what he
25
said about you, did he?
0230
1
A. No.
2
Q. You didn't ask him either, did you?
3
A. I did and he wouldn't tell me.
4
Q. Did you wonder why he wouldn't tell you
5
what he had told Mr. Epstein's lawyers about you?
6
A. No, and I could really care less because he
7
didn't go through half the traumatic things I did with
8
Mr. Epstein.
9
Q. Well, what traumatic things did you go
10
through?
11
A. Well, being that I was an underage girl with
12
an old man masturbating in front of me and bribing me
13
with hundreds and hundreds of dollars
14
Q. And how did that, how did that result in
15
any injury to you?
16
A. Well, my mental stability is nothing like it
17
used to be before I met Mr. Epstein.
18
Q. What do you mean by mental stability?
19
A. I'm scared to go places by myself. I have
20
trust issues with people now. I don't like when older
21
guys stare at me.
22
Q. Well, after you worked -- anything else?
23
A. Oh, no, you can go ahead.
24
Q. No, I want to get all your injuries that
25
you claim you have suffered as a result of going to
0231
1
Mr. Epstein's. Anything else?
2
A. You may continue.
3
Q. Is there anything else or have you now
4
told me everything and I will go back and ask you
5
about it?
6
A. You can continue asking me questions.
7
Q. Is there any other way you suffered any
8
damage as a result of going to Mr. Epstein other
9
than your mental stability is not the same, you're
10
scared to go places by yourself, that older guys,
11
you don't like it when older guys stare at you.
12
A. I have trust issues.
13
Q. Trust issues. Anything else?
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=== Page 33 ===
14
A. I don't know right now.
15
Q. Do you know of any way you suffered any
16
damage?
17
A. What?
18
MR. SCAROLA: Well, you have already heard
19
repeatedly
20
MR. LUTTIER: No speaking Other than
21
what you have told me in this deposition.
22
MR. SCAROLA: That's fine.
23
BY MR. LUTTIER:
24
Q. Okay. Is that it?
25
A. Yeah, that's it.
0232
1
Q. Okay. Now, what do you mean when you say
2
you have trust issues.
3
A. Exactly what I said.
4
Q. Well, I don't understand that. Explain
5
that. Explain that to me. What do you mean you
6
have trust issues?
7
A. I have trust issues with people.
8
Q. Meaning what, you can't trust people?
9
A. No, I can't.
10
Q. Anybody?
11
A. Guys particularly.
12
Q. Males?
13
A. Males, older males.
14
Q. Any males, older males?
15
A. Yes.
16
Q. What age male does it have to be for you
17
not to be able trust them?
18
A. Older than myself.
19
Q. So, any man that is older than you, you
20
don't feel like you can trust him?
21
A. No.
22
Q. How has that impacted you in your daily
23
life?
24
A. Well, I go outside and there is men
25
everywhere.
0233
1
Q. Okay. So, what effect does that have on
2
you? You can't trust the people
3
A. Exactly
4
Q. -- according to you?
5
A. -- it. I can't trust nobody.
6
Q. So, you're not asking them to do anything
7
or do anything for you, are you?
8
A. No, because I don't want them to.
9
Q. Okay. So, help me understand how has this
10
impacted you at all that you claim you can't trust
11
men that are older than you?
12
A. Because I can't trust them. What else do you
13
want me to say?
14
Q. Well, I want you to describe how
15
A. I can't
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=== Page 34 ===
16
Q. How your damage what is it that you
17
want these men to do
18
A. Nothing, I don't want them to do anything.
19
Q. that wait a minute.
20
A. I want them all to leave me alone.
21
Q. What is it that you want these men to do
22
that you can't trust them to do?
23
A. There is nothing that I don't want, that I
24
want them to do.
25
Q. Have you ever asked a man older than you
0234
1
to do something?
2
A. Other than my attorneys, no.
3
Q. All right.
4
A. No offense to you guys.
5
Q. So, there has never been an occasion since
6
you last went to Mr. Epstein where you asked a man
7
that was older than you to do something and you
8
counted on trusting them?
9
A. I counted well, my attorneys, but that's
10
it.
11
Q. Okay. But there has never been a time
12
that you've placed your trust
13
A. I refuse
14
Q. Wait a minute.
15
A. No, I don't let them, allow them.
16
Q. Now, so, you haven't even attempted to,
17
quote, to use your words, trust a man that's older
18
than you since you last saw Mr. Epstein; is that
19
correct?
20
A. Yes. That's correct.
21
Q. Now, when you say trust, do you mean you
22
don't want to be in their physical presence?
23
A. I don't, no, I don't want to be in their
24
physical presence.
25
Q. But in fact as you testified earlier, you
0235
1
worked for at least two escort services where you
2
have gone out and been paid to be in the presence of
3
men older than you, correct?
4
A. Correct.
5
Q. Didn't feel like you were in any kind of
6
danger, right?
7
A. No, sometimes I did. And I already told you
8
those times.
9
Q. Well, you wouldn't have gone if you
10
thought you were in any danger, would you?
11
A. Exactly.
12
Q. Okay. So there were many occasions that
13
the driver came and got you, and you were going out
14
with somebody at the escort services where they were
15
older than you and you had no fear of anything;
16
isn't that right?
17
A. Yes.
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18
Q. By the way, when you worked for these
19
escort services, would they call you up and tell you
20
on such-and-such a day there is somebody that wants
21
to go out with you? Is that how it was done?
22
A. Yes.
23
Q. What would they tell you about the person
24
that wanted to go out with you, if anything?
25
A. They would tell me where, what the occasion
0236
1
was, what I would be doing, what kind of wear I would
2
have to wear, formal, outside, the type of dress I
3
needed to wear.
4
Q. Did they well, what specifically did
5
they tell you about what you had to wear? Did they
6
tell you, describe what kind of clothes or just--
7
A. I just said formal.
8
Q. But did they say, for example, wear
9
something that's low cut or don't wear a bra or, you
10
know, wear this or wear that?
11
A. No.
12
Q. Or this is just a formal or this is a
13
semi-formal occasion?
14
A. It's a formal or semi-formal for the fourth
15
time now I am telling you. So I am done answering
16
questions about that.
17
Q. What else did they tell you other than
18
what to wear?
19
A. Nothing.
20
Q. Did they tell you anything at all about
21
the person with whom you would be going out?
22
A. Sometimes.
23
Q. And with what degree of frequency would
24
they tell you about the person that you were going
25
out with? Did they always do that?
0237
1
A. Sometimes. I just said sometimes.
2
Q. More than half the time?
3
A. Sometimes. If it was
4
Q. More than half
5
A. more than half the time, I would have said
6
more than half the time, but it's sometimes.
7
Q. So that was
8
A. Sometimes yes and sometimes no, sometimes.
9
Q. Would you estimate that it was less than
10
half the time?
11
A. I'm not answering that question seriously
12
because I have said sometimes.
13
Q. Describe sometimes to me by percentage.
14
A. I don't know the percentage of sometimes.
15
Sometimes.
16
Q. Well, let's we all know what 50 percent
17
is, right?
18
A. So 50 percent. There you go. There is your
19
sometimes.
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20
Q. Don't let me put words in your mouth,
21
ma'am. You were there, not me.
22
A. I said sometimes.
23
Q. If you could just tell me if it was more
24
or less than 50 percent of the time?
25
MR. SCAROLA: And you have been told
0238
1
repeatedly that she is unable to do that for
2
you.
3
BY MR. LUTTIER:
4
Q. So, how can you quantify for me by
5
definition your phrase sometimes?
6
MR. SCAROLA: And the answer to that
7
question is she's been unable to. So we're
8
sorry that we can't give you more specific
9
information. But "sometimes" obviously means
10
more than once and less than always.
11
THE WITNESS: So you figure it out.
12
BY MR. LUTTIER:
13
Q. Well, now, ma'am, it would be hard for me
14
to do that. I wasn't there. So, it could have been
15
as much, according to your definition, as 99 percent
16
of the time, right?
17
MR. SCAROLA: At this point those
18
questions are annoying, embarrassing, and
19
harassing, and I will instruct the witness not
20
to answer.
21
BY MR. LUTTIER:
22
Q. What else, if anything, were you told
23
about the individuals that you were going to be
24
going out with when you were working for the escort
25
services?
0239
1
A. What does this have to do with the original
2
question at hand?
3
Q. If you can just answer my question now.
4
A. And I already told you what they would tell
5
me.
6
Q. Were you told anything else?
7
A. No.
8
Q. Were you told the person's name?
9
A. Yes.
10
Q. All right. Were you told the person's
11
name each time?
12
A. Yes.
13
Q. All right. So there's a piece of
14
information that you got every time. Were you told
15
the person's age?
16
A. No.
17
Q. Ever?
18
A. No.
19
Q. Did you tell the people at the escort
20
service that you only wanted to go out with people
21
of a certain age bracket?
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22
A. No.
23
Q. You had to it was like a come and take
24
all? You had to go out with whoever they said?
25
A. Yes.
0240
1
Q. Did you have the right to say no to
2
somebody?
3
A. Yes.
4
Q. Did you ever, did they ever call you and
5
say they had someone for you to go out with and you
6
said, no, I don't want to go out with them?
7
A. No.
8
Q. So everybody that was ever, I will say
9
offered to you, you accepted?
10
A. Yes.
11
Q. What's your best estimate about how many
12
escorts you had between these two escort services?
13
A. I don't know.
14
Q. More than 50?
15
A. No.
16
Q. More than 25?
17
A. No. About 25 people.
18
Q. Were you told the person's race?
19
A. Yes.
20
Q. Did you give the escort service any
21
criteria about the type of person you would agree to
22
go out with?
23
A. Yes.
24
Q. What criteria did you give them?
25
A. I wouldn't go out with black guys because
0241
1
black people are abusive and controlling. And I have, I
2
just felt unsafe. And I would only go out with people
3
that didn't want sex or anything sexual.
4
Q. So you said no black guys and you said no
5
one that wants anything, sex or anything that's
6
sexual?
7
A. Yes.
8
Q. Did you have to describe for the escort
9
service
10
A. No, I didn't.
11
Q. what you meant by sexual?
12
A. Anybody in their right mind what know what
13
sexual and sexual things are.
14
Q. So, you didn't give them any age bracket,
15
right?
16
A. No.
17
Q. You didn't give them a weight bracket,
18
correct?
19
A. No.
20
Q. And on how many occasions did you have men
21
that you went out with that were older than you?
22
A. Every time.
23
Q. Did you ever have to seek any kind of
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24
medical care or attention after going out with one
25
of these individuals that was provided through an
0242
1
escort service?
2
A. No.
3
Q. Did you ever seek any kind of mental
4
health counseling?
5
A. No.
6
Q. Or mental health services as a result of
7
having gone out with anyone through the escort
8
service?
9
A. No.
10
Q. Were you ever physically hurt in any
11
manner whatsoever as a result of going out with
12
anyone through one of these escort services?
13
A. Would that qualify under me having to seek
14
medical attention?
15
Q. No. Were you ever hurt in any manner as a
16
result of going out with anyone through any of these
17
escort services?
18
A. No.
19
Q. After you quit going to Mr. Epstein's, did
20
you work at one or more topless bars or
21
establishments?
22
A. No.
23
Q. Have you ever worked at a topless
24
establishment?
25
A. I was a stripper for one night.
0243
1
Q. And where?
2
A. For three hours, not even.
3
Q. Where was that?
4
A. I don't remember the name. I think it was
5
Platinum Showgirls or something.
6
Q. And when was that?
7
A. I don't remember the year.
8
Q. Was it after Mr. Epstein?
9
A. Yes. I left because I felt degraded.
10
Q. During the time that after you left
11
strike that. After you last went to Mr. Epstein
12
which you say is in August of '03, did you have a
13
normal sexual relationship with
?
14
A. No.
15
Q. Were you having sex with him as frequently
16
as twice a day?
17
A. No.
18
Q. Have you ever told anyone that that's what
19
you did?
20
A. No.
21
Q. Was there ever a time that you had sex
22
with
twice a day?
23
A. Yes.
24
Q. When was that?
25
A. Before Mr. Epstein.
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0244
1
Q. And when did it change?
2
A. When I started going to Mr. Epstein's.
3
Q. And what did it change to?
4
A. To once or twice a week.
5
Q. And why did it change?
6
A. Because I felt disgusting.
7
Q. Did there ever come a time after you went
8
to Mr. Epstein's that you resumed having sexual
9
relationships with the same degree of frequency with
10
or anyone else?
11
A. With what?
12
Q. With
?
13
A. What do you mean?
14
Q. Did there ever come a time --
15
A. That I went back to the same
16
Q. Right.
17
A. No.
18
Q. Did you have sexual relationships with
19
?
20
A. Yes.
21
Q. And you met him after Mr. Epstein, right?
22
A. (Witness nods head.)
23
Q. Did you have a normal sexual relationship
24
with him?
25
A. Yes.
0245
1
Q. With what degree of frequency did you have
2
sex with him?
3
A. Once, twice, or three times a week.
4
Q. As often as you wanted it?
5
A. As often as I could stand it.
6
Q. Did you have it as often as he wanted it?
7
A. No.
8
Q. Did you have a baby with him as well?
9
A. Yes.
10
Q. And the baby that you had with
, that
11
baby's name is what?
12
A.
13
Q. And have you what is known as relinquished
14
your parental rights for
?
15
A. No, but I see my son as often as I would like.
16
And as fast as I get out of here is as fast as I can go
17
pick him up.
18
Q. You say you did not relinquish your
19
parental rights?
20
A. I did not.
21
Q. Was
,
that is your son, ever taken
22
away from you?
23
A. I signed my parental rights over to his
24
aunt
25
Q. Okay. Well, that's what I meant by the
0246
1
word--
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2
A. for his financial stability.
3
Q. Maybe you didn't understand what I meant
4
by the word relinquished. Did you ever give up or
5
sign away your parental rights to your son,
?
6
A. Yes, I did.
7
Q. Would you explain the facts and
8
circumstances surrounding you doing that?
9
A. I was not financially stable enough to take
10
care of him.
11
Q. And how about
, your boyfriend, the
12
father of your son?
13
A. He doesn't have rights to him either.
14
Q. And was there a legal proceeding brought
15
to get that accomplished?
16
A. Yes, there was.
17
Q. And who brought that legal proceeding?
18
A. What do you mean who brought that?
19
Q. Who, who filed, who was the moving party?
20
Did DCF bring that proceeding?
21
A. Yes.
22
Q. And as part of that proceeding, did DCF
23
tell you that they were going to take away your
24
parental rights if you didn't sign them off?
25
A. No.
0247
1
Q. And was that action brought here in Palm
2
Beach County?
3
A. Yes.
4
Q. And isn't it true that you, that DCF told
5
you you had no choice but to either voluntarily sign
6
over your rights, or they were going to take your
7
son?
8
A. No.
9
Q. What did they tell you about what your
10
choices were?
11
A. They told me I had to go through classes and
12
all kinds of things. But I still, whether I did the
13
class or not, I wouldn't have been financially stable
14
enough to take care of my son. So, I signed my rights
15
