# docs_fts_content

c1: EFTA00017999
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017999.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: CBP Question
Date: Tue, 21 Sep 2021 02:54:59 +0000
Attachments:
TECS_Travel_Records.pdf
Hi
Could you please take a look at these and let us know if any of these dates line up with Maxwell or Epstein's travel?
Thanks!
From:
Sent: Monday, September 20, 2021 10:49 PM
To:
Cc:
Subject: [EXTERNAL] RE: CBP Question
Hey
Attached ate the travel records as requested. However, it's the same issue as last time since the outbound departures
were not recorded during that timeframe it only shows the inbound arrivals. Any questions or concerns don't hesitate to
reach out.
Respectfully,
U.S. Customs and Border Protection
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
WARNING:
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws
including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and
destroy all copies of the communication.
DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may
be disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to
unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be
released to the public or media.
From:
Sent: Monday, September 20, 2021 2:11 PM
EFTA00017999

=== Page 2 ===
To:
Cc:
Subject: RE: CBP Question
Thanks so much! Can you please pull the CBP records for
We would like the CBP records for the 1990s
only. Her date of birth is
She is French. Please let us know if you need any other information. Thanks again!
From:
Sent: Monday, September 20, 2021 1:50 PM
To:
Cc:
Subject: Re: CBP Question
Hey
Sure no problem, send over the info you need and I'll work on it today.
Sent from my iPhone
On Sep 20, 2021, at 1:42 PM,
wrote:
Hi
I hope you are doing well. We were hoping you could pull some additional CBP records for us. Are you able to assist us
with that this week?
Thanks so much,
From:
Sent: Thursday, July 29, 2021 5:31 PM
To:
Cc:
Subject: Re: CBP Question
Hey
Sorry I was on the road but I spoke with Jared he filled me in on what your looking for. I'm also available for a call to
further discuss.
Respectfully,
U.S. Customs and Border Protection
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
EFTA00018000

=== Page 3 ===
WARNING:
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable
laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the
sender and destroy all copies of the communication.
DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may be
disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to
unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be
released to the public or media.
From:
Sent: Thursday, July 29, 2021 3:56:15 PM
To:
Cc:
Subject: CBP Question
CAUTION: This email originated from outside of DHS. DO NOT click links or open attachments unless you recognize and/or trust the
sender. If you feel this is a suspicious-looking email, please report by using the Report Phish button option.
Hi
I hope you are well!
passed along your info to us. We were hoping to connect with you by phone about
a question in one of our cases. Do you have time to talk today or tomorrow morning?
Thanks so much!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
EFTA00018001


c1: EFTA00017948
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017948.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: DVR Update
Date: Mon, 09 Mar 2020 21:59:42 +0000
Special Agent
FBI New York Field Office
Violent Crimes Task Force
From:
Sent: Tuesday, September 17, 2019 12:43 PM
To:
Cc:
Subject: DVR Update
Just got an update from OTD, Digital Forensic Analysis Unit (DFAU),
DVR 1 has been up and running since the last update. DFAU received the password from the MCC Contractor
earlier this morning. They are reviewing the data now. (NFI)
DVR 2 (the cameras that covered the MCC SHU) is currently not running. The MCC Contractor has been
approved to enter the OTD Lab and start working with DFAU tomorrow to get DVR 2 running. More to follow.
Special Agent
FBI New York I C-19
Violent Crimes Task Force
EFTA00017948


c1: EFTA00019669
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019669.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
DEPARTMENT OF JUSTICE
FEDERAL
STATE
)
FBI New York Office
Criminal Division Branch C
Little Saint James Island (LSJ)
Squad C-20 I 31E-NY-3027571
USVI, USA
12 AUGUST 2019
UNCLASSIFIED//FOR OFFICIAL USE ONLY
EFTA00019669

=== Page 2 ===
Situation/Mission
(U//FOUO) On 12 AUGUST 2019, FBI NYO Criminal
Branch C will execute the search warrant for Little
Saint James Island (LSJ), USVI, USA. LSJ is currently
owned by JEFFREY EPSTEIN, subject of a Child Sex
Trafficking investigation.
UNCLASSIFIED//FOR OFFICIAL USE ONLY
EFTA00019670

=== Page 3 ===
2019
Sunrise/Sunset
Daylength
Astronomical Twilight
Nautical Twilight
Aug
Sunrise
Sunset
Length
Difference
Start
End
Start
End
1
5:57 am (71°)
6:54 pm (289)
12:56:41
-0:45
4:38 am
8:12 pm
5:06 am
7:44 pm
2
5:57 am (71°)
6:53 pm (289")
12:55:55
-0:46
4:39 am
8:12 pm
5:07 am
7:44 pm
3
5:58 am (71°)
6:53 pm (289°)
12:55:08
-0:46
4:39 am
8:11 pm
5:07 am
7:43 pm
4
5:58 am (71°)
6:52 pm (288*)
12:54:21
-0:47
4:40 am
8:10 pm
5:08 am
Predicted
7:43 pm
5
5:58 am - (72°)
6:52 pm (288°)
12:53:33
-0:48
4:40 am
8:10 pm
5:08 am
7:42 pm
Weather/Nautical
6
5:59 am (72°)
6:51 pm (288°)
12:52:44
-0:48
4:41 am
8:09 pm
5:08 am
7:41 pm
Report for Saint
7
5:59 am (72°)
6:51 pm (287°)
12:51:55
-0:49
4:41 am
8:08 pm
5:09 am
7:41 pm
8
5:59 am (73°)
6:50 pm (287°)
12:51:05
-0:49
4:42 am
8:07 pm
5:09 am
7:40 pm
Thomas, USVI
9
5:59 am (73*)
6:50 pm (287°)
12:50:14
-0:50
4:42 am
8:07 pm
5:10 am
7:39 pm
10
6:00 am (73°)
6:49 pm (287°)
12:49:23
-0:51
4:43 am
8:06 pm
5:10 am
7:39 pm
11
6:00 am (74°)
6:48 pm (286°)
12:48:31
-0:51
4:43 am
8:05 pm
5:10 am
7:38 pm
12
6:00 am (74°)
6:48 pm (286°)
12:47:39
-0:52
4:43 am
8:05 pm
5:11 am
7:37 pm
13
6:00 am / (74°)
6:47 pm (286°)
12:46:47
-0:52
4:44 am
8:04 pm
5:11 am
7:37 pm
14
6:01 am (75*)
6:47 pm (285°)
12:45:53
-0:53
4:44 am
8:03 pm
5:11 am
7:36 pm
15
6:01 am (75°)
6:46 pm (285°)
12:45:00
-0:53
4:45 am
8:02 pm
5:12 am
7:35 pm
Conditions
Comfort
Precipitation
Sun
Day
Temperature
Weather
Feels Like
Wind
Humidity
Chance
Amount
UV
Sunrise
Sunset
Fri
87 / 80 °F
Aug 9
Showers early. Morning clouds.
96 °F
13 mph
71%
49%
0.05"
7 (High)
5:59 am
6:50 pm
Sat
86 / 80 °F
Sunny.
93 °F
14 mph
-
68%
6%
-
Aug 10
10 (Very high)
6:00 am
6:49 pm
Sun
86 / 79 °F
More sun than clouds.
92 °F
14 mph
-
66%
6%
-
10 (Very high)
6:00 am
Aug 11
6:48 pm
Mon
86 / 79 °F
More sun than clouds.
94 °F
13 mph
-
70%
5%
-
10 (Very high)
6:00 am
Aug 12
6:48 pm
Tue
85 / 79 °F
Partly cloudy.
93 °F
14 mph
-
68%
7%
-
10 (Very high)
6:00 am
Aug 13
6:47 pm
Wed
87 / 79 °F
Showers early. More sun than clouds.
94 °F
13 mph
-
69%
39%
0.01"
10 (Very high)
6:01 am
Aug 14
6:47 pm
Thu
87 / 84 °F
Showers early. Mostly sunny.
98 °F
17 mph
-
79%
46%
0.02"
Aug 15
10 (Very high)
6:01 am
6:46 pm
EFTA00019671