over to his aunt who was financially able to take care
16
of my child.
17
Q. And you, in fact, had gone to court and
18
gotten a child support award from
, had you
19
not?
20
A. A child support order?
21
Q. An award of child support from, from
22
You filed a judicial action and made a
23
complaint against him said you wanted child support?
24
A. That's when I still had my son, yes.
25
Q. All right. So, so, and the court entered
0248
1
an order that said he had to pay you a certain
2
amount of child support, right?
3
A. Which he never did.
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4
Q. Did that child support ever come to your
5
mother, for example?
6
A. We never got child support from
7
Q. Did you ever have a complaint that your
8
mother was taking your child support?
9
A. No.
10
Q. Did you ever complain to anyone that your
11
mother was taking your child support?
12
A. No.
13
Q. And your daughter's name is what?
14
A.
15
Q. Well, is it, is it
16
A.
17
Q. Does it cause you any kind of upset that
18
you have signed over your parental rights to your
19
son
?
20
A. Of course I am upset about it, but I did what
21
was best for him.
22
Q. Do you have parental rights for your
23
daughter
?
24
A. No, I do not. I signed my rights over to her
25
grandmother.
0249
1
Q. And did DCF bring an action to take away
2
your parental rights in that case?
3
A. They tried.
4
Q. And as a result of that did you
5
voluntarily relinquish your rights?
6
A. Yes, I did.
7
Q. And again did DCF insist that in order for
8
you to see your child, you would have to do certain
9
things?
10
A. Yes.
11
Q. And did you decide that what you would do
12
is sign over parental rights rather than do those
13
things?
14
A. No, I, I did some of the things that I was
15
supposed to do.
16
Q. Do you know what a performance agreement
17
is?
18
A. No.
19
Q. Did you do all the things that DCF said
20
you had to do?
21
A. Everything except for domestic violence class.
22
Q. And did DCF say that as a result of you
23
not doing everything, they were going to take your
24
child away?
25
A. They said they were going to terminate my
0250
1
rights, so I signed my parental rights over to
2
3
Q. So, in both the situation involving your
4
son and your daughter, DCF had told you --
5
A. Yes.
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6
Q. -- before you signed over your rights that
7
they were going to terminate your rights?
8
A. Yes.
9
Q. And is it also distressing to you that you
10
had to relinquish your rights to your daughter
11
?
12
A. Of course it's distressing.
13
Q. And where does
live?
14
A. In Texas.
15
Q. How often do you see her?
16
A. Once a month.
17
Q. And how is it that you see her?
18
A. Her grandmother brings her here.
19
Q. And
father is a guy name
20
?
21
A. No. His first name is
22
Q. What's his last name?
23
A.
24
Q. Now, has
ever been
25
violent to you?
0251
1
A. Yes.
2
Q. When was he violent to you?
3
A. When I was pregnant.
4
Q. What did he do?
5
A. He slapped me.
6
Q. And where were you when that happened?
7
A. At a restaurant.
8
Q. Was that distressful to you?
9
A. Yeah.
10
Q. Upset you at the time?
11
A. Obviously.
12
Q. Was, was that the first time a man had
13
been physically violent towards you?
14
A. No.
15
Q. Who was the first person --
16
A.
17
Q.
-- that was physically violent? And what
18
did
do to you that was vio -- physically
19
violent?
20
A. He held a gun to my head.
21
Q. And when was that?
22
A. I don't remember the time and day.
23
Q. Was that before you went to Georgia?
24
A. Yes.
25
Q. And was that while you were going to
0252
1
Mr. Epstein?
2
A. Yep, it was while I was going to
3
Mr. Epstein's.
4
Q. And was, did he hold a gun to your head
5
because he thought you had been cheating on him?
6
A. Yeah, but not with Mr. Epstein.
7
Q. And had you, in fact, been cheating on
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8
him?
9
A. No. He was cheating on me with
10
Q. That is he had sexual relations with
,
11
your best friend?
12
A. Yes, yes.
13
Q. And when did that happen?
14
A. I don't know the time and date.
15
Q. While you were going to Mr. Epstein?
16
A. Yes.
17
Q. Did you know that your then boyfriend,
18
had had sexual relations with your
19
best friend,
, before you took her to
20
Mr. Epstein's?
21
A. No.
22
Q. Did you ever discuss with
the fact
23
that she had had sex with your boyfriend?
24
A. Yes.
25
Q. And what was her response?
0253
1
A. She was sorry.
2
Q. And have you two mended your ways since
3
then?
4
A. Absolutely not.
5
Q. You no longer associate with her?
6
A. Hell, no.
7
Q. And is it because that you're upset that
8
she had sex with
while you were dating
9
him?
10
A. Yeah.
11
Q. Is there any other reason? Was there any
12
other rift between the two of you?
13
A. No.
14
Q. Did, did you and she have this
15
confrontation before you stopped going to see
16
Mr. Epstein?
17
A. Yes.
18
Q. And as a result of
having
19
sexual relations with
, did you have sexual
20
relations with somebody else?
21
A. Yes, I did.
22
Q. Who did you have sex with?
23
A.
best friend.
24
Q. Sort of like as they say, what's good for
25
the goose is good for the gander?
0254
1
A. A tit for a tat. Yes, it was.
2
Q. And who was
best friend.
3
A.
4
Q. What's
last name?
5
A. I don't remember.
6
Q. Is the person you had sex with you, you
7
can't remember his last name?
8
A. I can't remember his last name. I'm sorry.
9
Q. Did you have have you had sex with more
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10
than one person whose name you can't remember?
11
A. No.
12
Q.
the only person?
13
A. I can't remember his last name.
14
Q. Well, you recently filed some answers,
15
some amended answers to interrogatories. Let me --
16
MR. LUTTIER: What number are we on?
17
THE COURT REPORTER: Four.
18
THE WITNESS: Exhibit 4.
19
MR. LUTTIER: These are, I think, Jack,
20
are the ones I was talking about.
21
BY MR. LUTTIER:
22
Q. Let me show you what's been marked as
23
Exhibit 4 which purport to be your Third Amended
24
Answers to Defendant's Interrogatories. These do
25
not contain a signature by you. So I would like you
0255
1
to look at those, and tell me if the answers are
2
true and correct and complete.
3
A. Yeah, those are the people that I have had sex
4
with in my life.
5
Q. Okay. Well, you have answered
6
A. I didn't put
name. Would you like me
7
to reapply it?
8
Q. You actually answered one, two, three.
9
You have three answers that you have amended here.
10
So, I want you to look at all three, and now while
11
you're under oath, I am going to ask you if these
12
answers are true and correct and if they are
13
complete.
14
So, if you need to take some time, fine.
15
When you're done, let me know and I'll
16
A. Yeah, they're all right.
17
Q. Okay. With, with the following exception,
18
right, in 18, in answer to 18 there should be
19
another person's name,
somebody?
20
A. Yep.
21
Q. And where would he fit in in terms of the
22
chronology here?
23
A. Between
and
24
Q. Now, you said that you dated
I
25
don't know where it is -- from 2001 to 2005. In
0256
1
your answers to interrogatories, you indicate that
2
you had sexual intercourse with
when
3
you were 15 to 16 years old?
4
A. So
5
Q. So. does this mean that you had sex with
6
while you were dating
?
7
A. Yes.
8
Q. Did
know about that?
9
A. Yes.
10
Q. Did you tell him about it before it
11
happened?
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12
A. No.
13
Q. How did it happen that you had sex with
14
while you were dating
?
15
A.
went to Georgia.
16
Q. Okay. So
17
A. So,
went to Georgia.
18
Q. He went to Georgia without you?
19
A. Obviously.
20
Q. When did he go to Georgia in relationship
21
to the testimony --
22
A. To see-
23
Q. you gave me earlier
24
A. To see
25
Q. -- that you went there in June of '03?
0257
1
A. He went with his family when we first started
2
dating like, well, towards the first year we were
3
dating.
4
Q. Before you went and saw Mr. Epstein?
5
A. Yeah.
6
Q. All right. So the sex that you had with
7
is sex that you had prior to the
8
time that you first met Mr. Epstein?
9
A. No.
10
Q. When you say that you dated
from
11
January, from '01 to '05 and that that was
12
continuous
13
A. Right.
14
Q. Was he living in Georgia part of the time?
15
A. No. He went there on vacation.
16
Q. Okay. So how long was he gone for this
17
vacation?
18
A. I don't remember. Like a week.
19
Q. All right. So, while he was gone on
20
vacation for a week during the period of time that
21
you were dating him between 2001 and 2005, you had
22
sexual relations with
?
23
A. Yes, I did.
24
Q. And, and did you tell
about it after
25
the fact?
0258
1
A. Yes.
2
Q. And that wasn't any problem for you? You
3
didn't have any trust issues with
at the
4
time?
5
A. No, I didn't have trust issues with
6
Q. So, by, by your acknowledgment in these
7
answers to interrogatories before you ever went to
8
Mr. Epstein's house the first time, you had had
9
sexual relations with
10
,
and somebody whose last name you
11
can't remember, and
12
A. And that's it.
13
Q. And
?
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=== Page 46 ===
14
A. No.
15
Q. Not
but up through
?
16
A. Yes.
17
Q. And, and the, the relationship you
18
testified about earlier with
Now, during this
19
period of time with
between '01 and
20
'05, tell me about what the facts and circumstances
21
were surrounding him holding a gun to your head?
22
A. He cheated on me with
and I suppose he
23
felt guilty about it. So, he tried to say I was
24
cheating on him and I wasn't cheating on him. He was
25
cheating on me and felt guilty, and then decided he was
0259
1
going to try to kill me.
2
Q. And you were afraid where were you when
3
this gun was held to your head?
4
A. In the middle of a field.
5
Q. Where?
6
A. In West Palm Beach.
7
Q. And you were fearful at that time that he
8
might shoot you?
9
A. Obviously.
10
Q. Well, can would you agree that it was a
11
traumatic event to you to have somebody hold a gun
12
to your head?
13
A. Wouldn't it be for you?
14
Q. I would assume so.
15
A. Yeah.
16
Q. As they say you see your life flash before
17
your eyes?
18
A. I guess.
19
Q. Did you ever seek any kind of counseling
20
or treatment for that traumatic event?
21
A. No.
22
Q. Had anyone else ever threatened your life
23
other than
as of that time?
24
A. No.
25
Q. Has anyone ever threatened your life since
0260
1
that event?
2
A. No.
3
Q. Have you ever been affiliated with a gang?
4
A. No.
5
Q. Have any of the individuals that you have
6
dated ever been affiliated with a gang?
7
A. No.
8
Q. Have you been present when
9
claimed that he was affiliated with a gang?
10
A. Nope.
11
Q. Have you told others that you cannot
12
answer the question about whether you're affiliated
13
with a gang because if you did, it would risk
14
personal harm to you?
15
A. No. I said I can't speak for anybody else if
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16
they're in a gang because I don't know about it. And if
17
they were in a gang, it's none of my business to let
18
anybody else know about it. I can't tell somebody
19
something about somebody else if I don't know if it's
20
true or not.
21
Q. Have you ever participated in any gang
22
membership ritual?
23
A. No.
24
Q. For approximately how long did the event
25
take place that
held a gun to your head?
0261
1
A. Like five minutes and then we kissed and made
2
up and had sex.
3
Q. In the field?
4
A. Yep.
5
Q. Isn't it a fact that you told
6
that he held a gun on your head for a good hour?
7
A. No. We were arguing for an hour. He didn't
8
hold the gun to my head for an hour. That doctor is on
9
some other shit.
10
Q. And you genuinely feared that you were
11
going to die on that occasion, did you not?
12
A. Well, somebody holds a gun to your head, I am
13
pretty sure that anybody would feel that they are going
14
to die.
15
Q. Was there another occasion that
16
was physically violent towards you?
17
A. Yes.
18
Q. When was that?
19
A. When he tried to drown me in a canal.
20
Q. When was that?
21
A. I don't recall.
22
Q. Was it before you went to Georgia or
23
after?
24
A. Before.
25
Q. Was it while you were going to
0262
1
Mr. Epstein's?
2
A. Yep.
3
Q. Did you tell Mr. Epstein about it?
4
A. Yes, I did.
5
Q. And when did you tell Mr. Epstein about
6
it?
7
A. On one of the occasions I went to his house.
8
Q. And what did he say?
9
A. I don't know. He talked to me about it.
10
Q. Was he sympathetic toward you?
11
A. A little bit.
12
Q. Did you tell you you ought to get away
13
from this guy?
14
A. Yeah.
15
Q. Did you pay attention to what he said?
16
A. Obviously not, if I had a kid with him some
17
years later.
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=== Page 48 ===
18
Q. You elected not to sever your relationship
19
with
correct?
20
A. What? I wasn't going to leave
21
Q. Voluntary decision on your part, right?
22
A. I love
23
Q. Nobody -
24
A. I still love
25
Q. Nobody forced you into it.
0263
1
Big girl, you made your own decision, correct?
2
A. And I had stayed with
, yes.
3
Q. And let's talk a little bit more about it.
4
When you say he tried to drown you, exactly what did
5
he do?
6
A. Stuck my head in canal water.
7
Q. And where was this canal?
8
A. On the street where any canal would be.
9
Q. Where, in, in West Palm Beach?
10
A. Yes.
11
Q. And what was the event that led to him
12
sticking your head in canal water?
13
A. I have absolutely no idea.
14
Q. And were you terrified?
15
A. A little.
16
Q. How long did he hold your head under
17
water?
18
A. I'm I wasn't looking at my watch.
19
Q. Were you running out of breath?
20
A. No. He was lifting me back up. I caught my
21
breath.
22
Q. So, he was dunking you in and out of
23
water?
24
A. Yeah.
25
Q. So, you didn't ever have to fight to get
0264
1
up and get your head out of water?
2
A. While I was trying to fight to get my head out
3
of the water, the whole time he was trying to drown me.
4
Q. Were you fighting with him at the time?
5
A. We were in an argument.
6
Q. Was it a traumatic event to you?
7
A. Kind of.
8
Q. Did you seek any type of counseling or
9
A. No.
10
Q. medical care.
11
THE WITNESS: What time is it?
12
MR. SCAROLA: We're getting close.
13
MR. LUTTIER: 4:32.
14
MR. SCAROLA: Less than a half hour.
15
THE WITNESS: Thank God. 30 more minutes
16
of this crap. These things are really good.
17
BY MR. LUTTIER:
18
Q. When you met with the FBI and the U.S.
19
Attorney -
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=== Page 49 ===
20
A. Yes.
21
Q. -- did you tell them that you had worked
22
for escort services?
23
A. I don't think so. I don't remember.
24
Q. Did you tell them that you had been
25
sexually active prior to the time that you went to
0265
1
Mr. Epstein's?
2
A. I don't remember.
3
Q. Did you tell them that you had been raped
4
before you went to Mr. Epstein's?
5
A. I don't remember.
6
Q. Did you tell them that you had been
7
molested by your grandfather?
8
A. I don't remember.
9
Q. Tell them that you had been molested by
10
your cousin?
11
A. I don't remember.
12
Q; Did you tell them about your relationship
13
with
?
14
A. I don't remember.
15
Q. Did you tell them about physical violence
16
that had been inflicted upon you by
or by
17
?
18
A. I don't remember. They more wanted to know
19
about what happened with the child molester.
20
Q. Other than the occasion when
21
slapped you while you were pregnant, was
22
ever physically violent with you?
23
A. Nope.
24
Q. Was there ever an occasion that the police
25
came to visit you and
when you had
0266
1
your child with you?
2
A. Other than the time you mean that my child was
3
born?
4
Q. No. When they came to where you were
5
living and your child was there with you.
6
A. We had gotten in a fight with my brother and
7
his girlfriend. And after the fight was over, I went a
8
got my daughter from the neighbor's house.
9
Q. Did the police come?
10
A. Yes.
11
Q. Was there ever a time that the police came
12
when your child was there and they found drug
13
paraphernalia or drugs on either you or
14
?
15
A. Drug paraphernalia?
16
Q. Or drugs.
17
A. No.
18
Q. Was there ever a time that
19
was arrested in your presence because he had drugs
20
on his possession.
21
A. I have no idea.
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=== Page 50 ===
22
Q. Were you ever present when
23
was arrested?
24
A. Yeah.
25
Q. How many times?
0267
1
A. I don't recall.
2
Q. More than once?
3
A. I don't remember.
4
Q. And what is your current relationship with
5
?
6
A. I don't talk to him. He is incarcerated.
7
Q. And why is he incarcerated?
8
A. Because he beat up his pregnant girlfriend.
9
Q. And, and the pregnant girlfriend would be
10
who.
11
A. I don't know her name and I could care less
12
about the bitch.
13
Q. You say what? You could careless about
14
what?
15
A. About the bitch.
16
Q. Okay. Did you know the girl?
17
A. I have no idea who she is.
18
Q. You mentioned the name earlier in the
19
deposition,
?
20
A. Uh-huh. That was the missing Jane Doe No.
21
102's, whatever Jeffrey did with her, boyfriend.
22
Q. When did you first meet
?
23
A. A couple of weeks before I saw Mr. Epstein for
24
the first time. That was Jane Doe No. 102's boyfriend.
25
Q. When was the last time you spoke with
0268
1
?
2
A. A couple of days after Jane Doe No. 102 went
3
missing.
4
Q. Now, earlier you were making reference to
5
injecting drugs and I asked you a question about, I
6
don't remember if I asked you about a needle or a
7
syringe, so I need to go back and clarify. Was it
8
your testimony that you were able to go to a drug
9
store without a prescription and purchase a syringe
10
with a needle on it?
11
A. Yes.
12
Q. And what drug store was that?
13
A. One that sells them.
14
Q. Would that be a drug store here in Palm
15
Beach County?
16
A. It's a drug store in every county.
17
Q. Did you purchase a syringe with a needle
18
here in Palm Beach County
19
A. Yes.
20
Q. without a prescription?
21
A. Yes.
22
Q. Do you have any prescription that allows
23
you to, specifically for hypodermic needles?
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24
A. You don't need one.
25
Q. Are you diabetic or anything like that?
0269
1
A. No.
2
Q. Have you ever used a needle that had been
3
used before?
4
A. Not by anybody else, no.
5
Q. Not my question?
6
A. No, I have never shared a needle, no.
7
Q. Did you ever use
8
A. No.
9
Q. You need to listen to my question.
10
A. I heard you. You asked me if I ever used a
11
needle that's been used before and I said no.
12
Q. And what you said was, not one that had
13
been used by somebody else. So, which leaves open
14
the possibility, have you ever used a needle that
15
had been used before, even if it was used on you?
16
A. Even if it was used on me?
17
Q. Yes.
18
A. Well, then the answer would be yes, because I
19
had always, I had always used my own needle.
20
Q. You used a needle on yourself which you
21
had used before?
22
MR. SCAROLA: How about this: Have you
23
used the same needle more than once?
24
MR. LUTTIER: Fine.
25
THE WITNESS: Yes.
0270
1
BY MR. LUTTIER:
2
Q. Okay. And when was it that you did that?
3
A. I don't know.
4
Q. When was the last time you used a needle?
5
A. Back in July when I gave myself a staph
6
infection.
7
Q. And the needle that you used in July, had
8
you used it before?
9
A. Obviously if I gave myself staph with it.
10
Q. And when had you used it before July?
11
A. In the same day or two. I don't remember.
12
Q. And for what reason had you used it in the
13
same day or two?
14
A. Because it was the last one I had.
15
Q. But what did you use it for in the same
16
day or two?
17
A. To inject my prescription Roxicodone.
18
Q. So, in July you had injected yourself at
19
lease three times with Roxicodone?
20
A. I told you two.
21
Q. So, the needle that you used in July, when
22
you injected Roxicodone, you had used either same
23
time day or the day before to inject yourself with
24
Roxies?
25
A. Uh-huh.
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=== Page 52 ===
0271
1
Q. Which would mean that would be the second
2
time you used it, right?
3
A. Yes.
4
Q. Had you used it at any time before that?
5
A. No.
6
Q. So this needle you only used twice?
7
A. Yes.
8
Q. Were there other needles that you had used
9
in the past on yourself that you had used on
10
yourself more than once?
11
A. No. It's raining.
12
MR. SCAROLA: Uh-huh.
13
BY MR. LUTTIER:
14
Q. Isn't it, is it true at that Wellington
15
Regional would not discharge you because they deemed
16
you to be an IV drug user?
17
A. That's not true.
18
Q. Did you give them a history that you were
19
an IV drug user?
20
A. I led them, I told them I was an IV drug user.
21
Q. What exactly did you tell them about your
22
IV drug usage?
23
A. That I am an IV drug user.
24
Q. And did you give them anything, any more
25
detail than that?
0272
1
A. I told them that I shot Roxies.
2
Q. Did you tell them that you, that you shot
3
Roxi pursuant to a prescription?
4
A. Pursumed (phonetic).
5
Q. Pursuant to a prescription.
6
A. What does that mean?
7
Q. That the reason that you did it was you
8
had a prescription to do it?
9
A. Yeah.
10
Q. You are sure that you told them it was
11
pursuant to a prescription?
12
A. I told them. They asked me. I told them I
13
had a prescription. I no longer have that prescription,
14
and I no longer go to that doctor.
15
Q. When did you, when did that prescription
16
expire?
17
A. Earlier this year or last year.
18
Q. Being '08?
19
A. Yeah.
20
Q. And when you say the prescription expired,
21
what do you mean?
22
A. Well, it didn't really expire. I mean, I
23
never went and got a new prescription.
24
Q. When you say the prescription expired, do
25
you mean you ran out of the pills that you had
0273
1
purchased?
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=== Page 53 ===
2
A. Yeah.
3
Q. And that happened in '08?
4
A. Yeah.
5
Q. So, in July of '09 when you were shooting
6
up Roxicodone, where did you get those Roxicodone?
7
A. Oh, no. I still had the prescription but I
8
never went back to the doctor to get a new one. I had
9
the same prescription from '08 in '09.
10
Q. And you got it refilled?
11
A. No.
12
Q. Okay. Let's go back.
13
A. No. I saved the Roxie pills.
14
Q. I thought you told me a minute ago that
15
your prescription had expired and by definition --
16
A. I meant as
17
Q. And by definition that you had used up all
18
of the pills that you gotten initially?
19
A. No. I misunderstood you. That's why I was
20
trying to
21
Q. So, you still had pills left?
22
A. Yes. I never went back to the doctor to get a
23
new prescription, so I still had some in the bottle from
24
last year.
25
Q. When did you first use cocaine?
0274
1
A. During the time I met Mr. Epstein. I was
2
going Mr. Epstein's.
3
Q. And you never, prior to that had you used
4
it in any form, powder or crack?
5
A. No.
6
Q. Had you told anyone that you had used
7
cocaine prior to the time that you went to
8
Mr. Epstein's?
9
A. No.
10
Q. When did you first use marijuana?
11
A. Prior to the time I went to Mr. Epstein's.
12
That was the only drug I ever used before I met
13
Mr. Epstein.
14
Q. And you started using marijuana at age
15
what?
16
A. Thirteen.
17
Q. And you used it with what degree of
18
frequency?
19
A. I don't know, every day.
20
Q. And you were able to purchase that?
21
A. Yeah.
22
Q. At 13?
23
A. Yeah.
24
Q. Where did you get the money to buy that
25
marijuana?
0275
1
A. Allowance, about all I could
2
Q. Did you get the allowance from your
3
mother?
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=== Page 54 ===
4
A. Yeah, or cleaning people's houses or yard
5
work, stupid stuff kids do.
6
Q. And have you ever had a sexually
7
transmitted disease?
8
A. If you want to pelvic inflammatory disease,
9
but I got it from a tampon.
10
Q. Other than Roxicodone, have you ever
11
obtained well, strike that.
12
Have you ever obtained any type of pill
13
from any source whatsoever other than through a
14
prescription issued by a doctor?
15
A. What do you mean like have I gotten a pill
16
Q. Yep.
17
A. from anywhere else?
18
Q. Yep. Somebody gave you pills. You bought
19
the pills. Anything like that?
20
A. Yeah.
21
Q. And what kind of pills had you taken that
22
you didn't have a prescription for?
23
A. Percocet.
24
Q. And with what degree of frequency?
25
A. Like I took one one time.
0276
1
Q. At what age did you start taking pills
2
that you didn't have prescriptions for?
3
A. Twenty-two.
4
Q. You said you took Ms.
to
5
Mr. Epstein's as well, correct?
6
A. Yes.
7
Q. What did you tell Ms.
before you took
8
her there the first time?
9
A. I told her what was going to happen.
10
Q. What exactly did you tell
11
A. But she did more things willingly than I even
12
told her.
13
Q. How do you know that?
14
A. Because I was there and I left the room.
15
Q. What did you see
do?
16
A. She was offering information and Mr. Epstein
17
asked me to leave the room, and I was leaving the room.
18
Q. Offering information on what?
19
A. On things that her and her mother did.
20
Q. Like what?
21
A. I have no idea. I don't remember. I just
22
remember her saying things that her and her mother did
23
and I felt uncomfortable. And her and Mr. Epstein were
24
laughing and he asked me to leave the room and I left
25
the room.
0277
1
Q. Well, if you have a recollection that she
2
said something about
3
A. I said I don't have the recollection of
4
exactly what she said. I remember
5
Q. What's your best recollection of the
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=== Page 55 ===
6
subject matter about which she was talking?
7
A. That her and her mom have had, her mom does
8
things and has prices for things. Something of that
9
matter. I don't
10
Q. Sexual nature?
11
A. Yeah.
12
Q. What kinds of things?
13
A. I don't remember.
14
Q. And when you, before you took
to
15
Mr. Epstein the first time, what you did you tell
16
her was going to happen?
17
A. I told her that he might ask her to get nude.
18
And I told her that you were just going to massage him.
19
Q. Did you tell her anything about your
20
experience with the other woman?
21
A. I didn't tell anybody that experience about,
22
with that other woman like I told you before.
23
Q. When you took
the first time did you
24
go with her?
25
A. Yes.
0278
1
Q. Did you get paid?
2
A. Yes.
3
Q. How much?
4
A. $400.
5
Q. Just for taking her.
6
A. Well, 300 that I always get and an extra 100
7
for taking her.
8
Q. On the time that you took
the first
9
time, did you go in with her and Mr. Epstein?
10
A. Yes.
11
Q. Did you take
a second time.
12
A. Yes, and that's when I was asked to leave the
13
room.
14
Q. Did you take her a third time?
15
A. No.
16
Q. After the second time did she go back
17
herself?
18
A. I don't know. Ask her.
19
Q. Did you tell her that you were getting
20
paid to take her?
21
A. No.
22
Q. Did you share that money that you got for
23
bringing her with her?
24
A. No.
25
Q. After you took her the first time, were
0279
1
you present in the room with Mr. Epstein the entire
2
time when she was there?
3
A. Other than the what
4
Q. When you went the first time --
5
A. The first time
6
Q. With
7
A. yes, I was there the whole time.
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=== Page 56 ===
8
Q.
What occurred at the first meeting of you
9
and
and Mr. Epstein?
10
A. We gave him a massage. She played with one
11
nipple. I played with the other, and he masturbated.
12
Q. And was the state of dress for you and
13
?
14
A. We were naked.
15
Q. Totally?
16
A. Uh-huh.
17
Q. And when, and when you left did you and
18
she discuss your encounter?
19
A. No.
20
Q. Did she have any complaints about it when
21
you left?
22
A. No.
23
Q. Did she
24
A. All she said was that was easy.
25
Q. Did she ask you if you, if you could take
0280
1
her back?
2
A. No.
3
Q. Were you present the second time she went?
4
A. Yes.
5
Q. That's the second time is when you
6
eventually walked out?
7
A. Yes. That's when I walked out.
8
Q. What occurred before you walked out?
9
A. They were joking and laughing. She was
10
telling him about some stuff that her mom and her did
11
sexually for money or some stuff like that. I don't
12
really remember the whole conversation word for word.
13
I need a drink. I have the hiccups really
14
bad. I am getting antsy.
15
MR. SCAROLA: Countdown is to about ten
16
minutes.
17
THE WITNESS: Good.
18
BY MR. LUTTIER:
19
Q. When was the first time you did acid?
20
A. When I was 19.
21
Q. And when you say acid, what specific drug
22
were you doing?
23
A. Acid.
24
Q. And in what form was it?
25
A. Paper.
0281
1
Q. And you swallowed it?
2
A. No, it dissolves on your tongue.
3
Q. And did you do it more than once?
4
A. I only did it once.
5
Q. And were you with anyone else?
6
A. Yeah, my friends.
7
Q. Who?
8
A. I'm not giving you their names. It's
9
irrelevant.
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10
Q. Okay. You're refusing to answer that
11
question?
12
A. Yes, yes, I am.
13
Q. Who provided the acid?
14
A. That's irrelevant and I refuse to answer that
15
one too.
16
Q. Was this after you got back from Georgia?
17
A. Yeah.
18
Q. So, there came a point in time after you
19
had been drug free
20
A. Yes.
21
Q. -- from Georgia that you decided to take
22
it up again, right?
23
A. Yep.
24
Q. When was the first time you started doing
25
drugs again after you had been drug free until
0282
1
January of '05?
2
A. When I was 18. When I was 18.
3
Q. Do you remember the event?
4
A. Do I remember the event that I did the drug?
5
Q. Yeah.
6
A. Yeah.
7
Q. And was it, was it on your birthday?
8
A. No.
9
Q. All right. Was it in January of '05?
10
A. No.
11
Q. When was it?
12
A. I was 18 but I don't remember the direct
13
month.
14
Q. Okay.
15
A. I know it was not by my birthday.
16
Q. Okay. And can you describe the event?
17
A. Some other people were doing it, so I did it.
18
Q. What drug?
19
A. Crack.
20
Q. And where were you?
21
A. In a house.
22
Q. First time you had done it?
23
A. Yeah.
24
Q. And who was with you?
25
A. People. Not giving you their names because
0283
1
it's irrelevant.
2
Q. And what house?
3
A. One that somebody lived in.
4
Q. And who supplied the crack?
5
A. I don't know.
6
Q. And after having been drug free from May
7
of '03 to January '05, why did you decide to do
8
crack?
9
A. I was going through a lot of things in my
10
brain. I had lost my boyfriend due to Mr. Epstein. I
11
lost my kid due to his stupid father. So, I was going
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12
through a lot. Why does anybody take up using drugs
13
or
14
Q. What boyfriend are you referring to,
15
saying you lost your boyfriend?
16
A.
17
Q. Now, why do you say you lost
because
18
of Mr. Epstein?
19
A. Because he found out finally we got into an
20
argument and I just told him everything that had
21
happened and
22
Q. And when did you do that?
23
A. After I had my son.
24
Q. While you were in Georgia?
25
A. No, while we were in Florida. I had my son in
0284
1
Florida.
2
Q. And that's the first time you told
3
everything?
4
A. Yeah.
5