=== Page 4 ===
Target: Little St. James Island, USVI, USA
10
St. John
386
St.John
104
Cruz Bay
PASTORY
Red Hook
ENIGHED
BELLEVUE
-
BETHANY
THINK
STATE
32
CONTANT
RYDENHOJ
Nazareth
Great Bay
RENDEZVOUS
Great Cruz
DITLEF
Bay
ovoni
Great
Cay
Cowpet Bay
Rendezvous
Great St
James
Island
Cas
tricia
Cay
Cay
Little St
St. Thomas
Island
Dog
Island
Little St. James
be ©CNES (2019) Distribution Airbus DS © 2019 HERE
Caribbean
EFTA00019672

=== Page 5 ===
MGRS: 20QLF0703824343
UNCLASSIFIED//FOR OFFICIAL USE ONLY
N
Lat/Long: 18.300006, -64.825621
Address: Little St. James Island, USVI, USA
ABCDEFCHIJKLMNOPO
1
1
2
2
3
3
4
4
5
5
6
6
7
7
8
8
9
9
10
10
11
11
12
12
13
13
14
14
15
15
ABCDEFCHIJKLMNOPQ
EFTA00019673

=== Page 6 ===
Target: Little St. James Island, USVI, USA
ALPHA
St James Cut
(ZONE 1)
BRAVO
(ZONE 2)
DELTA
(ZONE 4)
CHARLIE
(ZONE 3)
N
EFTA00019674

=== Page 7 ===
Target: Little St. James Island, USVI, USA
Structure Descriptions:
Al & A2: Single Story structures
I
No doors | Couches and other
Furniture seen via video
A3: Main Residence - single story
with stone exterior, blue
roof/white detailing
A4: Potential 2-Story structure
sub-level of Structures A1 -A3
A1
ALPHA
A3
+
ITI
N
Goog
EFTA00019675

=== Page 8 ===
Target: Little St. James Island, USVI, USA
Structure Descriptions:
B1 & B2: Single Story Sheds
B3: Dock/Small Wooden Structure
B4: 4-wall structures with several
sally port type doors
Red Squares: Helipad Structures
B5: Unknown
BRAVO
H
N
Google
EFTA00019676

=== Page 9 ===
Target: Little St. James Island, USVI, USA
CHARLIE
Structure Descriptions:
C1 & C2: Potential two-
N
story structure

=== Page 10 ===
Target: Little St. James Island, USVI, USA
DELTA
D1
Structure Descriptions:
D1: Single Story Structure - 3
Dark double doors
N
D2: Potential 2-Story Structure
Google
th
EFTA00019678

=== Page 11 ===
Target: Little St. James Island, USVI, USA
N
DELTA
(cont'd)
Structure Descriptions:
D3: Dome not seen on video
footage
I
Potential Single Story
Structure
Yellow Square: Potential Hidden
Structure
EFTA00019679

=== Page 12 ===
USNG/MGRS MAP
05
06
07
08
09
10
26
26
25
25
24
24
23
23
05
06
07
08
09
10
Mercator Projection
1
2
3
4km
N
WGS84
MN
USNG Zone 20QLF
0.5
1.0
1.5
2.0mi
-14°
CalTopo
Scale 1:25000 1 inch = 2083 feet
EFTA00019680

=== Page 13 ===
247
246
245
244
243
242
241
24
N
EFTA00019681
077
077
MN
-14°
076
076
075
075
1. 1.0km
0. 0.6mi
074
074
0.9
073
073
0.8
0.5
072
072
0.7
0.4
USNG/MGRS MAP
071
071
0.6
1 inch = 468 feet
07
07
0.5
0.3
690
690
0.4
Scale 1:5615
0.2
890
068
0.3
067
067
0.2
0.1
066
990
0.1
065
065
064
064
Mercator Projection
248
247
246
245
244
243
242
241
WGS84
USNG Zone 20QLF
24
CalTopo


c1: EFTA00020112
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020112.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: Paris Prosecutor Opens Investigation in Jeffrey Epstein Scandal - The New York Times
Date: Fri, 23 Aug 2019 22:41:27 +0000
"Exchanges" could be worse I suppose
> On Aug 23, 2019, at 6:35 PM,
>
V
>>
https://www.nytimes.com/2019/08/23/world/europe/paris-epstein-investigation.html
>>
>>
Sent from my iPhone
EFTA00020112


c1: EFTA00017817
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017817.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: BOBBI C STERNHEIM
Subject: RE: Ghislaine Maxwell- URGENT
Date: Fri, 20 Nov 2020 18:45:37 +0000
Bobbi,
I just tried you but got your voicemail. I am available on my cell at
I'll be available until 2pm and then
again after 3:30pm.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
From: BOBBI C STERNHEIM
Sent: Friday, November 20, 2020 1:40 PM
To
Subject: Ghislaine Maxwell- URGENT
Please call me
Much appreciated-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
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.
EFTA00017817

=== Page 2 ===
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.
EFTA00017818


c1: EFTA00019882
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019882.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
)"
Subject: Re:
Date: Mon, 23 Dec 2019 17:15:05 +0000
Yes, I believe we have all of the transcripts from all of the depositions in the Roberts V. Maxwell civil suit. They
are on the Epstein share drive. I don't have my laptop with me, so I can't send them via email. Do you have
access to the share? If so, I can tell you where to look for them there.
On Dec 23, 2019, at 2:02 PM,
(USANYS) [Contractor]
wrote:
Separate from
- do you all have the full transcripts of the depositions? At various points
and
have
asked me to find transcripts and I've only found excerpts from summary judgement exhibits unsealed by the 2nd circuit.
From:
Sent: Monday, December 23, 2019 11:59 AM
To:
(USANYS)
Cc:
is
)
(USANYS)
is
(USANYS) [Contractor]
Subject: Re:
She was deposed, but she invoked 5 throughout. We have the transcript, but it's just her asserting the privilege over
and over.
On Dec 23, 2019, at 1:57 PM,
(USANYS)
wrote:
Hey Guys - Not sure if any of you are around this week, but if so, quick question from
-- do you know if
was deposed as part of the Roberts-Maxwell litigation and, if so, do we have a transcript?
Thanks,
EFTA00019882


c1: EFTA00018600
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018600.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Text messages 4
Date: Sat, 21 Dec 2019 14:34:09 +0000
Inline-Images: IMG_2431.jpg; IMG_2432.jpg; IMG_2433.jpg; IMG_2434.jpg
EFTA00018600

=== Page 2 ===
8:51
No SMS connection
out and see if you are ok.
Second do you have any
questions for us. Thanks.
Monday, Aug 19 6:28 PM
Hey
thank you for
reaching out. It's been very
hectic with back to school,
SO I'm very sorry that it is
taking me SO long to get
back to you. I'm doing
okay, as I've heard many
of the other victims do, I
feel robbed. But this is the
second time around so it
is what it is. I can't say I'm
A
surprised at all.
Aug 19, 6:28 PM
Text
+
message
SMS

=== Page 3 ===
EFTA00018602

=== Page 4 ===
8:51
...
No SMS connection
Wednesday, Jul 10 3:53 PM
Conversation with
Hi
W r on for
Saturday at noon. I will
forward u the contact
number. Thanks
Jul 10, 3:54 PM SMS
Ok
Friday, Jul 12 1:49 PM
The number is
Text
+
Sat
message
SMS