Q. And what was his reaction?
6
A. Obviously it wasn't good if I am not with him.
7
Q. Well, did he, on that particular occasion
8
leave and say he didn't want anything to do with
9
you?
10
A. No. We argued for a while. We tried to make
11
it work and it just wouldn't work.
12
Q. Okay. Other than the fact that you and
13
had broken up and you had lost your kid, and
14
the kid that you're talking about there, is that
15
?
16
A.
17
Q. Anything else that caused you to use crack
18
in January of '05?
19
A. I was depressed about my whole life. And I
20
felt disgusted by Mr. Epstein.
21
Q. Well, actually the sexual encounters that
22
you had with others were far more extensive than
23
anything
24
A. What are you talking about--
25
Q. anything you had ever done with
0285
1
Mr. Epstein, right?
2
A. sexual encounters?
3
Q. I mean you, you had done, you had engaged
4
in sex with others, you engaged in sex with both
5
sexes. You had done all sorts of things that
6
Mr. Epstein never did with you, hadn't you?
7
A. So, what does that have to do with
8
Mr. Epstein, my sex life.
9
Q. When you talk about being disgusted
10
A. Why don't you get naked in front of an old man
11
and play with his nipples while he masturbates. You do
12
that and then you tell me if you feel good.
13
Q. And as you mentioned earlier, you did that
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14
to get money?
15
A. So? It still doesn't make it right.
16
Q. And any other reason why you decided to go
17
back and start using crack cocaine?
18
A. What do you mean go back and start using it?
19
Q. Any other reason why you started to go
20
back to drugs and in particular crack co, start
21
using crack cocaine in January of '05?
22
A. I never heard of it and it was the first time
23
so I tried it.
24
Q. Had you ever seen your mother use crack
25
cocaine?
0286
1
A. No.
2
Q. Had you ever been present when your
3
mothers was arrested for using crack cocaine?
4
A. No.
5
Q. Did you tell anybody your mother used
6
crack cocaine ever?
7
A. My mom used to be an alcoholic, whether she
8
used
9
Q. That's not my question. Did you ever tell
10
anybody ever
11
A. No.
12
Q. that your mother used crack cocaine?
13
A. No.
14
Q. Not
, not anybody else?
15
A. No.
16
Q. Did you ever prostitute yourself for
17
drugs?
18
A. No.
19
Q. Did you do acid on more than one occasion?
20
A. No.
21
Q. When did you first use Ecstasy?
22
A. I think when I was 14.
23
Q. Before you met Mr. Epstein?
24
A. No, during, meeting Mr. Epstein.
25
Q. What?
0287
1
A. After I had met Mr. Epstein.
2
Q. Well, you didn't meet him until you were
3
15.
4
A. I don't think that's right. I met him when I
5
was 14. I think I saw him for longer than just that
6
year.
7
Q. Well, according to your complaint the
8
first time you meet him was when you were 15?
9
A. I don't that, I don't know.
10
MR. SCAROLA: That may be an error.
11
THE WITNESS: Yeah, I think that's an
12
error.
13
BY MR. LUTTIER:
14
Q. When did you what were the
15
circumstances surrounding, surrounding you first
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16
using Ecstasy.
17
A. I was at a party.
18
Q. Where?
19
A. In West Palm Beach. Who was there, I don't
20
know. A bunch of people.
21
Q. And who provided the drug?
22
A. I don't know.
23
Q. Mr. Epstein certainly wasn't there, right?
24
A. No, Mr. Epstein was not there.
25
Q. Okay. Did somebody give you the drug or
0288
1
did you purchase the drug?
2
A. Somebody gave it to me.
3
Q. Had you ever used it before?
4
A. No.
5
Q. Did you ever use it again?
6
A. No.
7
Q. Did you enjoy it?
8
A. No. It was kind of weird.
9
Q. When was the first time you used heroin?
10
A. When I was 21.
11
Q. And what were the circumstances
12
surrounding you using heroin?
13
A. I was just trying it to try to escape my
14
problems.
15
Q. And where were you?
16
A. In my house.
17
Q. Where your mother lives?
18
A. No. In mine and
house.
19
Q. Did
use it with you?
20
A. Yeah.
21
Q. Who provided the heroin?
22
A. I don't know. Some dude.
23
Q. Was there more people there than just you
24
and
?
25
A. Yep.
0289
1
Q. And how did you take the heroin?
2
A. I snorted it.
3
Q. And did you use it again?
4
A. No.
5
Q. No one forced you to do it?
6
A. Donny did.
7
Q. How did he force you to do it?
8
A. He told me to do it.
9
Q. So he --
10
A. And I didn't want to. And he didn't like grab
11
me and tell me to do it, but I didn't want to and he
12
argued with me about it, so I just did it to stop
13
arguing.
14
Q. When was the first time you used crystal
15
meth?
16
A. I was, I was like 18.
17
Q. And where did you use that?
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18
A. In a house.
19
Q. With, who were you living with at the
20
time?
21
A. I was living with myself. Some people were
22
doing it. I snorted it.
23
Q. People you invited over?
24
A. People I invited over. People other people
25
invited over.
0290
1
Q. Was it given to you or did you buy it?
2
A. It was given to me.
3
Q. And why did you do it?
4
A. Something new to do.
5
Q. Have you ever gone through detox?
6
A. Yes.
7
Q. How many times?
8
A. Twice.
9
Q. When was the first time?
10
A. Earlier this year.
11
Q. That is earlier of '09?
12
A. Yes.
13
Q. Do you remember what month?
14
A. No.
15
Q. And where did you go through detox the
16
first time?
17
A. In my living room. I went
18
Q. And you were detoxing yourself?
19
A. Yes. And also I detoxed at CARP.
20
Q. Both, is that the, this is what you have
21
indicated is the first time both in your living room
22
and at CARP?
23
A. (Witness nods head.)
24
THE COURT REPORTER: Is that a yes?
25
THE WITNESS: Yes.
0291
1
BY MR. LUTTIER:
2
Q. And the second time when did you detox?
3
A. At CARP.
4
Q. When?
5
A. I don't know.
6
Q. Well, you said the first was early '09.
7
Does that mean the second was sometime after that?
8
A. Yeah.
9
Q. How long --
10
A. It was all in '09.
11
Q. How long after the first time?
12
A. Like a month or two later.
13
Q. And what were you detoxing yourself from
14
the first time in '09?
15
A. Roxies.
16
Q. Well, that was the drug that you were
17
taking pursuant to your prescription?
18
A. Yes.
19
Q. When did you become addicted to it?
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=== Page 62 ===
20
A. While I was being prescribed it.
21
Q. Did you tell the doctor you had been
22
become addicted to it?
23
A. Yes, this is why I no longer get a
24
prescription for it.
25
Q. And what were you getting detoxed from the
0292
1
second time at CARP?
2
A. Roxies.
3
Q. So you had to be detoxed twice from
4
Roxies?
5
A. Well, yes, because I detoxed the first time
6
and then I went back to using them again because of my
7
back pain.
8
Q. Did you report to the physician that was
9
giving you the prescription that you had been
10
detoxed one time before you went back to using?
11
A. No. Because if you recall in your notes, I
12
saved the prescription to the next year after I had
13
stopped going to that doctor.
14
Q. So, you continued to take the drug even
15
though you had detoxed from the drug?
16
A. Yes.
17
Q. You knew you were addicted to it in the
18
past?
19
A. Yes.
20
Q. Opted, by your own choice, to do it again?
21
A. Yes. So, if that makes me a criminal, then
22
sobeit. How much time do we have left? I want to go
23
get my son.
24
MR. SCAROLA: About two minutes.
25
THE WITNESS: Good. Yeah. I really want
0293
1
to go get my kid; the kid that I signed my
2
rights over to by the way.
3
BY MR. LUTTIER:
4
Q. What was the last grade you completed in
5
school?
6
A. Seventh.
7
Q. And what school were you attending?
8
A. Bear Lakes. Actually, yeah, actually the last
9
year I completed was seventh. I started eighth grade
10
and they kicked me out of school because I was too
11
physically developed.
12
Q. What do you mean by that?
13
A. My boobs were too big and I got sexually
14
harassed by the kids in school. So they called my mom
15
and told her she needed to sign me out. And if you
16
don't believe me, you take it up with Bear Lakes.
17
Q. So, did you enroll in another school?
18
A. No.
19
Q. Why not?
20
A. Because I didn't feel like it at the time.
21
Q. And you were, then you were what they call
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=== Page 63 ===
22
a truant at that point?
23
A. I wasn't truant. At 16 years of age, you
24
don't have to go to school anymore. It's legal.
25
Q. So, you opted by your own free will to
0294
1
quit going to school at that time?
2
A. Yes. I got pregnant and now have a
3
six-year-old son.
4
Q. You, did you get pregnant before you had
5
dropped out of school?
6
A. No. I got pregnant after.
7
Q. What did you do during the days after you
8
dropped out of school?
9
A. Watched TV.
10
Q. Had you had run-in's with the law prior to
11
that?
12
A. When I was 18 years old, I did.
13
Q. Had you had an incident while you were a
14
juvenile where you were arrested for throwing a
15
knife at your brother or something?
16
A. Yeah, he tried to kill my cat, and then he
17
tried to kill me, so I threw a knife at him.
18
Q. Had you and your brothers been removed
19
from your mom's care on an occasion
20
A. Never.
21
Q. when your mom was arrested?
22
A. Never.
23
Q. Do you remember being placed with some
24
neighbors and the neighbors calling the authorities
25
and saying they wanted someone to come pick you-all
0295
1
up?
2
A. No. We have never been removed out of my
3
mother's care or custody.
4
Q. Do you remember you and your brothers
5
being present on an occasion when your mother was
6
arrested and taken away?
7
A. No, I have never watched my mom be arrested.
8
Q. Do you remember any occasion where she was
9
arrested for possession of drug paraphernalia?
10
A. Yes. And if you look the DNA, the court did
11
DNA, and my mother's DNA was not on that paraphernalia.
12
So that charge was dropped.
13
Q. Were you present when these charges were
14
made?
15
A. I was present but I wasn't in the presence of
16
it happening.
17
Q. What do you mean by you were present but
18
you weren't?
19
A. I wasn't in the presence of it happening.
20
Q. Did you mean
21
A. I know about it.
22
Q. Okay. Well, where were you in
23
geographical proximity to this event?
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24
A. I was at my house.
25
Q. And was your mother at the house?
0296
1
A. No. I know two minutes is up.
2
MR. SCAROLA: Yeah, do you want to get to.
3
I mean, you set a 5:00 time limit.
4
MR. LUTTIER: Yeah, I do, I've got to go.
5
MR. SCAROLA: And we're there so --
6
MR. LUTTIER: All right. We'll just break
7
now.
8
THE WITNESS: Break to what? I thought
9
5:00 was at the end. I've got to go pick up my
10
kid.
11
MR. SCAROLA: Yes.
12
MR. LUTTIER: We'll reconvene you
13
deposition. I will put it on hold for right
14
now until we can get a new day.
15
THE WITNESS: Peace out.
16
THE VIDEOGRAPHER: Off the record at 5:00.
17
(A discussion was held off the record.)
18
THE COURT REPORTER: Do you want to order
19
this?
20
MR. LUTTIER: Yes.
21
THE COURT REPORTER: Do you want a copy?
22
MR. SCAROLA: Yes.
23
(Witness excused.)
24
(Deposition was adjourned.)
25
0297
1
CERTIFICATE OF OATH
2
THE STATE OF FLORIDA
3
COUNTY OF PALM BEACH
4
5
6
I, the undersigned authority, certify that
7
personally appeared before me
8
and was duly sworn on the 4th day of December, 2009.
9
10
11
Dated this 11th day of December, 2009.
12
13
14
15
16
17
Notary Public - State of Florida
My Commission Expires: February 25, 2011
18
My Commission No.: DD 643788
19
20
21
22
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=== Page 65 ===
23
24
25
0298
1
CERTIFICATE
2
THE STATE OF FLORIDA
3
COUNTY OF PALM BEACH
4
5
I,
Registered Professional
Reporter, Florida Professional Reporter and Notary
6
Public in and for the State of Florida at large, do
hereby certify that I was authorized to and did
7
report said deposition in stenotype; and that the
foregoing pages are a true and correct transcription
8
of my shorthand notes of said deposition.
9
I further certify that said deposition was
taken at the time and place hereinabove set forth
10
and that the taking of said deposition was commenced
and completed as hereinabove set out.
11
I further certify that I am not attorney or
12
counsel of any of the parties, nor am I a relative
or employee of any attorney or counsel of party
13
connected with the action, nor am I financially
interested in the action.
14
The foregoing certification of this transcript
15
does not apply to any reproduction of the same by
any means unless under the direct control and/or
16
direction of the certifying reporter.
17
Dated this 11th day of December, 2009.
18
19
20
21
22
23
24
25
0299
1
DATE:
December 11th, 2009
2
TO:
c/o Jack Scarola, Esquire
3
SEARCY, DENNEY, SCAROLA,
BARNHART & SHIPLEY, P.A.
4
5
IN RE: Jane Doe No. 2 VS. Epstein
6
CASE NO.: 08-CIV-80119-
7
Please take notice that on Friday, the 4th of
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=== Page 66 ===
8
December, 2009, you gave your deposition in the
above-referred matter. At that time, you did not
9
waive signature. It is now necessary that you sign
your deposition.
10
As previously agreed to, the transcript will be
furnished to you through your counsel. Please read
11
the following instructions carefully:
At the end of the transcript you will find an
12
errata sheet. As you read your deposition, any
changes or corrections that you wish to make should
13
be noted on the errata sheet, citing page and line
number of said change. DO NOT write on the
14
transcript itself. Once you have read the
transcript and noted any changes, be sure to sign
15
and date the errata sheet and return these pages to
me.
16
If you do not read and sign the deposition
within a reasonable time, the original, which has
17
already been forwarded to the ordering attorney, may
be filed with the Clerk of the Court. If you wish
18
to waive your signature, sign your name in the blank
at the bottom of this letter and return it to us.
19
Very truly yours,
20
21
22
23
I do hereby waive my signature.
24
25
0300
1
CERTIFICATE
2
3
THE STATE OF FLORIDA
4
COUNTY OF PALM BEACH
5
I hereby certify that I have read the foregoing
6
deposition by me given, and that the statements
7
contained herein are true and correct to the best of
8
my knowledge and belief, with the exception of any
9
corrections or notations made on the errata sheet,
10
if one was executed.
11
12
Dated this
day of
,
13
2009.
14
15
16
17
18
19
20
21
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=== Page 67 ===
22
23
24
25
0301
1
ERRATA SHEET
2
IN RE: JANE DOE NO. 2 VS. EPSTEIN
CR:
3
DEPOSITION OF:
TAKEN: December 4th, 2009
4
5
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
PAGE # LINE # CHANGE
REASON
6
7
8
9
10
11
12
13
14
15
16
17
Please forward the original signed errata sheet to
this office so that copies may be distributed to all
18
parties.
19
Under penalty of perjury, I declare that I have read
my deposition and that it is true and correct
20
subject to any changes in form or substance entered
here.
21
22
DATE:
23
24
SIGNATURE OF
DEPONENT:
25
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c1: EFTA00025292
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025292.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(NY) (FBI)"
Cc:
)"
Subject: FW: [EXTERNAL] Follow up to voicemail-
Date: Tue, 12 Oct 2021 23:32:20 +0000
From:
Sent: Tuesday, October 12, 2021 3:30 PM
To:
is
(USANYS)
Subject: FW: [EXTERNAL] Follow up to voicemail-
From:
Sent: Tuesday, October 12, 2021 3:19 PM
To:
Subject: [EXTERNAL] Follow up to voicemail-
EFTA00025292