=== Page 5 ===
EFTA00018604

=== Page 6 ===
8:51
...
No SMS connection
Saturday, Jul 13 . 12:07 PM
Hi
ru able to
make today's call
Im sorry I was not clear as
im on mountain time. It's
only 10:44 here
It's ok. I realized that when
u mentioned u were a few
hrs away. What's another
day that u can make it?
I can still do today when
the baby goes to sleep at 2
your time
Other
Text
message
SMS

=== Page 7 ===
EFTA00018606

=== Page 8 ===
8:52
...
No SMS connection
Otherwise tomorrow at 2
Ok let me see if they r
available tomorrow.
Let me check if they r
available today at 2 which
is 12 for u
Yes, today would be best
for me. If not 2, I can do a
lit later
Yes W can do it at 12 your
time
Today
Text
+
message
SMS

=== Page 9 ===
Sent from my iPhone
EFTA00018608


c1: EFTA00018261
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018261.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: RE: Discovery Issues
Date: Thu, 29 Oct 2020 19:54:43 +0000
Embedded: RE:_Discovery_Issues.msg
Sender:
Subject: RE: Discovery Issues
Message-Id:
M>
To:
To:
Cc:
Cc:
Cc:
EFTA00018261


c1: EFTA00018758
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018758.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Joe Nascimento
Cc:
(USANYS)"
Subject: RE: [EXTERNAL] Re:
)
- Epstein
Date: Thu, 30 Sep 2021 13:46:17 +0000
No worries at all, thanks for the heads up. No rush at all, we'll push back the start time, and whenever you can make it is
fine.
From: Joe Nascimento
Sent: Thursday, September 30, 2021 9:44 AM
To:
Cc:
(USANYS)
Subject: Re: [EXTERNAL] Re:
- Epstein
Good morning,
My virtual hearing is taking longer than I expected, so we may be a few minutes behind. Apologies!
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 28, 2021, at 9:56 PM,
)
wrote:
Joe,
10:15 is more than fine, no worries at all. If you prefer to start a little later just let me know.
Thanks!
On Sep 28, 2021, at 9:28 PM, Joe Nascimento
wrote:
Hi
,
Can we push our start to 10:15? I have a 9am Zoom hearing and want to give myself enough time to walk
over to your office. Otherwise, we are free all day.
EFTA00018758

=== Page 2 ===
We can start as early as you want on Friday (earlier than 9am is Ok).
I'll make sure
and I fill out the form and bring it with us.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 28, 2021, at 8:41 PM,
wrote:
Hi Joe,
Hope you're doing well. I wanted to check in on scheduling for our meetings on Thursday and Friday. Let's still plan to
meet at 10 a.m. on Thursday, if that works for you. On Friday, could we possibly move our meeting up to 9 a.m.?
With respect to pandemic protocols, our mask requirement remains in place. However, the process for entry is
different. I'm attaching the self-screening form the department uses. No need to send me anything-the folks at
security will review it with you and your client when you arrive, but that's it.
Thanks,
From: Joe Nascimento
Sent: Thursday, September 9, 2021 9:03 PM
To:
Cc:
(USANYS)
Subject: Re:
)
- Epstein
Sounds good to me. Thanks!
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
EFTA00018759

=== Page 3 ===
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 8, 2021, at 12:01 PM,
)
wrote:
We're flexible on timing. I would suggest that we meet at 10 a.m. on the first day, and depending on timing and
other factors we can consider having a second meeting that afternoon after a break. We can meet at 9:30 the
second morning to make sure everyone has time to catch an afternoon flight back, if that works.
From: Joe Nascimento
Sent: Wednesday, September 8, 2021 11:15 AM
To:
Cc:
(USANYS)
Subject: Re:
- Epstein
Great, when you can, let me know what times you'd like to meet.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 8, 2021, at 10:43 AM,
)
wrote:
Joe,
Those dates work for us, thanks. l'll reach out to our witness coordinator, who will likely be in touch with
later this week to make travel arrangements.
EFTA00018760

=== Page 4 ===
Thanks very much,
From: Joe Nascimento
Sent: Friday, September 3, 2021 9:41 PM
To:
Subject: Re:
)
- Epstein
No worries, enjoy your weekend! Hopefully you weren't impacted by the floods/storm.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 3, 2021, at 9:30 PM,
)
wrote:
Hi Joe,
Thanks very much, and apologies for the slow reply. I think those dates work, but I'm working on
confirming and should be able to let you know by early next week.
Thanks, and have a great holiday weekend-
On Sep 1, 2021, at 10:06 PM, Joe Nascimento
wrote:
Hi
EFTA00018761

=== Page 5 ===
Hope your travel this week goes well. I spoke with
and it looks like we are both available 9/30 - 10/1.
Let me know if that works on your end. If not, we can look at dates in October.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
<image001.png>
From: Joe Nascimento
Date: Friday, August 27, 2021 at 10:49 AM
To:
)
Subject: Re:
)
- Epstein
I'm free most of the day, feel free to call my cell at your convenience
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 27, 2021, at 10:47 AM,
)
wrote:
Hi Joe,
I am going to be traveling for work next week, so my schedule is a little up in the air, but I'm free today if you
have time to talk. If not, I can touch base next week when my schedule settles a bit. Thanks!
EFTA00018762

=== Page 6 ===
From: Joe Nascimento
Sent: Friday, August 27, 2021 10:44 AM
To:
Subject: Re:
)
- Epstein
Good morning
,
I am hoping you have 5 min for a call in the next few days. Nothing urgent. Please let me know
what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 9, 2019, at 9:47 PM,
)
wrote:
Joe,
We will meet tomorrow at the same place as last time- the Hilton in West Palm Beach, on
Okeechobee Blvd. My cell is
when you arrive. My colleague,
will
be joining us, and he can be reached at
Thanks,
Sent from my iPhone
EFTA00018763

=== Page 7 ===
On Sep 4, 2019, at 10:46 PM, Joe Nascimento
wrote:
Yes, we will be there.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi Joe,
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
Cc:
is
Subject: Re:
-
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th
or 13th work best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
EFTA00018764

=== Page 8 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this
afternoon. I'll plan to reach out then to discuss scheduling, if that's okay.
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check in to see if you still planned to travel south given the storm. Current
estimates show a landing (somewhere) Tuesday with very bad weather on Wednesday.
Airports might close (which will answer my question), but that's a guess.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00018765

=== Page 9 ===
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a
hotel in West Palm Beach, and I'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
Both the time and date work for us. Let me know the location when you have it confirmed.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
Following up on scheduling, we were wondering if your client is available for a proffer on
September 4th. We're flexible on timing that day, but we would propose meeting at 12:30 p.m.,
if that works.
EFTA00018766

=== Page 10 ===
Thanks,
From: Joe Nascimento
Sent: Wednesday, August 7, 2019 4:53 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early
afternoon (anytime after 1)? I have proactive cooperation ongoing in another case involving
multiple jurisdictions, and they are looking to meet the morning of 8/14. I understand if your
schedule is already set, and will work around it.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
,
)"
Subject: RE:
)
- Epstein
Joe,
Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a meeting, and
we'll follow up to firm up plans as we get closer. If there are any conflicts with that date, please
let us know, we're happy to be flexible.
EFTA00018767

=== Page 11 ===
Thanks,
From: Joe Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
I do not have any travel plans during the month of August, nor does
September is a
busy month with two trials set, and I will be traveling out of the country from Sept 17-30, but I
will do everything to be as flexible as possible.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
,
)"
Subject: RE:
)
- Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if you
could please let us know if there are any particular weeks that would not work for you or your
client for a meeting in Florida (in particular, we don't want to interfere with anyone's summer
vacation plans).
EFTA00018768

=== Page 12 ===
We will of course be in touch to talk about a next meeting in more detail, but in the first instance
it would be helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
That works for me. Please call me on my cell
(
). Thanks.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
Following up, we were wondering if you were available for a call to discuss next steps. We're
available on Friday at 2:30, if that works, but let us know if there are other times that would be
more convenient for you.
Thanks,
EFTA00018769

=== Page 13 ===
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Good afternoon,
It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
As always, feel free to contact me at any time if we can be of further assistance. Look forward
to meeting again.
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
"
)"
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you
are here, and we will meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
EFTA00018770

=== Page 14 ===
Subject: Re:
)
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still coordinating
logistics, and we will let you know that morning the address where we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for
any reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
EFTA00018771

=== Page 15 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-
data-detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-
detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
)
<mailto:
wrote:
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer
letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors:/2/0>rd<x-apple-
data-detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-
detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
On Jul 9, 2019, at 4:56 PM,
)
EFTA00018772

=== Page 16 ===
<mailto:
<mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for
sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors:/2/0> Avenue<x-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
<mailto:
<mailto:
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza
|
4th Floor
2250 S.W. 3rd Avenue
EFTA00018773

=== Page 17 ===
Miami, FL 33129
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com>
From:
"
)"
<mailto:
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
Cc:
)"
<mailto:
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m.
on Tuesday - you can reach us at
, or we can also call you then if that's
easier, whatever you prefer.
thanks,
From: Joe Nascimento
mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you.
Let's set a time for Tuesday morning (the earlier the better for me). Let me know what
works for you.
Thanks,
EFTA00018774

=== Page 18 ===
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors:/2/0> Avenue<x-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
On Jul 7, 2019, at 4:04 PM,
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with
you. I expect our schedules may be somewhat unpredictable tomorrow; would it work
to set a time to talk on Tuesday? We can schedule it for before you meet with
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later
today, or check in tomorrow about a possible afternoon discussion. Please let us know
what you prefer, and we look forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
EFTA00018775

=== Page 19 ===
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
Subject:
) - Epstein
My former partner, Alan Ross, represented
prior to his passing in 2018. Agent
served
with a grand jury
subpoena earlier today, and as Alan's former partner and FL Bar appointed inventory
attorney, she has contacted me. Unfortunately, I am unable to meet with her until
Tuesday, but I would appreciate a few minutes of your time at your convenience as I
am getting up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-
apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
<DOJ Visitor Health Self-Screening Sept 14.pdf>
EFTA00018776


c1: EFTA00019579
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019579.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: In re Application to Unseal Civil Discovery Materials SDNY 19-mc-00179
Date: Tue, 16 Apr 2019 18:25:05 +0000
Attachments: 19-MC-00179_Sealed_Order_4.15.19_Stamped.pdf
Mr.
Please see the attached PDF for an Order that was filed under seal today in 19-mc-179.
Thank you,
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
EFTA00019579


c1: EFTA00018919
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018919.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein Team Meeting
Start Date: 2019-12-09 20:30:00 +0000
End Date: 2019-12-09 21:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-12-08 19:19:03 +0000
Date Modified: 2019-12-08 19:19:03 +0000
Priority: 5
DTSTAMP: 2019-12-08 19:10:23 +0000
Attendee:
EFTA00018919


c1: EFTA00018724
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018724.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
MINISTÈRE
DE LA JUSTICE
Direction des affaires criminelles et des grâces
Liberté
Égalité
Fraternité
Sous-direction de la justice pénale spécialisée
Bureau de l'entraide pénale internationale
Paris, le 9 mars 2021
Monsieur le garde des Sceaux, ministre de la Justice
à
Department of Justice (D.O.J)
Par l'intermédiaire d'Andrew FINKELMAN, magistrat de liaison
Ambassade des Etats-Unis d'Amérique à Paris
J'ai l'honneur de porter à votre connaissance que la procédure et les conditions
d'extradition sont régies en France par les articles 696 et suivants du code de procédure pénale.
L'article 696-2 de ce code prévoit ainsi que « le gouvernement français peut remettre, sur leur
demande, aux gouvernements étrangers, toute personne n'ayant pas la nationalité française qui, étant l'objet d'une
poursuite intentée au nom de l'Etat requérant ou d'une condamnation prononcée par ses tribunaux, est trouvée sur
le territoire de la République. »
L'article 694-4 précise expressément que
« L'extradition n'est pas accordée
1° Lorsque la personne réclamée a la nationalité française, cette dernière étant appréciée à
l'époque de l'infraction pour laquelle l'extradition est requise ».
Ainsi, le fait que la personne recherchée ait la nationalité française constitue un obstacle
insurmontable à son extradition. Dès lors que cette nationalité s'apprécie au moment de la
commission de l'infraction, la perte de la nationalité, postérieurement à la commission de cette
dernière, est sans incidence sur la procédure d'extradition, et ne permet pas de lever cet obstacle.
Le Chef du Bureau de l'Entraide Pénale Internationale
Philippe IAEGLÉ
Téléphone
www.justice.gouv.fr
EFTA00018724

=== Page 2 ===
MINISTRY OF JUSTICE
Directorate of Criminal Affairs & Pardons
Liberty
Equality
Fraternity
Specialized Criminal Justice Sub-Directorate
International Criminal Assistance Bureau
Paris, March 9, 2021
His Honor the Keeper of Seals, Minister of Justice
To the
Department of Justice (D.O.J)
Through Andrew FINKELMAN, Liaison Magistrate on behalf of the
Embassy of the United States of America located in Paris, France
I hereby inform you that in France, all removal proceedings and conditions are
governed by Articles 696 et sq. of the Code of Criminal Procedure.
Article 696-2 of said Code provides that: "The French government is able to remit to
foreign governments upon their request any individual who is not a French citizen and who is subject to a
lawsuit brought on behalf of the requesting State, or who is subject to a sentence passed by the Court of said
requesting State, and who is located on the territory of the French Republic."
Article 694-4 expressly specifies as follows:
"Removal is not granted:
1- When the individual claimed to have French citizenship, said citizenship having been
assessed at the time of the offense on the basis of which removal is being
requested."
WHEREBY, the fact that the wanted individual is a French national constitutes an
insuperable obstacle to his/her removal. As long as said nationality is assessed at the time the
offense was committed, any loss of nationality subsequent to said offense has no bearing upon
the removal proceedings and shall not supersede said assessment of nationality.
Head of the International Criminal Assistance Bureau
Philippe
Telephone:
www.justice.gouvm
EFTA00018725


c1: EFTA00018841
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018841.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: [EXTERNAL] FW: Court Subpoena
Date: Tue, 05 Oct 2021 18:14:36 +0000
Attachments: 2021.08.27_Court_Subpoena_-_Sacramento_County_Clerk.pdf
Inline-Images: image004.png; image002.png
Good afternoon
Our Counsel had a further question regarding the subpoena. In the subpoena, it states the Sacramento County
Clerk/Recorder is to appear in person to testify, and produce the requested record, at the U.S. District Court for
the Southern District of New York. Is this a requirement, or will presentation of the record to your office
suffice?
Your assistance in this matter is greatly appreciated.
Thanks,
Andrew B. Graham
Deputy Clerk/Recorder
Sacramento County Clerk/Recorder
SACRAMENTO
COUNTY
From:
Sent: Monday, October 4, 2021 3:31 PM
To:
Cc:
is
Subject: RE: Court Subpoena
I just spoke with our Counsel regarding the subpoena. She agrees that, since this is in regards to a federal
criminal case, the record should be issued at no fee. We will need an vital record application completed. The
application can be completed in our office by one of your representatives. As an alternative, please complete
the attached application form and email back to me. After receiving the completed application, we can process
the request and mail it immediately to the address of your choosing. The application will need to be signed, but
there is not a requirement that the application be notarized.
If you have any questions, please feel free to contact me.
Thanks,
EFTA00018841