=== Page 2 ===
EFTA00025293


c1: EFTA00024714
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024714.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
)"
)"
(USANYS)"
Cc:
"
(USANYS)"
Subject: Fwd: New Epstein Ruling
Date: Thu, 21 Feb 2019 20:04:41 +0000
Importance: Normal
Sent from my iPhone
Begin forwarded message:
From:
"
(USANYS) [Contractor]"
Date: February 21, 2019 at 3:01:04 PM EST
To: "Berman, Geoffrey (USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: New Epstein Ruling
https://www.miamiherald.com/news/state/florida/article226577419.html
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00024714


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=== Page 1 ===
From: "Susan Necheles (via Google Docs)"
To:
Cc:
Subject: Submission on behalf of
Date: Fri, 13 Mar 2020 00:39:50 +0000
has shared a link to the following document:
Submission on behalf of
Unk
and
nown
profile
Attached is a draft of the factual statement, just so that you can better understand the
facts that we are presenting.
We feel that given
abuse, and given the fact that we see her basically as a
cog in Epstein's wheel, acting entirely at his direction and doing what she did at a time
that she herself was a very vulnerable victim, a non-pros would be the appropriate
disposition. But we want to discuss this with you before we finalize this and make a
submission.
Thanks, Susan
Open in Docs
Logo for
Google Docs: Create and edit documents online.
Google
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Docs
You have received this email because someone shared a document with you from Google Docs.
EFTA00025185


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=== Page 1 ===
From:
To:
Cc:
Subject: Final bail opp
Date: Wed, 16 Dec 2020 22:07:04 +0000
Attachments: 2020-12-16_GM_renewed_bail_motion_opposition_FINAL.docx
Attached is the final bail opposition. Please add a TOC and TOA then send back to me.
Thanks!
EFTA00024403


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
October 2, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing discovery materials pertinent to Ghislaine Maxwell
(02879-509) is
!
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Went me
Assistant United States Attorneys
EFTA00023696


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=== Page 1 ===
From: Robert Glassman
To:
Cc:
Subject: Re: RE:
follow-up
Date: Fri, 20 Mar 2020 20:26:19 +0000
Hey
Hope you guys are staying safe. Here was her response about the lion king:
Broadway play. Epstein bragged about being good friends with Julie Taymor, and we had amazing first row
mezzanine seats they she had apparently given him.
From:
Date: 3/20/20, 12:26:42 PM PDT
To: Robert Glassman
Cc:
Subject: RE:
follow-up
Robert,
Wanted to quickly follow up on our conversation from a couple weeks ago - obviously it was before the world
imploded, so understand if you haven't gotten a chance to connect on this yet, but we were wondering about the
Lion King question? Just to briefly remind, the Lion King musical first came out in 1997, which we think would have
been well after
first trip to New York (based on her recollection as well as the flight records), while the
movie came out in 1994 and was in theaters through approximately spring 1995. So entirely possible she was
referencing the movie version, or that going to the play wasn't the first visit, or just doesn't have a specific
memory, etc etc, but wanted to check for our records and our decision-making process.
Thank you! And hope you and your family are healthy and safe in the midst of everything going on.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00023550


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=== Page 1 ===
From:
To:
, "Berman, Geoffrey
(USANYS)"
Subject: Fwd: FOX Business inquiry
Date: Mon, 16 Mar 2020 15:17:33 +0000
Inline-Images: image001.png
Geoff: just let me know if you'd like for me to do anything other than decline. Thanks.
Sent from my iPhone
Begin forwarded message:
From: "Pagones, Stephanie"
Date: March 16, 2020 at 8:22:57 AM EDT
To:
Subject: FOX Business inquiry
Hi,
We're working on a story in which we speak to several former federal prosecutors and US Attorneys about the potential
next steps in the Epstein investigation, particularly as it pertains to Prince Andrew's unwillingness to cooperate.
One of the things that has come up from multiple people is how unusual it is for Geoffrey Berman to have spoken
publicly about this matter, not once, but twice.
Per one former US Attorney: "It's an unusual move because generally speaking, there is a rule, there's guidance in the
U.S. attorney's manual that comes from the attorney general that indicates that they are not to comment."
Full disclosure, in most, if not all cases, the people I spoke with said they would likely have done the same thing.
That said, would you or US Atty Berman like to provide any statement or comment to be included in the story?
We are on deadline for 4 p.m. Monday. Thank you in advance, I hope to hear from you before then.
Stephanie Pagones
Digital Reporter FOX Business
cell:
@steph_pagones
FOX
BUSINESS
This message and its attachments may contain legally privileged or confidential information. It is intended
solely for the named addressee. If you are not the addressee indicated in this message (or responsible for
delivery of the message to the addressee), you may not copy or deliver this message or its attachments to
anyone. Rather, you should permanently delete this message and its attachments and kindly notify the sender
by reply e-mail. Any content of this message and its attachments that does not relate to the official business of
Fox News or Fox Business must not be taken to have been sent or endorsed by either of them. No
representation is made that this email or its attachments are without defect.
EFTA00025549


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=== Page 1 ===
From:
)"
To:
Cc: "
)"
)"
,
Subject: RE: Epstein - Subpoena Tracker
Date: Fri, 05 Jun 2020 18:46:02 +0000
Thanks very much for this - we'll take a look as circle back as needed.
thanks,
From:
Sent: Tuesday, June 02, 2020 08:13
To:
Cc:
>;
is
is
Subject: Epstein - Subpoena Tracker
As a follow up to our conversation, I have attached a copy of my subpoena tracker. The tracker only includes
subpoenas that were served by the FBI. As an example, the Epstein Deutsche Bank production is not included
in this list.
If you are missing any productions, please have
contact me and I will provide it to him.
You mentioned that is it is possible to set up a DOJ virtual drive that we can share. That sounds great.
Best
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
EFTA00025128


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein items
Date: Wed, 22 Jul 2020 21:07:07 +0000
Okay, great. Thanks. Very frustrating given the history, but hopefully we now have everything (and everything done
correctly).
From:
Sent: Wednesday, July 22, 2020 4:58 PM
To
Cc:
Subject: FW: Epstein items
FYI below, the FBI says its dropping off extractions of nearly all the remaining devices tomorrow. Why after ten months of
nothing we were able to get literally everything in a week is absolutely beyond me, but hopefully the data they get us is
correct, accurate, and workable. We should be able to get the drive sent to
copied here) tomorrow, and then if it all
looks okay, likely out to
for processing and upload next week. Will keep everyone posted as always.
From:
Sent: Wednesday, July 22, 2020 16:56
To:
Cc:
is
Subject: RE: Epstein items
Thanks very much for letting us know, that's very helpful. After you finalize and drop off the drive, if tomorrow you could
please send us a scrubbed and updated spreadsheet, so we can match up everything we're working with, that would be
extremely helpful.
thanks again,
From:
Sent: Wednesday, July 22, 2020 16:52
To:
Subject: Epstein items
,
The last item is currently copying to the drive
gave me for submittal to Southern. Unfortunately, the copy
will take several more hours, so it will not be available today, but will be 1st thing tomorrow morning. This
EFTA00023763

=== Page 2 ===
includes all outstanding items except the 2 servers that need hardware data recovery. I'll drop the drive off
tomorrow morning. Let me know if you need anything else.
EFTA00023764


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=== Page 1 ===
From:
To:
Subject: quick thing
Date: Mon, 16 Dec 2019 22:28:37 +0000
Hey you're both on your flights so wanted to send a brief note that
mentioned that
misspoke
yesterday about the possible identities of individuals on Epstein's phone yesterday - not the person she thought
it might have been. So no emergency except I didn't want that accidentally incorrect info to go up the chain, and
can chat more later or tomorrow about it.
Sent from my iPhone
EFTA00026613


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=== Page 1 ===
From:
To:
Cc:
Subject: GHISLAINE MAXWELL Removal Hearing 20mj132-01
Date: Thu, 02 Jul 2020 17:07:57 +0000
Importance: Normal
Attachments: unnamed
This meeting invitation shall not be shared, and unknown persons who attempt to join the
video conference will not be admitted.
Only necessary case participants will be permitted to join this video hearing. All others may
access the proceeding via telephone conference.
GHISLAINE MAXWELL Removal Hearing 20mj132-01 7/2/2020 at 3:30 p.m.
NOTICE: Pursuant to Local Rule 83.8, all persons participating in court proceedings
remotely by videoconference or teleconference shall not photograph, broadcast, or televise
any of these court proceedings. This prohibition applies to counsel, the parties, the media
and any member of the public.
Counsel shall notify the clerk's office in advance if there are any matters pending before the
court that should be presented under seal.
Join ZoomGov Meeting
https://nhd-uscourts.zoomgov.com/j/160146293?
pwd=Rlc5c3BFOFpoQzQ3M250azh5WWNrUT09
Meeting ID: 160 146 2933
Password: 182411
One tap mobile
+16692545252,, 1601462933#,, 182411# US (San Jose)
+16468287666,1601462933#,1#,182411# US (New York)
Dial by your location
+1 669 254 5252 US (San Jose)
+1 646 828 7666 US (New York)
Meeting ID: 160 146 2933
Password: 182411
Find your local number: https://nhd-uscourts.zoomgov.com/u/adw03gcwSb
EFTA00024527

=== Page 2 ===
Join by SIP
1601462933@sip.zoomgov.com
Join by H.323
161.199.138.10 (US West)
161.199.136.10 (US East)
Meeting ID: 160 146 2933
Password: 182411
EFTA00024528


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=== Page 1 ===
From:
To:
Subject: FW: Noel and Thomas Nolle Memo and Application
Date: Wed, 24 Nov 2021 14:21:13 +0000
Attachments: Ex _B-1_-_2021.05.25_Noel_DP_(signed,_ECF).pdf_Ex_B-2_-
2021.05.25_Thomas_DP_(signed,_ECF).pdf;
2021.11.23_Nolle_Application_and_Order_(Ex_C).docx:2021.1123_Nolle_Memo_-
_Noel_and_Thomas.docx; Ex_A-1_-
_Tova_Noel_19_Cr_830_DP_memo_from_Committee.pdf;Ex_A-2_-
Michael_Thomas_19_Cr_830_DP_memo_from_Committe.pdf
I can review this one
From
Sent: Tuesday, November 23, 2021 10:12 PM
To:
Subject: Noel and Thomas Nolle Memo and Application
-
Attached for your review is the nolle memo for Tova Noel and Michael Thomas. Also attached are the exhibits, including
the nolle application, which is Exhibit C. Sorry if I got your titles wrong on the memo, please correct if they aren't right.
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
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=== Page 1 ===
From:
"
(USANYS)"
To:
Subject: Epstein Meeting (Please hold the time)
Date: Fri, 10 Jan 2020 18:54:36 +0000
Importance: Normal
Attachments: unnamed
EFTA00024251


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=== Page 1 ===
From:
To:
Cc:
Bec: "USAHUB-USAJournal111"
Subject: Re: Maxwell Follow Up
Date: Mon, 22 Feb 2021 21:44:58 +0000
Embedded: Re_Maxwell_Follow_Up.msg
Sender:
Subject: Re: Maxwell Follow Up
Message-Id:
<BLAPR09MB7268617C5C2B47206871BF29E9819@BLAPR09MB7268.namprd09.prod.outlook.com>
Recipient:
EFTA00027082


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
:
)"
=
Subject: Re: Ghislaine Maxwell's Asst
Date: Sun, 25 Jul 2021 01:12:46 +0000
Hi
Thanks very much for passing this along, we'll take care of this.
On Jul 24, 2021, at 8:44 PM,
)
wrote:
FYI-
l'll forward the voicemail as well, although it doesn't include additional information.
From:
Sent: Friday, July 23, 2021 9:31 PM
To:
)
Subject: Ghislaine Maxwell's Asst
Hi
I may have info that can help this prosecution. Ghislaine's asst.,
lived with me while she was working for
her. I just left you a voicemail.
"Kindness Matters"
EFTA00025070


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
86 Chambers Street
New York, New York 10007
June 5, 2020
By Electronic Mail
Robert Glassman, Esq.
Panish Shea & Boyle LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, CA 90025
Re:
Request for Information Relating to Jeffrey Epstein
Dear Mr. Glassman:
I am the Assistant U.S. Attorney ("AUSA") who will be handling the request you
discussed with AUSA
for certain information relating to Jeffrey Epstein.
Because your request seeks information from Department of Justice (the "Department")
employees acquired during and as part of their performance of their official duties, your request
is governed by certain Department regulations-commonly referred to as Touhy regulations-
which, inter alia, prohibit any Department employee from disclosing such information "without
prior approval of the proper Department official in accordance with §§ 16.24 and 16.25 of this
part." 28 C.F.R. $ 16.22(a); see also United States ex rel. Touhy V. Ragen, 340 U.S. 462 (1951);
28 C.F.R. $ 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United
States Attorney for the Southern District of New York. The Touhy regulations provide a set of
procedures for the United States Attorney to follow when considering such requests. See 28
C.F.R. §§ 16.22(b), 16.24.
A party seeking to obtain records or employee testimony from the Department must first
submit a written demand. See 28 C.F.R. § 16.22. To assist the United States Attorney in
evaluating your request, we ask that this demand provide a detailed statement of the information
sought; the litigation for which you seek this information; the pertinence of the information
sought to your litigation; and the availability (or absence) of means in that litigation, including
discovery, to obtain the information in question. See id. § 16.22(d).
The U.S. Attorney will reach a determination regarding your request in light of the
considerations codified at 28 C.F.R. §§ 16.24, 16.25, and 16.26. Such considerations include,
inter alia, "[w]hether such disclosure is appropriate under the rules of procedure governing the
case or matter in which the demand arose," 28 C.F.R. $ 16.26(a)(1), and "[w]hether disclosure is
appropriate under the relevant substantive law concerning privilege," including law enforcement
privilege. 28 C.F.R. $ 16.26(a)(2). Disclosure will not be made when, inter alia, "[d]isclosure
would violate a statute
or a rule of procedure, such as the grand jury secrecy rule," 28 U.S.C.
§ 16.26(b)(1), "[d]isclosure would reveal a confidential source or informant," 28 U.S.C. §
16.26(b)(4), or "[d]isclosure would reveal investigative records compiled for law enforcement
purposes, and would interfere with enforcement proceedings or disclose investigative
techniques," 28 U.S.C. $ 16.26(b)(5). Applying these considerations, the Department will make
appropriate disclosures when warranted. See 28 C.F.R. § 16.26(c).
EFTA00026569

=== Page 2 ===
Page 2
My understanding is that you may intend to make a formal written request pursuant to the
above-described regulations. If you choose to submit a written request, please send it directly to
me. We will act upon an application made pursuant to the Department's regulations.
Please contact me once you have had a chance to review this letter if you would like to
discuss the issues herein further.
Sincerely,
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By:
Assistant United States Attorney
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=== Page 1 ===
From:
"
I"
To:
"
Cc:
"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Epstein/Maxwell Upload
Date: Fri, 25 Sep 2020 14:47:00 +0000
Embedded: RE:_Epstein_Maxwell_Upload.msg
Sender:
Subject: RE: Epstein/Maxwell Upload
Message-Id:
<CY1P110MB053317CB79C5A4F16F056A32F5360@CY1P110MB0533.NAMP110.PROD.OUTLOOK.COM
>
EFTA00023687