=== Page 2 ===
Andrew B. Graham
Deputy Clerk/Recorder
Sacramento County Clerk/Recorder
SACRAMENTO
COUNTY
From: Graham. Andrew
Sent: Monday, October 4, 2021 12:25 PM
To:
Cc:
Subject: FW: Court Subpoena
You can reach me between 8-5 (Pacific Time), Monday thru Friday.
Thanks,
Andrew B. Graham
Deputy Clerk/Recorder
Sacramento County Clerk/Recorder
SACRAMENTO
COUNTY
From:
Sent: Monday, October 4, 2021 11:43 AM
To: Hermison. Jon
>; Colston. Noriko
Cc:
;
Subject: Court Subpoena
EXTERNAL EMAIL: If unknown sender, do not click links/attachments.
Good afternoon,
I'm reaching out regarding the attached subpoena, which was served on your office in connection with an upcoming
criminal trial in the United States District Court for the Southern District of New York. I understand there have been some
questions regarding compliance. Could you please let me know your availability for a call?
Thank you,
tes Attorney
EFTA00018842

=== Page 3 ===
Southern District of New York
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein
Date: Thu, 25 Jul 2019 15:55:28 +0000
Sure
From:
(USANYS)
Sent: Thursday, July 25, 2019 11:55 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein
Now?
From:
(USANYS)
Sent: Thursday, July 25, 2019 11:53 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: Epstein
I would like to discuss when you have a moment:
https://abcnews.go.com/US/millionaire-convicted-sex-offender-jeffrey-epstein-put-suicide/story?
id=64562129&cid=social_twitter_abcn
Millionaire and convicted sex offender Jeffrey Epstein, facing charges of federal sex trafficking, was placed on
suicide watch after being found unresponsive and with injuries to his neck at a federal lockup in New York City,
according to a law enforcement official briefed on the incident
https://www.nytimes.com/2019/07/25/nyregion/jeffrey-epstein-injured-jail.html?
action=click&module=Top%20Stories&pgtype=Homepage
A week after being denied bail, Jeffrey E. Epstein was found unconscious in his cell on Tuesday at a
federal jail in Manhattan with marks on his neck, and prison officials were treating the incident as a
possible suicide attempt, a law enforcement official who had been briefed on the matter said.
Mr. Epstein's injuries were not serious, said the official, who requested his
name not be published because he was not authorized to speak on the matter.
And of course there is the WNBC report
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=== Page 1 ===
Experian Information Solutions, Inc.
701 Experian Parkway
Allen, Tx 75013
Attn: Subpoena Compliance Dept.
Please provide any and all credit reports, fraud alerts, and related documents pertaining to the following
individuals listed, including all known accounts and lines of credit, addresses and personal identifying
information, and all credit inquiries regarding the individuals and the addresses provide at the time of
said inquiry regardless of whether accounts were open.
Please utilize the identifiers below:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
If you have any questions, please contact Forensic Accountant
at
or Special
Agent
at
Please forward the results in an electronic format to Special
Agent
Federal Bureau of Investigation, 26 Federal Plaza, New York, NY 10278, telephone
(
).
The Government hereby requests that you voluntarily refrain from disclosing the existence of the
subpoena to any third party. While you are under no obligation to comply with our request, we are
requesting you not to make any disclosure in order to preserve the confidentiality of the investigation
and because disclosure of the existence of this investigation might interfere with and impede the
investigation. If you intend to disclose the existence of this subpoena to a third party, please let a Special
Agent know before making any such disclosure.
EFTA00020169


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
,
)"
Subject: Notes from 11/24/30 call with Dave Kelley
Date: Tue, 24 Nov 2020 23:34:45 +0000
DK is one of the Dechert attorneys conducting the Apollo internal investigation regarding Leon Black's
relationship with Epstein. Mandate is to understand what the relationship was between the two men and why
Black was paying Epstein money. Looks to be Epstein was being paid for some reason other than the services he
was providing.
DK reaching out to ask SDNY if there is anything available publicly that would shed any light on either Black's
relationship with Epstein and/or Epstein's source of expertise to charge money. DK made clear he is not asking for
SDNY to provide anything that is not public or would not be ordinarily accessible by third parties.
indicated would check with team and get back to DK.
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Passport
Date: Fri, 12 Jul 2019 02:44:38 +0000
Importance: Normal
I can certainly send you the court order on the bail determination once it's issued. If you haven't gotten it from me by
later next week, could you please just remind me? I don't want it to get lost in the avalanche of current stuff.
Also just to note, we obviously have no position (or request, directive, hint, nod, or wink) whatsoever regarding his
passport-we don't know what that process is so we completely defer on the substance. But of course happy to get you
the order, and let us know if anything else would be helpful.
thank you,
From:
Sent: Thursday, July 11, 2019 10:43
To:
Cc:
Subject: Re: Epstein Passport
The State Department has gotten several inquires regarding Epstein's passport. He currently has one valid
passport and Consular Affairs (CA) would like to revoke it.
I understand he will have a bail hearing on Monday. Would you be able to send me the court order (even if he is
remanded) so CA can revoke to the book? I assume if he is released on bail there will be a travel restriction
imposed/surrender of his passport.
Thanks.
ASAC
EFTA00018178

=== Page 2 ===
U.S. Department of State
Diplomatic Security Service
New York Field Office
From:
Sent: Wednesday, July 10, 2019 10:14 PM
To:
Cc:
Subject: RE: Epstein Passport
Happy to be in touch - let us know what info we can provide or how we can be of help.
thanks,
From:
Sent: Wednesday, July 10, 2019 22:12
To:
Cc:
Subject: Epstein Passport
Cc'ed to this email is the prosecution team for the Epstein case.
Team,
Please meet
an ASAC at the DSS NY Field Office (and my former boss).
State Department's Consular Affairs Bureau is looking for some information regarding Epstein's passport, as they
considering revoking it. Can you guys please coordinate with
regarding this issue.
Thanks!
Special Agent
U.S. Attorney's Office
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Jane Doe 43 V. Epstein, et al., 17 Civ. 616 (JGK)(SN)
Date: Tue, 09 Apr 2019 23:06:59 +0000
Importance: Normal
Attachments: 2019-04-
09,_JE,_letter_providing_additional_authority,_17_Civ_0616_(SN)_(with_exhibit).pdf
To the Chambers of Judge Netburn:
In connection with the Government's application relating to the above-captioned case, please see the attached letter,
with enclosure, relating to a recent pertinent decision.
Respectfully,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Thursday, March 14, 2019 14:56
To:
Subject: RE: Jane Doe 43 V. Epstein, et al., 17 Civ. 616 (JGK)(SN)
Rachel,
Yes of course - please see the attached, and please let me know if any additional information would be useful.
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Thursday, March 14, 2019 14:29
To:
Subject: Jane Doe 43 V. Epstein, et al., 17 Civ. 616 (JGK)(SN)
Mr.
Judge Netburn was wondering if you have a Word version of the Sealed Order that you can email?
Let me know when you get the chance.
Thank you,
EFTA00019577

=== Page 2 ===
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: FW: SDNY News Clips Wednesday, July 31, 2019
Date: Wed, 31 Jul 2019 21:13:52 +0000
Attachments: 2019_7-31.pdf
It looks like NDGa just filed something in the CVRA litigation - do you have a copy by any chance?
From:
Sent: Wednesday, July 31, 2019 5:12 PM
Cc:
Smolar,
Subject: SDNY News Clips Wednesday, July 31, 2019
SDNY News Clips
Wednesday, July 31, 2019
Contents
Public Corruption. 2
Epstein. 2
Collins. 18
Securities and Commodities Fraud. 20
Stewart 20
Thompson. 22
Pinto-Thomaz. 24
Narcotics. 26
Castro. 26
Rochester Drug Company. 28
Civil 30
Life Spine. 30
Matters of Interest 32
The U.S. said a California cherry-picker went to Pakistan for terrorist training. Now the case has collapsed. 32
Fed Cuts Interest Rates for First Time Since 2008 Crisis. 35
Public Corruption
Epstein
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=== Page 2 ===
Jeffrey Epstein Hoped to Seed Human Race With His DNA
New York Times
By James B. Stewart, Matthew Goldstein and Jessica Silver-Greenberg
7/31/19
Jeffrey E. Epstein, the wealthy financier who is accused of sex trafficking, had an unusual dream: He hoped to
seed the human race with his DNA by impregnating women at his vast New Mexico ranch.
Mr. Epstein over the years confided to scientists and others about his scheme, according to four people familiar
with his thinking, although there is no evidence that it ever came to fruition.
Mr. Epstein's vision reflected his longstanding fascination with what has become known as transhumanism: the
science of improving the human population through technologies like genetic engineering and artificial
intelligence. Critics have likened transhumanism to a modern-day version of eugenics, the discredited field of
improving the human race through controlled breeding.
Mr. Epstein, who was charged in July with the sexual trafficking of girls as young as 14, was a serial illusionist:
He lied about the identities of his clients, his wealth, his financial prowess, his personal achievements. But he
managed to use connections and charisma to cultivate valuable relationships with business and political leaders.
Interviews with more than a dozen of his acquaintances, as well as public documents, show that he used the same
tactics to insinuate himself into an elite scientific community, thus allowing him to pursue his interests in
eugenics and other fringe fields like cryonics.
Lawyers for Mr. Epstein, who has pleaded not guilty to the sex-trafficking charges, did not respond to requests
for comment.
Mr. Epstein attracted a glittering array of prominent scientists. They included the Nobel Prize-winning physicist
Murray Gell-Mann, who discovered the quark; the theoretical physicist and best-selling author Stephen
Hawking; the paleontologist and evolutionary biologist Stephen Jay Gould; Oliver Sacks, the neurologist and
best-selling author; George M. Church, a molecular engineer who has worked to identify genes that could be
altered to create superior humans; and the M.I.T. theoretical physicist Frank Wilczek, a Nobel laureate.
The lure for some of the scientists was Mr. Epstein's money. He dangled financing for their pet projects. Some of
the scientists said that the prospect of financing blinded them to the seriousness of his sexual transgressions, and
even led them to give credence to some of Mr. Epstein's half-baked scientific musings.
Scientists gathered at dinner parties at Mr. Epstein's Manhattan mansion, where Dom Pérignon and expensive
wines flowed freely, even though Mr. Epstein did not drink. He hosted buffet lunches at Harvard's Program for
Evolutionary Dynamics, which he had helped start with a $6.5 million donation.
Others flew to conferences sponsored by Mr. Epstein in the United States Virgin Islands and were feted on his
private island there. Once, the scientists - including Mr. Hawking - crowded on board a submarine that Mr.
Epstein had chartered.
The Harvard cognitive psychologist Steven Pinker said he was invited by colleagues - including Martin
Nowak, a Harvard professor of mathematics and biology, and the theoretical physicist Lawrence Krauss - to
"salons and coffee klatsches" at which Mr. Epstein would hold court.
While some of Mr. Pinker's peers hailed Mr. Epstein as brilliant, Mr. Pinker described him as an "intellectual
impostor."
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=== Page 3 ===
"He would abruptly change the subject, A.D.D.-style, dismiss an observation with an adolescent wisecrack," Mr.
Pinker said.
Another scientist cultivated by Mr. Epstein, Jaron Lanier, a prolific author who is a founding father of virtual
reality, said that Mr. Epstein's ideas did not amount to science, in that they did not lend themselves to rigorous
proof. Mr. Lanier said Mr. Epstein had once hypothesized that atoms behaved like investors in a marketplace.
Mr. Lanier said he had declined any funding from Mr. Epstein and that he had met with him only once after Mr.
Epstein in 2008 pleaded guilty to charges of soliciting prostitution from a minor.
Mr. Epstein was willing to finance research that others viewed as bizarre. He told one scientist that he was
bankrolling efforts to identify a mysterious particle that might trigger the feeling that someone is watching you.
At one session at Harvard, Mr. Epstein criticized efforts to reduce starvation and provide health care to the poor
because doing so increased the risk of overpopulation, said Mr. Pinker, who was there. Mr. Pinker said he had
rebutted the argument, citing research showing that high rates of infant mortality simply caused people to have
more children. Mr. Epstein seemed annoyed, and a Harvard colleague later told Mr. Pinker that he had been
"voted off the island" and was no longer welcome at Mr. Epstein's gatherings.
Then there was Mr. Epstein's interest in eugenics.
On multiple occasions starting in the early 2000s, Mr. Epstein told scientists and businessmen about his
ambitions to use his New Mexico ranch as a base where women would be inseminated with his sperm and would
give birth to his babies, according to two award-winning scientists and an adviser to large companies and
wealthy individuals, all of whom Mr. Epstein told about it.
It was not a secret. The adviser, for example, said he was told about the plans not only by Mr. Epstein, at a
gathering at his Manhattan townhouse, but also by at least one prominent member of the business community.
One of the scientists said Mr. Epstein divulged his idea in 2001 at a dinner at the same townhouse; the other
recalled Mr. Epstein discussing it with him at a 2006 conference that he hosted in St. Thomas in the Virgin
Islands.
The idea struck all three as far-fetched and disturbing. There is no indication that it would have been against the
law.
Once, at a dinner at Mr. Epstein's mansion on Manhattan's Upper East Side, Mr. Lanier said he talked to a
scientist who told him that Mr. Epstein's goal was to have 20 women at a time impregnated at his 33,000-square-
foot Zorro Ranch in a tiny town outside Santa Fe. Mr. Lanier said the scientist identified herself as working at
NASA, but he did not remember her name.
According to Mr. Lanier, the NASA scientist said Mr. Epstein had based his idea for a baby ranch on accounts of
the Repository for Germinal Choice, which was to be stocked with the sperm of Nobel laureates who wanted to
strengthen the human gene pool. (Only one Nobel Prize winner has acknowledged contributing sperm to it. The
repository discontinued operations in 1999.)
Mr. Lanier, the virtual-reality creator and author, said he had the impression that Mr. Epstein was using the
dinner parties - where some guests were attractive women with impressive academic credentials - to screen
candidates to bear Mr. Epstein's children.
Mr. Epstein did not hide his interest in tinkering with genes - and in perpetuating his own DNA.
One adherent of transhumanism said that he and Mr. Epstein discussed the financier's interest in cryonics, an
unproven science in which people's bodies are frozen to be brought back to life in the future. Mr. Epstein told
this person that he wanted his head and penis to be frozen.
EFTA00018443