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=== Page 1 ===
From:
)"
To: "McGorty, Glen"
Cc:
)"
"Zelenko, Daniel"
"Giffuni, Danielle"
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Thu, 06 May 2021 17:10:15 +0000
Thanks, that would be great. We can use this conference line:
, passcode
Original Message
From: McGorty, Glen
Sent: Thursday, May 6, 2021 12:55 PM
To:
Cc:
X
Zelenko, Daniel
Giffuni, Danielle
(USANYS)
Subject: Re: Wednesday's WebEx
Of course. How is 3 pm?
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<x-apple-data-detectors://6/1>th<x-apple-data-detectors://
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EFTA00024938

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On May 6, 2021, at 12:50 PM,
)
wrote:
External Email
Hi Glen,
Hope you're doing well. Do you have time for a quick call this afternoon or tomorrow?
Thanks very much,
From:
Sent: Wednesday, November 18, 2020 10:52 AM
To: McGorty, Glen
..
)
Cc: Zelenko, Daniel
; Giffuni, Danielle
(USANYS)
Subject: RE: Wednesday's WebEx
Glen,
Attached please find the fully executed proffer agreement with the agent's initials and my initials added.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
From:
)
Sent: Tuesday, November 17, 2020 9:30 PM
To: McGorty, Glen
<mailto:
;
)
<mailto:
Cc: Zelenko, Daniel
<mailto:
>; Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
Received, thank you very much, Glen.
Best,
EFTA00024939

=== Page 3 ===
Assistant United States Attorney
Southern District of New York
<mailto:
From: McGorty, Glen
<mailto:
Sent: Tuesday, November 17, 2020 8:21 AM
To:
<mailto:
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
sorry for the delay. Here is the executed proffer agreement from our last meeting.
Best,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
https://protect2.fireeye.com/v1/url?k=f71221c7-
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253A-252F-252Fwww.crowell.com-252Fprofessionals-252FGlen-
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COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource
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4hDu615ug_T7XCVardfvyVA4USCDMtMTJH_9MCwLk%26e%3D>
From:
)
<mailto:
Sent: Wednesday, November 11, 2020 1:43 PM
To: McGorty, Glen
<mailto:
)
<mailto:
Cc: Zelenko, Daniel
<mailto:
>; Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Glen,
We will be joined by two FBI agents who are focusing on the CBP topics that we have previously discussed. I
expect one of those agents will take the lead on questioning Mr.
The topics we expect to cover include:
* The identities of any CBP employees Mr.
recalls interacting with Jeffrey Epstein in the Virgin Islands.
* Any steps Mr.
recalls any CBP employees in the Virgin Islands taking to help Epstein and those
traveling with Epstein to enter the country, including any steps that allowed Epstein or those traveling with him
to avoid processing that travelers would normally undergo.
* Any favors Mr.
recalls Epstein doing for CBP employees in the Virgin Islands, such as trips to
Epstein's island.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
From: McGorty, Glen
<mailto:
Sent: Tuesday, November 10, 2020 1:16 PM
To:
<mailto:
)
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
EFTA00024941

=== Page 5 ===
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully
prepared, so if there is any more granularity on this topic (or any additional topic or topics), please let us know.
Thanks,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
I
https://protect2.fireeye.com/v1/url?k=dc0510d8-
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From:
)
<mailto:
Sent: Monday, October 26, 2020 6:19 PM
To: McGorty, Glen
<mailto:
)
<mailto:
Cc: Zelenko, Daniel
<mailto:
>; Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Thanks very much, Glen. Let's plan for 1pm on Thursday, 11/12. I will circulate a WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
,
the U.S. Customs and Border
Protection employee who worked in Saint Thomas and who had Mr.
listed as a contact in his phone. I
expect we will ask for an approximate timeline of when Mr.
met and interacted with
, the nature
of those interactions, and any interactions
may have had with Epstein (to the best of Mr.
knowledge).
Best,
Assistant United States Attorney
Southern District of New York
<mailto:
EFTA00024943

=== Page 7 ===
From: McGorty, Glen
<mailto:
Sent: Monday, October 26, 2020 11:58 AM
To:
<mailto:
)
<mailto:
A
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
Sorry for the delay. Looks like we can do between 11 a.m. and 2 p.m. on Tuesday, 11/10, or any time on
Thursday, 11/12. Let us know if anything in that range will work.
So as to make sure Mr.
is prepared, can you give us an overview of what you expect to cover?
Thanks,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
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Center<https://protect2.fireeye.com/v1/url?k=2221ea22-7dbad2d2-2226cec7-ac1f6b0176b0-
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EFTA00024945

=== Page 9 ===
253D%26d%3DDwMFAg%26c%3DAnw7wKLFSGyH7zEzIqo-zgMRy5HE-AH-
SibmOy3H7xE%26r%3Dz3qSdxmKBzz6GPGylfF-
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NJ0fcA4DmP6v-LanqWQLToaJ-5gCKcrjX-hBWEeZvg%26e%3D>
From:
)
<mailto:
Sent: Thursday, October 22, 2020 10:33 AM
To:
<mailto:
McGorty, Glen
<mailto:
Cc: Zelenko, Daniel
<mailto:
>; Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Glen,
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via WebEx. Are there any days the week of November 9th when your team and Mr.
would be
available? We would expect this proffer to be much shorter than our first, and certainly no more than two hours
at most.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
From:
<mailto:
Sent: Friday, October 9, 2020 4:42 PM
To: McGorty, Glen
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
Hi Glen,
Thanks very much. I'm attaching the fully executed copy.
Thanks,
From: McGorty, Glen
<mailto:
EFTA00024946

=== Page 10 ===
Sent: Thursday, October 8, 2020 9:31 AM
To:
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
I
https://protect2.fireeye.com/v1/url?k=da840e91-
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EFTA00024947

=== Page 11 ===
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Privileged and Confidential Attorney-Client Communication Attorney Work Product This message contains
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Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource
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985e4f7e982ffae6&q=1&e=1d1e9fd4-963c-4f0c-9030-
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EFTA00024948

=== Page 12 ===
From:
<mailto:
Sent: Monday, October 5, 2020 4:14 PM
To: McGorty, Glen
<mailto:
Cc: Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
(USANYS)
<mailto:
)
<mailto:
Subject: RE: Wednesday's WebEx
External Email
Hi Glen,
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues
crop up, and we'd be happy to work through them.
Thanks,
From: McGorty, Glen
<mailto:
Sent: Monday, October 5, 2020 12:48 PM
To:
)
<mailto:
)
<mailto:
(USANYS)
<mailto:
Cc: Zelenko, Daniel
<mailto:
<mailto:
Giffuni, Danielle
<mailto:
Morrissey, Josh
<mailto:
Subject: Wednesday's WebEx
,
,
,
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail: Dan,
Danielle and Mr.
, but also Josh Morrissey who is in our IT group and will make sure we are good to go
for our meeting.
Thanks,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
<mailto:
|
https://protect2.fireeye.com/v1/url?k=c09173b4-
9f0a4b44-c0965751-ac1f6b0176b0-29cd07b17c018992&q=1&e=1d1e9fd4-963c-4f0c-9030-
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=== Page 13 ===
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EFTA00024951


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=== Page 1 ===
From:
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Date: Mon, 14 Sep 2020 19:31:55 +0000
You are most welcome.
You will receive a link shortly.
Office of The State Attorney, 15th Judicial Circuit
West Palm Beach, FL 33401
Original Message
From:
Sent: Monday, September 14, 2020 3:30 PM
To
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Received, thank you very much.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
Original Message
From:
Sent: Monday, September 14, 2020 3:23 PM
To:
Subject: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
The attached document is in regard to the above referenced case, to which you are a party of or have an interest
in. If you have any questions, please contact our office at
Please note: Florida has a very broad public records law. Most written communications to or from state officials
regarding state business are public records available to the public and media upon request. Your e-mail
communications may therefore be subject to public disclosure.
EFTA00023541


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=== Page 1 ===
From:
Subject: Accepted: Mark Epstein Meeting
Date: Mon, 04 Nov 2019 14:19:56 +0000
Importance: Normal
Attachments: unnamed
EFTA00023933


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=== Page 1 ===
Event: Accepted: Epstein estate call
Start Date: 2019-12-02 15:30:00 +0000
End Date: 2019-12-02 16:00:00 +0000
Location: Skype Meeting; Conference ID: 169 269 771;
Class: X-PERSONAL
Comment:
Date Created: 2019-11-25 15:12:12 +0000
Date Modified: 2019-11-25 15:12:12 +0000
Priority: 5
DTSTAMP: 2019-11-25 14:50:35 +0000
Attendee: Weinstein, Marc A.
EFTA00025252


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: RE: the week ahead
Date: Fri, 18 Sep 2020 13:53:49 +0000
Also, while you're obviously recused from the merits, the Cops argument is Monday morning at 10, which will be a big test
of Silver.
is doing the argument, panel is Walker, Carney and Park.
From:
(USANYS)
Sent: Friday, September 18, 2020 9:13 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: the week ahead
Hi
Another relatively quiet week for the PCU.
-
NYCHA. On Monday we have the NYCHA meeting with the Brass. The team circulated the relevant materials by
email earlier this week.
-
Robert Adams Arrest. At some point next week we expect to arrest Robert Adams, a guard at MCC who we
indicted yesterday with bribery in connection with an incident last year when he caught a woman smuggling in
contraband, and told her she wouldn't get in trouble if she went to a motel and had sex with him, which she did.
The FBI is working on the details and exact timing of the arrest; we are exploring whether an arrest at MCC or a
voluntary surrender would be appropriate. (If the name sounds familiar, Adams was working in the SAMS unit the
night of Epstein's suicide, and we interviewed him and got him appointed counsel in connection with that
investigation; this charge spun out of that). We plan to do a press release.
Have a nice weekend!
From:
(USANYS)
Sent: Friday, September 18, 2020 8:52 AM
To:
Subject: the week ahead
Happy National Cheeseburger Day! Enjoy lunch (breakfast?), and then please promptly turn your attention to letting me
know what's happening in your unit next week.
Thanks as always.
P.S. If you are looking ahead to tomorrow (and who isn't), you should know that it is International Talk Like a Pirate Day.
Aargh!
EFTA00025524

=== Page 2 ===
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00025525


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: travel approval request
Date: Thu, 13 Feb 2020 13:10:31 +0000
Okay, thanks for informing me
Please let me know ASAP the definite date(s) you would like to schedule the
conference room for at the Beverly Hilton Hotel for so I can get the conference room documentation processed and
funded by
in Budget.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Thursday, February 13, 2020 1:15 AM
To:
Cc:
is
Subject: FW: travel approval request
just FYI, in connection with this trip to Los Angeles, I just made a reservation for a hotel on E2 (see attached) - if I
did anything wrong, it can be changed, but it's a hotel that is almost never available for us so I wanted to make the
reservation tonight just in case. And will follow up with flights in the coming days. Happy to chat if that's useful, and
thanks very much.
From:
Sent: Wednesday, February 12, 2020 22:55
To:
Cc:
is
>;
Subject: Re: travel approval request
Approved
Sent from my iPad
On Feb 12, 2020, at 9:14 PM,
wrote:
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 three interviews in Los Angeles on February 26, 27, and 28 (we have at
least one interview on each of those days). We expect to be traveling, respectively, some combination of the 25th to the
29th. Also similar to prior trips, we'd like to request approval to get a conference room for one of those dates (the
26th).
thank you,
EFTA00026843

=== Page 2 ===
From:
)
Sent: Tuesday, January 21, 2020 14:49
To:
Cc:
is
V.
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the 27th
(overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on our
formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of those
days at a hotel for the interview itself.
Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as well
as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input on
that.
thank you,
From:
Sent: Wednesday, December 11, 2019 09:58
To:
Cc:
>;
)
V.
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
V.
Subject: RE: travel approval request
EFTA00026844

=== Page 3 ===
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
>;
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 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:
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
Subject: RE: travel approval request
EFTA00026845

=== Page 4 ===
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
)
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week
for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night
and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
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
EFTA00026846

=== Page 5 ===
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:
(USANYS)"
(USANYS)"
Cc:
)"
Subject: RE: Cite Check
Date: Wed, 27 Oct 2021 16:06:32 +0000
Attachments: Govt_Reply_v2.docx
Hi
Thanks for the help with this project! I've attached the document we need citechecked. Feel free to give me a call if you
have any questions!
From:
(USANYS)
Sent: Wednesday, October 27, 2021 11:03 AM
To:
(USANYS)
Cc:
)
is
Subject: RE: Cite Check
Thanks so much
!
We really appreciate you helping out. We should have something to send to you for cite
checking fairly soon. Thanks again!
From:
(USANYS)
Sent: Wednesday, October 27, 2021 10:39 AM
To:
(USANYS)
Subject: Cite Check
Good Morning,
My name is
and I am an intern in the office assigned to
He told me to reach out to
you as I believe you wanted something cite checked? If so I would be happy to help with whatever the assignment is.
Thank you,
EFTA00025145


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=== Page 1 ===
From: "Chris R. Rodgers"
To:
)"
, Jack Scarola
Cc:
)"
N
(USANYS)"
>, Mary McCann
>, "Wendy P.
Calvet"
Subject: RE:
- Discovery Responses
Date: Tue, 19 Jan 2021 18:50:10 +0000
Attachments:
s_Second_Amended Answers_to_Interrogs-10104500-10108102.pdf;
Pltf S Amended_NSA -
-10081828.pdf;
s_Notice_of_Serving_Verified_Answer.r_Interrogatories-10105037-10108103.pdf;
3rd_Amended_Answers_to_Interrogs -
-10107590.pdf; Answers_to_Interrogatories-
633274.pdf; Pltf_s_Suppl_RRP_-
10107593.pdf;
-answers_to_rtp-633273.pdf
Attached please find the Discovery Responses filed on
behalf in her civil matter against Epstein.
I
Privileged and Confidential | Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin.
2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is
not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this
communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at
and destroy all copies of the original message. Thank you.
EFTA00024995


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: Re: URGENT REQUEST FOR VTCs-GHISLAINE MAXWELL 02879-509
Date: Tue, 15 Dec 2020 17:33:54 +0000
Embedded: Re:_URGENT_REQUEST_FOR_VTCs-GHISLAINE_MAXWELL_02879-509.msg
Sender:
Subject: Re: URGENT REQUEST FOR VTCs-GHISLAINE MAXWELL 02879-509
Message-Id: <C76AF8C5-E863-42FD-9F72-6F28B90E9D75@mac.com>
Recipient:
EFTA00024291


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=== Page 1 ===
From:
)"
To: "Hudgens, Johanna Rae"
Subject: Accepted: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
Date: Wed, 06 Nov 2019 18:13:35 +0000
Importance: Normal
Attachments: unnamed
EFTA00025376