=== Page 4 ===
Southern Trust Company, Mr. Epstein's Virgin Island-incorporated business, disclosed in a local filing that it was
engaged in DNA analysis. Calls to Southern Trust, which sponsored a science and math fair for school children
in the Virgin Islands in 2014, were not returned.
In 2011, a charity established by Mr. Epstein gave $20,000 to the Worldwide Transhumanist Association, which
now operates under the name Humanity Plus. The group's website says that its goal is "to deeply influence a new
generation of thinkers who dare to envision humanity's next steps."
Mr. Epstein's foundation, which is now defunct, also gave $100,000 to pay the salary of Ben Goertzel, vice
chairman of Humanity Plus, according to Mr. Goertzel's résumé.
"I have no desire to talk about Epstein right now," Mr. Goertzel said in an email to The New York Times. "The
stuff I'm reading about him in the papers is pretty disturbing and goes way beyond what I thought his misdoings
and kinks were. Yecch."
Alan M. Dershowitz, a professor emeritus of law at Harvard, recalled that at a lunch Mr. Epstein hosted in
Cambridge, Mass., he steered the conversation toward the question of how humans could be improved
genetically. Mr. Dershowitz said he was appalled, given the Nazis' use of eugenics to justify their genocidal
effort to purify the Aryan race.
Yet the lunches persisted.
"Everyone speculated about whether these scientists were more interested in his views or more interested in his
money," said Mr. Dershowitz, who was one of Mr. Epstein's defense lawyers in the 2008 case.
Luminaries at Mr. Epstein's St. Thomas conference in 2006 included Mr. Hawking and the Caltech theoretical
physicist Kip S. Thorne. One participant at that conference, which was ostensibly on the subject of gravity,
recalled that Mr. Epstein wanted to talk about perfecting the human genome. Mr. Epstein said he was fascinated
with how certain traits were passed on, and how that could result in superior humans.
Mr. Epstein appears to have gained entree into the scientific community through John Brockman, a literary agent
whose best-selling science writers include Richard Dawkins, Daniel Goleman and Jared Diamond. Mr.
Brockman did not respond to requests for comment.
For two decades, Mr. Brockman presided over a series of salons that matched his scientist-authors with potential
benefactors. (The so-called "billionaires' dinners" apparently became a model for the gatherings at Mr. Epstein's
East 71st Street townhouse, which included some of the same guests.)
In 2004, Mr. Brockman hosted a dinner at the Indian Summer restaurant in Monterey, Calif., where Mr. Epstein
was introduced to scientists, including Seth Lloyd, the M.I.T. physicist. Mr. Lloyd said that he found Mr. Epstein
to be "charming" and to have "interesting ideas," although they "turned out to be quite vague."
Also at the Indian Summer dinner, according to an account on the website of Mr. Brockman's Edge Foundation,
were the Google founders Sergey Brin and Larry Page and Jeff Bezos, who was accompanied by his mother.
"All the good-looking women were sitting with the physicists' table," Daniel Dubno, who was a CBS producer at
the time and attended the dinner, was quoted as saying. Mr. Dubno told The Times that he did not recall the
dinner or having said those words.
Mr. Brockman was Mr. Gell-Mann's agent, and Mr. Gell-Mann, in the acknowledgments section of his 1995
book "The Quark and the Jaguar," thanked Mr. Epstein for his financial support.
EFTA00018444

=== Page 5 ===
However impressive his roster of scientific contacts, Mr. Epstein could not resist embellishing it. He claimed on
one of his websites to have had "the privilege of sponsoring many prominent scientists," including Mr. Pinker,
Mr. Thorne and the M.I.T. mathematician and geneticist Eric S. Lander.
Mr. Pinker said he had never taken any financial or other support from Mr. Epstein. "Needless to say, I find
Epstein's behavior reprehensible," he said.
Mr. Thorne, who recently won a Nobel Prize, said he attended Mr. Epstein's 2006 conference, believing it to be
co-sponsored by a reputable research center. Other than that, "I have had no contact with, relationship with,
affiliation with or funding from Epstein," he said. "I unequivocally condemn his abhorrent actions involving
minors."
Lee McGuire, a spokesman for Mr. Lander, said he has had no relationship with Mr. Epstein. "Mr. Epstein
appears to have made up lots of things," Mr. McGuire said, "and this seems to be among them."
Some of Jeffrey Epstein's victims don't want new charges in South Florida
South Florida Sun Sentinel
By Marc Freeman
7/30/19
Financier Jeffrey Epstein has been branded a pervert and an abuser, but not all of his victims want to see him
prosecuted further in South Florida.
Some of the girls Epstein assaulted at his Palm Beach mansion before 2008 have already reached financial
settlements with him and fear they'll lose their anonymity. Federal prosecutors - the ones who approved his
lenient plea deal to begin with - say they fully support that position.
Epstein faces separate federal sex trafficking charges in New York, but the debate about prosecuting him in
South Florida will be resolved soon enough. A federal judge in West Palm Beach is considering whether to strike
down parts of a controversial 2007 deal that gave him and unnamed co-conspirators immunity from federal
charges.
U.S. District Judge Kenneth Marra ruled in February that Epstein's non-prosecution agreement violated the
federal Crime Victims' Rights Act. Dozens of victims were improperly kept in the dark about it until after it had
been finalized.
Marra must decide how to rectify this violation 12 years later, after receiving arguments from lawyers for two of
Epstein's victims, prosecutors and Epstein.
The victims in the case, cited as Jane Does, say the necessary remedy is for Epstein to face what they say are
long overdue charges in Florida.
"To be sure, Jane Doe 1 and 2 very much appreciate the laudable efforts of the diligent prosecutors in New
York," their lawyers wrote. "But those New York charges, important though they are, still leave Epstein's crimes
in Florida uncharged and all of his co-conspirators at large."
Lawyers for the U.S. government disagree.
They concede that prosecutors back then "fell short" of treating victims properly as they reached a settlement
with Epstein. But the attorneys now contend "the past cannot be undone" and the deal must be upheld under the
law.
Among their arguments is that many victims clearly want to let it go, because they are content with financial
settlements they obtained from Epstein, and his 2008 guilty plea to two state prostitution charges. That plea
EFTA00018445