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=== Page 1 ===
From:
)"
To: Jennifer Richardson
, Gary Bloxsome
Cc: Daniel Cundy
)"
)"
Subject: RE: Sensitive Correspondence
Date: Mon, 03 Aug 2020 14:44:48 +0000
Inline-Images: image001.jpg; image002.jpg
Jen,
Confirmed, thank you - we look forward to speaking with you shortly.
Best,
From: Jennifer Richardson
Sent: Monday, August 03, 2020 10:37
To:
; Gary Bloxsome
Cc: Daniel Cundy ;
) ;
Subject: RE: Sensitive Correspondence
Dear
Just confirming dial in details for our 4pm teleconference as follows:
1. Dial-in number(s):
2. Enter Guest PIN:
Kind regards
Jen
Jennifer Richardson I Solicitor-Advocate
RANKED IN
Chambers
UK
Blackfords LLP
I
2020
TOP TIER
www.blackfords.com
Leading Firm
2020
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
From:
Sent: 31 July 2020 19:53
To: Gary Bloxsome
Cc: Daniel Cundy
>; ; Jennifer Richardson
>; ; Moe,
EFTA00023817

=== Page 2 ===
Alison (USANYS)
is
Subject: RE: Sensitive Correspondence
External email: is it safe to open attachments and links?
Gary,
Thank you for your email below, which we have received. We will confer on these issues and we look forward to speaking
again on Monday.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Friday, July 31, 2020 12:14
To:
Cc: Daniel Cundy
>; Jennifer Richardson
in
is
Subject: Re: Sensitive Correspondence
Dear
Thank you for your emails of 28th and 29th July 2020.
In relation to protections equivalent to those that would be available in any compelled MLAT interview, we would
seek to secure the following from you;
[1] An undertaking that the evidence obtained from our client pursuant to the agreement will not be used for any
purpose other than that specified in the agreement namely, the proceedings on indictment in US V Maxwell,
without the consent of our client and;
[2] An undertaking that the answers to questions, statements, or information given by the client in a voluntary
interview conducted with the DOJ, shall not be used in evidence against the client, except as against the client for
possible prosecution in the UK for providing false or misleading statements or where the client, in giving evidence
in a prosecution for some other offense, provides testimony inconsistent with his responses given in the voluntary
interview, pursuant to the agreement.
Kind regards and speak on Monday.
Gary
Gary Bloxsome I Partner
RANKED IN
Chambers
Blackfords LLP
I
UK
500
www.blackfords.com
2020
TOP TIER
Leading Firm
2020
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00023818

=== Page 3 ===
On 29 Jul 2020, at 20:19,
>
wrote:
External email: is it safe to open attachments and links?
Gary,
A brief update to the below information - I should have included the specific jury instruction elements for 18 U.S.C.
1001, subsection (2), which likely would be more applicable to a prosecution based on a proffer statement. Although the
knowing and willful element in particular is identical, we nevertheless wanted to provide this to you as well. Pursuant to
Sand, Modern Federal Jury Instructions, Instruction 36-9 (Elements of the Offense), those elements are:
First, on or about the date specified, the defendant made a statement or representation;
Second, that this statement or representation was material;
Third, the statement or representation was false, fictitious or fraudulent;
Fourth, the false, fictitious or fraudulent statement was made knowingly and willfully; and
Fifth, the statement or representation was made in a matter within the jurisdiction of the government of the United
States (or federal funds were involved).
Regards,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Tuesday, July 28, 2020 18:29
To: Gary Bloxsome
Cc: Daniel Cundy
>; Jennifer Richardson
is
is
Subject: RE: Sensitive Correspondence
Gary,
We write to follow up on our conversation yesterday, to confirm certain aspects of our discussion and to provide certain
information you requested. First, thank you for conveying your questions, and I hope our initial responses were of some
use. To provide additional information that may be helpful, attached please find a blank proffer agreement, which is our
standard form agreement for proffer interviews, as you requested. Please note that in addition to the provisions I briefly
described on our call, there are also provisions that may not be relevant to your client. We nevertheless send the
complete agreement for your review.
Additionally, and also as requested, certain information relating to Title 18, United States Code, Section 1001, is
provided below.
In relevant part, that statute states the following: "Except as otherwise provided in this section, whoever, in any matter
within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States, knowingly
and willfully-(1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact; (2) makes any materially
false, fictitious, or fraudulent statement or representation; or (3) makes or uses any false writing or document knowing
the same to contain any materially false, fictitious, or fraudulent statement or entry [is guilty of an offense]. The full
language of the statute is also available here.
Regarding the elements required to prove such an offense, pursuant to Sand, Modern Federal Jury Instructions,
Instruction 36-3 (Elements of the Offense), a conviction for this offense require that the following elements each must
be proven beyond a reasonable doubt:
First, that on or about the date specified in the indictment, the defendant falsified (or concealed or covered up) a
material fact;
Second, that the fact falsified (or concealed or covered up) was material;
Third, that defendant did so by trick, scheme or device;
Fourth, that defendant acted knowingly and willfully; and
EFTA00023819

=== Page 4 ===
Fifth, that the falsification, concealment or coverup was with respect to a matter within the jurisdiction of the
government of the United States (if applicable: or that federal funds were involved).
You may note in particular the inclusion of the "knowingly and willfully" requirement, as we discussed.
We also understand that you will send us, to the extent you believe it is relevant or helpful for our consideration, any
particular provisions or protections contemplated under the MLAT process, and which of those, if any, you believe are
relevant, or should be applicable, to a voluntary interview.
We look forward to speaking with you again this coming Monday, August 3, at 4:00 p.m. (LDN time), and we further
confirm, as discussed, that our Office is prepared to extend the Negotiation Period, referenced in our email of July 14,
2020, for two weeks from our call yesterday, to August 10, 2020, under the terms previously mutually agreed upon.
Regards,
Assistant U.S. Attorney
Southern District of New York
EFTA00023820


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=== Page 1 ===
DGC
ACCOUNTING TAX ADVISORY
SCOTT BORGERSON & GHISLAINE MAXWELL
DEAR SCOTT & GHISLAINE:
ENCLOSED ARE YOUR 2019 INCOME TAX RETURNS, AS FOLLOWS...
2019 U.S. INDIVIDUAL INCOME TAX RETURN
2019 FEDERAL REPORT OF FOREIGN BANK AND FINANCIAL ACCOUNTS
2019 MASSACHUSETTS INDIVIDUAL INCOME TAX RETURN
FORM(S) 114, REPORT OF FOREIGN BANK AND FINANCIAL ACCOUNTS, WILL BE
ELECTRONICALLY FILED WITH THE FINCEN.
WE PREPARED THE RETURNS FROM INFORMATION YOU FURNISHED US WITHOUT
VERIFICATION. UPON EXAMINATION OF THE RETURNS BY TAXING AUTHORITIES, REQUESTS
MAY BE MADE FOR UNDERLYING DATA. WE THEREFORE RECOMMEND THAT YOU PRESERVE
ALL RECORDS WHICH YOU MAY BE CALLED UPON TO PRODUCE IN CONNECTION WITH SUCH
POSSIBLE EXAMINATIONS.
VERY TRULY YOURS,
Lama K. Barooshia
LAURA K. BAROOSHIAN
DICICCO, GULMAN & COMPANY LLP
150 Presidential Way, Suite 510, Woburn, MA 01801 781.937.5300 dgccpa.com
EFTA00025558

=== Page 2 ===
2019 TAX RETURN FILING INSTRUCTIONS
REPORT OF FOREIGN BANK AND FINANCIAL ACCOUNTS
PREPARED FOR:
SCOTT BORGERSON & GHISLAINE MAXWELL
PREPARED BY:
DICICCO, GULMAN & COMPANY, LLP
150 PRESIDENTIAL WAY, SUITE 510
WOBURN, MA 01801
FORM MUST BE FILED ON OR BEFORE:
RETURN FORM(S) 114A TO US ON OR BEFORE OCTOBER 15, 2020.
SPECIAL INSTRUCTIONS:
THE SPOUSE'S FORM 114 HAS BEEN PREPARED FOR ELECTRONIC FILING.
PLEASE SIGN, DATE, AND RETURN FORM 114A TO OUR OFFICE. WE WILL THEN
TRANSMIT THE SPOUSE'S FORM TO THE FINCEN.
EFTA00025559

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=== Page 4 ===


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc:
Christian Everdell
>, "Mark S. Cohen"
Subject: Re: URGENT re: Ghislaine Maxwell 02879-509
Date: Fri, 15 Jan 2021 18:27:26 +0000
I am on the VTC with Ms. Maxwell.
She has not received the time-sensitive legal mail referenced in my earlier email.
Please assist in getting this legal mail provided to her today.
Thank you-
Enjoy the long weekend.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
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.
On Jan 15, 2021, at 11:01 AM, BOBBI C STERNHEIM wrote:
Good morning-
The "next-day" express mailing (referenced in yesterday's email below)
was delivered to the MDC today at 7:25 am (see tracking information below).
As requested, it is imperative that Ms. Maxwell be given this legal mail containing time-sensitive
documents TODAY.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
EFTA00024992

=== Page 2 ===
Main:
Cell:
Fax:
*Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
On Jan 14, 2021, at 2:38 PM, BOBBI C STERNHEIM
wrote:
Good afternoon-
Yesterday, we expressed mailed time-sensitive documents to Ms. Maxwell for delivery today.
We are requesting that this legal mail be given to Ms. Maxwell immediately.
She must have them by tomorrow, Friday, for review over the weekend.
I received no response to the email regarding these documents (see below).
The courtesy of a response to today's email is appreciated.
Thank you-
Bobbi
On Jan 12, 2021, at 11:12 PM, BOBBI C STERNHEIM
wrote:
Good morning-
On Thursday, 12/14, we are express mailing time-sensitive documents for next-day delivery for review by
Ms. Maxwell. We need to discuss these documents with Ms. Maxwell on Tuesday 12/19, in order to comply
with a court-ordered filing deadline. We understand that legal calls are suspended on holidays (Monday,
1/18, is Martin Luther King Day).
To ensure that Ms. Maxwell receives the documents on Friday for review over the weekend, we are
requesting permission to send them to the attention of the Legal Department for prompt delivery to Ms.
Maxwell.
Please let me know if this is acceptable.
In addition, we are requesting that Ms. Maxwell be given access to the laptop
computer provided by the government for use over the weekend.
The MDC computers are not capable of opening discovery documents provided by the government,
which is why the laptop has been provided. Without access to a computer that allows her
to review discovery, Ms. Maxwell is effectively denied the ability to assist in her defense.
Your assistance is greatly appreciated.
EFTA00024993

=== Page 3 ===
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
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.
EFTA00024994


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=== Page 1 ===
EXHIBIT 1

=== Page 2 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 11, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Pursuant to Judge Nathan's Order of September 3, 2021 (Dkt. No. 335), the Government
writes to inform you that it may refer at trial to the following individuals as co-conspirators of the
defendant, including for the purpose of Fed. R. Evid. 801(d)(2)(E):
Jeffrey Epstein
The Government has produced all co-conspirator statements which it intends to offer at
trial pursuant to Fed. R. Evid. 801(d)(2)(E) in the Government's production today or in its previous
productions. To the extent the Government learns of additional co-conspirator statements as it
continues to prepare for trial, it will produce those statements in connection with its ongoing
obligation to produce Jencks Act material.
EFTA00025067

=== Page 3 ===
Page 2
Please be advised that the above list is limited to the individuals the Government may refer
to as co-conspirators at trial. While the Government makes no representations as to whether it
views other individuals as potential or actual co-conspirators of the defendant, it does not intend
to refer to any other individuals as co-conspirators at trial. The above list is also not intended to
reflect a complete list of individuals who may be referenced at trial. That information is contained
in the Government's Jencks Act production(s).
Please note that this letter and the information contained herein is governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential" under the
Protective Order.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
EFTA00025068


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=== Page 1 ===
Event: Accepted: Epstein Call
Start Date: 2020-05-22 17:00:00 +0000
End Date: 2020-05-22 18:00:00 +0000
Location: 877-720-9282 - 8146826
Class: X-PERSONAL
Comment:
Date Created: 2020-05-21 13:53:00 +0000
Date Modified: 2020-05-21 13:53:00 +0000
Priority: 5
DTSTAMP: 2020-05-21 13:35:08 +0000
Attendee:
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=== Page 1 ===
From:
To:
Subject: Update division
Date: Fri, 01 Mar 2019 14:55:01 +0000
Importance: Normal
Epstein
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
t.
EFTA00027045


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 19:09:23 +0000
Thanks!
From:
Sent: Thursday, July 2, 2020 3:01 PM
To:
Subject: Fwd: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations!
Begin forwarded message:
From:
Date: July 2, 2020 at 1:22:27 PM EDT
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
[cid:image001.png@01D53E43.CA2BB290]
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH
JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS<https://edit.justice.gov/usao-sdny/pr/ghislaine-
maxwell-charged-manhattan-federal-court-conspiring-jeffrey-epstein-sexually
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F. Sweeney
Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation
("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"), announced that
GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel to engage in
criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity, conspiracy to
commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment unsealed
today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator Jeffrey
Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in
federal court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and participated
EFTA00024531

=== Page 2 ===
in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then delivered them
into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust. All the while,
she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself. Today, after
many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the most
important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the law
and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest
for justice has been met with great disappointment for the victims, and that reliving these events is traumatic.
The example set by the women involved has been a powerful one. They persevered against the rich and
connected, and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the
bravery exhibited by the women involved here has empowered others to speak up about the crimes of which
they've been subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will be
abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact the FBI at 1-
800-CALL FBI, and reference this case.
According to the Indictment[ unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated in
Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies
or taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's
behavior. Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to
accept offers of financial assistance from Epstein, including offers to pay for travel or educational expenses.
MAXWELL also normalized and facilitated sexual abuse by discussing sexual topics with victims,
encouraging them to massage Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and susceptible
to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between minor victims
and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL was present
for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages during which a
minor victim was fully or partially nude, as well as group sexualized massages of Epstein involving a minor
victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching of a
victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to touch
Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and Epstein's
victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as well as
MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made false
statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal sex
acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
EFTA00024532

=== Page 3 ===
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent unless
and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook<https://www.facebook.com/usaosdny/> Follow us on
Twitter<https://twitter.com/SDNYnews> SDNY website<http://www.justice.gov/usao-sdny>
|YouTube<https://www.youtube.com/user/USAOSDNY>
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the
Indictment set forth herein, constitute only allegations, and every fact described therein should be treated as an
allegation. The defendant is presumed innocent unless and until proven guilty.
<image001.png>
<U.S. V. Ghislaine Maxwell Indictment.pdf>
<Ghislaine Maxwell Indictment PR.pdf>
EFTA00024533


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=== Page 1 ===
From: "Weinstein, Marc A."
To:
,
"Tomback, Andrew"
Subject: Epstein estate
Date: Wed, 23 Oct 2019 13:06:09 +0000
Importance: Normal
Attachments: unnamed
Inline-Images: ATT33828_1.jpg
HHR OnlineMeetingCenter
Dial-In Information (for meetings with no presentations or video)
Dial-In Number:
Conference ID:
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
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Full list of dial-in numbers
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Joining from a computer using the "Connect from computer or mobile device" link provides additional
capabilities, however you can simply call in from your telephone using the number provided above if your
meeting will not include video or a presentation. Click the "Help" link for additional information if you are a
guest joining a Skype for Business meeting from your computer or mobile device for the first time.
For meeting organizers: Reset your dial-in PIN?
EFTA00024296


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=== Page 1 ===
From:
(USANYS)"
To:
Cc:
Subject: Re: Tip re Epstein
Date: Sat, 17 Aug 2019 15:13:58 +0000
who are copied.
> On Aug 17, 2019, at 10:57 AM,
wrote:
V
V
a defense attorney who represents an inmate at MCC called me last night with some information. Who
shall I connect her with at SDNY?
V
>
> Sent from my iPhone
EFTA00024008


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=== Page 1 ===
From:
(USANYS)"
To:
Cc:
)"
Subject: FW: Letter regarding jail conditions and court appearance
Date: Fri, 21 Aug 2020 17:25:07 +0000
Attachments: Ltr_to_Judge_Karas_-_re_Continued_Inhumane_Prison.pdf
- Can we please jump on a call this afternoon to discuss? As you can see, we have only until Monday to respond.
Co-Chief, Narcotics Unit
O:
U.
From:
Sent: Friday, August 21, 2020 1:22 PM
To: Bruce Barket
Cc: Aida Leisenring
>;
>;
>; Michael Bachrach
>;
>; John Diaz
in
is
is
(USANYS)
is
(USANYS)
is
>;
(USANYS)
Subject: Re: Letter regarding jail conditions and court appearance
All,
Attached please find a memo endorsement from Judge Karas.
-Chambers of Judge Karas
From: Bruce Barket
Sent: Thursday, August 20, 2020 6:24 PM
To:
Subject: FW: Letter regarding jail conditions and court appearance
Good afternoon,
I sent this to
but wanted to forward here as well. Can you confirm that the judge will see it?
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
EFTA00023680

=== Page 2 ===
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
From: Bruce Barket
Sent: Thursday, August 20, 2020 12:50 PM
To:
Cc: Aida Leisenring
>; ; tonyricco
is
>; Michael Bachrach
>; Kenneth J. Montgomery Esq
>; 'john diaz
(
)'
is
i
is
is
(USANYS)
is
is
(USANYS)
(
Subject: Letter regarding jail conditions and court appearance
I hope all is well. Can you please bring this letter to the attention of the judge? Note that I copied the lawyer for the MCC
and the prosecution team as well as firewall counsel. Thank you.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
EFTA00023681


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=== Page 1 ===
Case 1:19-cv-03377-LAP Document 100 Filed 12/20/19 Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
V.
ALAN DERSHOWITZ,
Civil Action No. 1:19-cv-3377 (LAP)
Defendant.
ALAN DERSHOWITZ,
Counterclaim Plaintiff,
V.
,
Counterclaim Defendant.
PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF HER
MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT
Pursuant to Rule 15(a) of the Federal Rules of Civil Procedure, Plaintiff
respectfully requests leave of the Court to file the attached Amended Complaint. This motion
should be granted for three reasons. First, since Plaintiff filed her complaint in April 2019, the
revival provision of the New York Child Victims Act has gone into effect, reviving a battery claim
against Defendant Alan Dershowitz that had previously been time barred. N.Y.C.P.L.R. $ 214-g.
Second, since Plaintiff filed her Complaint, Defendant has produced a copy of a recording
that he represents captures a portion of a confidential telephonic settlement conference between
EFTA00027039

=== Page 2 ===
Case 1:19-cv-03377-LAP Document 100 Filed 12/20/19 Page 2 of 5
himself and Plaintiff's attorney, David Boies. 1 This unauthorized recording, use, and disclosure of
a communication made on Plaintiff's behalf for the purpose of defaming Plaintiff violates 18
U.S.C. $ 2511(1). As a "person whose wire, oral, or electronic communication" was "intercepted,
disclosed, [and] intentionally used in violation" of that provision, Ms.
is entitled to recover
from Mr. Dershowitz. Id. $ 2520.
Finally, since Plaintiff filed her Complaint, Defendant's campaign of defamatory
statements against Ms.
has not only continued but has intensified. Each new defamatory
statement gives rise to a new claim for defamation. Although the frequency with which Mr.
Dershowitz defames her will prevent Ms.
from amending her complaint every time Mr.
Dershowitz publishes a new defamatory statement, the scope and nature of the new statements
justify an amendment in this instance, especially given that Ms.
is amending the complaint
to add the other two claims.
Federal Rule of Civil Procedure 15 provides that a plaintiff may amend her complaint
"with the opposing party's written consent or the court's leave." FED. R. CIV. P. 15(a)(2). "The
court should freely give leave when justice so requires." Id.
In the absence of any apparent or declared reason-such as undue delay, bad faith
or dilatory motive on the part of the movant, repeated failure to cure deficiencies
by amendments previously allowed, undue prejudice to the opposing party by
virtue of allowance of the amendment, futility of amendment, etc.-the leave
sought should, as the rules require, 'be freely given.'
Foman V. Davis, 371 U.S. 178, 182 (1962) (quoting FED. R. CIV. P. 15(a)). "[A]bsent a showing
of bad faith or undue prejudice," mere delay "does not provide a basis to deny
the
right
to
amend." State Teachers Ret. Bd. V. Fluor Corp., 654 F.2d 843, 856 (2d Cir. 1981). Moreover, "the
1
Dershowitz had previously claimed to have such a recording, but Plaintiff and her
attorneys did not obtain access to it until after the complaint was filed.
2
EFTA00027040

=== Page 3 ===
Case 1:19-cv-03377-LAP Document 100 Filed 12/20/19 Page 3 of 5
party opposing the amendment bears the burden of showing prejudice, bad faith, and futility
"
Williams V. Epic Security Corp., 358 F. Supp. 3d 284, 294 (S.D.N.Y. 2019) (quotation marks
omitted).
There is no reason to deny leave to amend in this instance. Defendant has no valid basis to
allege "undue delay, bad faith or dilatory motive" on Plaintiff's part: the events precipitating the
battery and Wiretap Act claims occurred while a motion to dismiss the Complaint was pending.
Many of the new defamatory statements occurred during the same period or even more recently.
When it denied the motion to dismiss, the Court also disqualified Plaintiff's counsel. Her new
counsel have worked diligently since their retainer less than two months ago to develop Plaintiff's
new claims.
Defendant will not be prejudiced by the amendment. The case is in its early stages, with
parties making initial disclosures this week, and most of the factual allegations underpinning
Plaintiff's new claims-including the truth or falsity of the new defamatory statements-depend
on the same body of proof as the claims and counterclaims already in suit.
Defendant has indicated that he will argue that the claims are futile. The only ground for
futility his counsel has identified-that Plaintiff was too old at the time of the battery to invoke
the revival statute, see Transcript of Dec. 2, 2019, Status Conference, Doc. No. 96 at 20 ("Dec. 2
Tr.")-raises a question of fact unsuitable for resolution on a motion to amend. See, e.g., Benton
V. Brookfield Properties Corp., 2004 WL 1335908, *6 (S.D.N.Y. June 14, 2004) (granting leave
to amend where merits of new claim depended upon a question of fact). The statute re-opens the
limitations period for one year beginning in August 2019 for civil actions arising from conduct
that violated Article 130 of the Penal Code committed against the Plaintiff before the age of 18.
N.Y.C.P.L.R. $ 214-g. The proposed Amended Complaint alleges Defendant sexually assaulted
3
EFTA00027041

=== Page 4 ===
Case 1:19-cv-03377-LAP Document 100 Filed 12/20/19 Page 4 of 5
her prior to the age of 18. See Proposed Amended Complaint 11 38, attached as Exhibit A to the
Declaration of Haley Proctor (Dec. 20, 2019) ("Proposed Am. Compl."). Accordingly, the battery
claim is not futile.
The Court independently raised the question whether Ms.
would have "standing"
to make a claim under the Wiretap Act. See Dec. 2 Tr. at 21. Section 2520 of Title 18 provides for
civil relief under the Act for "any person whose wire, oral, or electronic communication is
intercepted, disclosed, or intentionally used in violation of this chapter." 18 U.S.C. $ 2520(a)
(emphasis added). Thus, Plaintiff must have a "possessory interest" in the communication to bring
a claim under the Act. Smoot V. United Transp. Union, 246 F.3d 633, 640 (6th Cir. 2001). Courts
have held that statements made by an agent of the plaintiff in course of the agent's representation
of the plaintiff are possessed by the plaintiff and thus are sufficient to confer standing to bring a
Wiretap Act claim. E.g., id. at 640-41. In the Proposed Amended Complaint, Ms.
has
sufficiently alleged a possessory interest because the captured communication was a confidential
settlement communication made by her attorney. See Proposed Am. Compl. 76, 117-18.
Accordingly, the Wiretap Act claim is not futile.
For the reasons stated above, Plaintiff respectfully requests that the Court grant her Motion
for Leave To File an Amended Complaint.
Dated: December 20, 2019
Respectfully submitted,
/s/ Charles J. Cooper
Charles J. Cooper*
Michael W. Kirk*
Nicole J. Moss*
Haley N. Proctor*
COOPER & KIRK PLLC
1523 New Hampshire Ave. NW
Washington, DC 74008
(202) 220-9600
*Admitted PHV
4
EFTA00027042

=== Page 5 ===
Case 1:19-cv-03377-LAP Document 100 Filed 12/20/19 Page 5 of 5
CERTIFICATE OF SERVICE
I hereby certify that on December 20, 2019, I electronically filed the foregoing with the
Clerk of the Court using the CM/ECF system, and I hereby certify that the foregoing was served
upon all counsel of record using the CM/ECF system.
/s/ Charles J. Cooper
Charles J. Cooper*
COOPER & KIRK PLLC
1523 New Hampshire Ave. NW
Washington, DC 74008
(202) 220-9600
*Admitted PHV
Attorney for Plaintiff
EFTA00027043


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=== Page 1 ===
From:
To:
Subject: Accepted:
Date: Mon, 04 Nov 2019 15:17:18 +0000
Importance: Normal
Attachments: unnamed
EFTA00023934


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=== Page 1 ===
From:
To:
Cc:
Subject: Tags for US V. Epstein Relativity Database
Date: Sun, 20 Sep 2020 22:03:36 +0000
Hi
We would like to use several tags as we conduct our review of documents in the "US V Epstein" database on Relativity.
For that database, would you please help us create the below tags?
Reviewed
Witness Statement
Produce As Is
Produce With Redactions
Produce As Confidential
Produce As Highly Confidential
Work Product (Do Not Produce)
Potential Brady
Hot Doc
For Further Review
Tech Issue
Please let me know if you have any questions or would like to discuss.
Thanks very much,
EFTA00023546


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=== Page 1 ===
From:
To:
Subject: RE: NPA
Date: Tue, 23 Feb 2021 20:13:50 +0000
Attachments: 2021-02-26_GM_Government_Opposition_(NPA)_(MC)_(AR)_(LP).docx
My comments layered on top in the attached. I think this is very strong and well written.
From:
Sent: Tuesday, February 23, 2021 2:05 PM
To:
is
is
Subject: RE: NPA
Hi all,
My comments attached. I think we're in great shape too - we have a lot of convincing reasons her motion should be
denied.
I'm around to discuss anytime.
Thanks,
From:
Sent: Tuesday, February 23, 2021 12:54 PM
To:
is
>;
Subject: RE: NPA
Thanks for the close read - can the three of us chat after
and
have also reviewed? Thanks.
From:
Sent: Tuesday, February 23, 2021 12:46 PM
To:
is
is
Subject: RE: NPA
Thanks very much,
I think this is in great shape and is very compelling. Some small edits and my responses to your
comments attached. Happy to jump on a call if that would be useful.
From:
Sent: Tuesday, February 23, 2021 2:02 AM
To:
is
is
Subject: NPA
All,
EFTA00025193

=== Page 2 ===
Attached is the most recent draft of the NPA brief. Apologies for the delay, I really struggled with this one. I think our
arguments in the first half are strong, but I'm really not wild about the second half. Would very much appreciate your
comments/edits. I've also flagged a few issues for consideration/discussion. If you're able to review tomorrow morning,
that would be great.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00025194


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein estate counsel call
Date: Wed, 23 Oct 2019 19:38:58 +0000
Importance: Normal
Attachments: unnamed
EFTA00025255


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=== Page 1 ===
From: "Miller, Michael"
To:
)"
"Martin G. Weinberg"
"Weingarten, Reid"
Cc:
)"
)"
Subject: RE: US V Epstein
Date: Sat, 10 Aug 2019 23:34:37 +0000
Thanks for being available today and for getting the wheels turning for an investigation into how he died.
On a related note, we are hearing that Jeffrey's autopsy may occur tomorrow morning. We would like to have a
pathologist present for his autopsy and cannot line up someone on such short notice. Is there any way to push
the autopsy off until Tuesday to give us time to do that?
Mike
From:
Sent: Saturday, August 10, 2019 7:31 PM
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: RE: US V Epstein
Mike, Marty, Reid,
I just wanted to let you know that I don't expect we'll have any further updates today, and so wanted to send you a brief
note to let you know that since we hadn't otherwise been in touch since earlier this afternoon. I imagine we will continue
to be in contact in the coming days; meanwhile, I appreciate you being in touch today, and I hope the investigations of
these events will be thorough and swift.
respectfully,
From:
Sent: Saturday, August 10, 2019 14:14
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: RE: US V Epstein
Following up on the below, wanted to make sure the attached letter from the Warden immediately got to Mike as well (in
addition to Marty and Reid having been copied and emailed). As the letter indicates, there are now investigations
ongoing, including as initiated by the Attorney General himself. Separately, we have not received additional information
on topics such as the apparent cause of death, the status of observation of Mr. Epstein at the time, etc., but we will
continue to be in touch immediately if that changes.
thank you,
EFTA00024363

=== Page 2 ===
From:
Sent: Saturday, August 10, 2019 11:57
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: Re: US V Epstein
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments
ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It represents
all the information we have from BOP so far, but of course if we are successful in our continuing efforts to get
additional information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are
accurate, and I fully expect that investigation to be extremely rigorous.
As always please don't hesitate to reach out to us directly at any time if that would be useful.
thank you,
EFTA00024364


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein
Date: Thu, 25 Jul 2019 13:14:11 +0000
Hi
He is in psychological observation. It is similar to suicide watch, but more like a step-down from it. It is also used a
temporary housing for inmates who have mental health issues that do not arise to the level of suicidality.
Thanks
>>>
7/25/2019 8:30 AM >>>
Hi
Can you tell me where Epstein is right now? Is he still on suicide watch?
Thanks,
EFTA00025523


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc:
, Christian Everdell
Subject: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Date: Wed, 27 Oct 2021 01:14:55 +0000
Good evening-
I am still awaiting a reply to yesterday's email regarding Ms. Maxwell's legal mail.
There are items that need to be picked up by the MDC.
I have provided the tracking information.
Please provide a response by 10:00 am tomorrow Wednesday.
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
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.
On Oct 25, 2021, at 8:33 PM, BOBBI C STERNHEIM
wrote:
Good evening -
During my in-person visit yesterday with Ms. Maxwell, the HEPA filters were not operating in the visiting
room that I have been required
to use, even when more than one attorney is present. The officers told me to use the larger, corner room.
Previous requests to use this more ample corner room have been denied because the officers' claim
the camera cannot be positioned. Yesterday, the officers simply and easily positioned the camera focused on the
corner room.
I am requesting that future in-person visits be conducted in the larger corner room.
The previous reason for denying that request appears invalid.
EFTA00025142

=== Page 2 ===
Also, legal mail sent to the MDC has not been picked up by the facility. See tracking information below.
Please promptly provide an explanation and inform me when Ms. Maxwell will receive these deliveries.
Thank you-
Bobbi
<Screen Shot 2021-10-25 at 7.10.13 PM.png>
<Screen Shot 2021-10-25 at 7.07.56 PM.png>
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
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.
EFTA00025143