=== Page 6 ===
resulted in 13 months in Palm Beach County Jail and registering as a sex offender.
The prosecutors say they reached this position based on "conversations" with the victims and their lawyers,
without giving a specific number.
Attorney Spencer Kuvin of West Palm Beach said he represents one victim who met with the U.S. Attorney's
Office in April.
"She said she'd like to see him prosecuted and put in jail," Kuvin said. "She said, 'I don't know if that's a
realistic possibility, but that's what I want."
He said it's not surprising that other victims are less inclined to participate.
"When you have so many victims, you're going to have just as many different opinions as to how it should be
handled," Kuvin said. "But that shouldn't stop the prosecution of a predator. One victim that wants to come
forward is enough to put him away."
The federal prosecutors explained that while some victims "would like to see Epstein prosecuted for his crimes,
they valued anonymity above all and were not willing to speak with law enforcement or otherwise participate in
any criminal or civil litigation due to the risk that their involvement may become known to family, friends, or the
public."
This is not to say there aren't many victims who are eager to see Epstein face new charges in South Florida,
wrote Byung J. Pak, U.S. Attorney for the Northern District of Georgia, and Jill E. Steinberg and Nathan P.
Kitchens, special attorneys for the Southern District of Florida.
But they conclude that reopening their cases against Epstein in South Florida still "exacerbates the harm to
victims who have attempted to readjust their lives in the interim."
Kuvin said he agrees, "It's a valid concern for some of the victims."
Attorneys for two victims in the pending Crime Victims' Right Act litigation blasted the government's reasoning
to leave Epstein's non-prosecution agreement in place.
Lawyers Bradley Edwards, Paul Cassell and Jack Scarola say any South Florida victims who are not willing to
prosecute Epstein because of privacy concerns can simply decline to do so and remain anonymous.
The lawyers say there's no way that prosecuting Epstein for some victims would harm other victims unless the
prosecutors somehow disclose their identities in the process.
"The Government's argument thus boils down to a stop-us-before-we-do-something-bad claim that deserves no
credence from the Court," wrote Edwards and his co-counsel on behalf of the two women, identified as Jane Doe
1 and Jane Doe 2.
They also pointed out that the prosecutors weren't asserting the alleged "risk" to some victims outweighs
obtaining justice for their clients.
"But in any event, on closer examination, the Government's argument turns out to be vaporous," they wrote this
month.
Epstein's lawyers told the judge they support the South Florida prosecutors' arguments that the once-secret deal
shouldn't be blown up to allow new charges.
Jeffrey Epstein faces 'a million pages' of evidence: defense lawyer
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=== Page 7 ===
New York Post
By Andrew Denney and Bruce Golding
7/31/19
Prosecutors have 1 million pages of evidence against Jeffrey Epstein, his lawyer revealed in court Monday -
without shedding any new light on the jailhouse incident that left the convicted pedophile with bruises on his
neck.
No marks were visible on Epstein's neck, and he never appeared to be in pain during the 15-minute hearing in
Manhattan federal court.
The judge overseeing the case tentatively scheduled Epstein's trial for June 2020 after a prosecutor said the child
sex-trafficking charges against him should be resolved as "swiftly as possible."
"We don't think any delay in this is in the public interest," Manhattan Assistant US Attorney
said.
Epstein's trial is expected to last four to six weeks, and the defense will have all the prosecution's evidence
against the multimillionaire financier by Oct. 31, she said.
Defense lawyer Martin Weinberg objected to starting the trial before September 2020, saying, "We need time to
review a million pages of discovery."
But Judge Richard Berman said he was blocking out time in June 2020 on the presumption that the defense
would be ready by then.
Weinberg didn't make any mention of the July 23 incident in which law enforcement sources have said Epstein,
66, was found sprawled on the floor of his cell in the Metropolitan Correctional Center, where he's being held
without bail.
Weinberg declined to answer questions about the incident outside court.
Epstein, who wore dark blue jail scrubs over a brown T-shirt, didn't speak during the hearing.
He's pleaded not guilty to accusations he sexually abused dozens of underage girls - some as young as 14 - in
his Upper East Side townhouse and his waterfront mansion in Palm Beach, Florida, between 2002 and 2005.
Berman set a Sept. 13 deadline for defense motions in the case, and Weinberg said he planned to seek dismissal
of a conspiracy charge on grounds of double jeopardy tied to allegations that underpinned a non-prosecution
agreement that Epstein struck in 2008 with then-Miami US Attorney Alex Acosta.
That deal was exposed last year in an award-winning series of stories by the Miami Herald, and controversy that
erupted following Epstein's July 6 arrest forced Acosta to resign as President Trump's labor secretary.
Jeffrey Epstein appears in court for first time since reported jail injuries
The Guardian
By Victoria Bekiempis
7/31/19
Financier Jeffrey Epstein looked physically healthy when he appeared in court in New York on Wednesday in his
sex trafficking case, about a week after reportedly being found unconscious in his jail cell with neck injuries.
He wore dark blue jail scrubs during his brief appearance in Manhattan federal criminal court on Wednesday
morning, in a proceeding scheduled before the apparent incident behind bars last week.
There were no signs of injuries that had been reported at the time and he appeared well and more neatly
presented than at some previous hearings.
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=== Page 8 ===
The Jeffrey Epstein scandal
His lawyers did not bring up the incident in court and refused to comment on the topic following the hearing,
which focused on scheduling issues.
Prosecutor
asked for a June 2020 trial date to be set, telling the judge: "We don't think that any delay
in this case is in the public interest."
The Manhattan US attorney's office alleged earlier in July that Epstein "sexually exploited and abused dozens of
minor girls" from 2002 to 2005. Some of his victims were just 14 years old, prosecutors alleged.
The disgraced financier, who was arrested on 6 July, pleaded not guilty several weeks ago.
Epstein has long been accused of sexually abusing underage girls. He also has purported connections to Donald
Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship
with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, brokered a plea deal in
2008 that closed a federal inquiry involving at least 40 teenage girls.
Under this arrangement, Epstein pleaded guilty to state charges, which presented far less potential jail time than
if he had faced federal charges. The Miami Herald reporter Julie K Brown exposed the secretive nature of this
agreement. Acosta resigned from his post as Trump's labor secretary following extensive criticism of the deal.
Epstein has unsuccessfully requested bail while awaiting trial. The 66-year-old, who registered as a sex offender
following the Florida case, had maintained through lawyers that he neither posed a danger nor risk of flight.
In rejecting Epstein's request, Judge Richard Berman said, "the government has established danger to others and
to the community by clear and convincing evidence", adding: "I doubt that any bail package can overcome a
danger to the community."
Epstein's lawyers are appealing against the decision, according to court filings.
Late last week, Judge Berman also ruled in favor of prosecutors' proposed protective order, which will keep case
materials relating to "the government's ongoing investigation of uncharged individuals" under wraps.
Judge sets tentative date for Jeffrey Epstein's trial
Associated Press
By Larry Neumeister and Jim Mustian
7/31/19
A subdued Jeffrey Epstein listened passively in court Wednesday as a judge said he won't face trial on sex
trafficking charges before June 2020, and more likely a few months afterward.
There was no mention at the Manhattan federal court appearance or any visible sign of injuries after the 66-year-
old financier was found on the floor of his cell last week with neck bruises.
Epstein's lawyer, Martin Weinberg, refused to say what might have left his client with neck bruises after the court
hearing.
Assistant U.S. Attorney
urged a June trial date for the man accused of arranging to have sex with
girls as young as age 14, saying there is "a public interest in bringing this case to trial as swiftly as possible."
But Weinberg said the case is far from "ordinary," adding the defense team won't be ready before Labor Day
2020. He said prosecutors delayed bringing charges that relate to alleged crimes that occurred in the early 2000s
at Epstein's residences in Manhattan and Florida.
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U.S. District Judge Richard M. Berman said a trial projected to last four to six weeks could tentatively begin
June 8, but he'll likely defer to defense lawyers' needs if they are not ready.
Epstein's demeanor in court was noticeably different from previous appearances, when he was actively engaged
with his lawyers and looking through papers.
On Wednesday, he sat quietly, his hands folded in front of his face through much of the 20-minute proceeding.
Occasionally, he looked toward courtroom artists and reporters seated in a jury box.
Epstein has remained at the Metropolitan Correction Center, which is adjacent to the downtown Manhattan
courthouse.
He has pleaded not guilty to sex trafficking charges that carry the potential for up to 45 years in prison.
Berman refused bail after concluding he is a danger to the community and a flight risk. Prosecutors have said
they fear he might try to influence a growing number of witnesses who support charges that he recruited and
abused dozens of girls in New York and Florida in the early 2000s. His lawyers had argued he should be allowed
to stay under house arrest in his Manhattan mansion.
His lawyers say an agreement reached with federal prosecutors a dozen years ago disallows the charges and they
say he has committed no new crimes.
The lawyers agreed to file written arguments about the agreement and double jeopardy claims by Sept. 13. Oral
arguments will occur in October.
The non-prosecution deal was reached before he pleaded guilty in state court in Florida to prostitution-related
charges involving underage girls. Afterward, he was required to register as a sex offender and pay restitution to
many victims. While he served a 13-month jail term, he was permitted to leave jail to work for 12 hours a day,
six days a week.
Epstein was arrested July 6 when he arrived at a New Jersey airport on a private jet from Paris, where he has a
home.
Did Jeffrey Epstein try to kill himself? He and his lawyer, back in court, aren't saying
Miami Herald
By Miami Herald Staff
7/31/19
Victims of Jeffrey Epstein share the emotional toll that sexual abuse has taken on them - even years after the
abuse occurred. Miami Herald reporter Julie K. Brown interviewed the young women, most speaking for the first
time about Epstein. BY EMILY MICHOT I JULIE K. BROWN
For the first time since he was found semi-conscious in his jail cell with telltale bruise marks on his neck,
accused sex trafficker Jeffrey Epstein appeared in a Manhattan court room.
Epstein - onetime friend of the rich and powerful, including current President Donald Trump and past President
Bill Clinton - learned Wednesday that he will not face trial until at least next June.
The multimillionaire part-time resident of Palm Beach sat subdued in front of U.S. District Court Judge Richard
M. Berman. The 66-year-old defendant wore dark blue jail scrubs and glasses.
His lawyer, Martin Weinberg, declined to reveal any details about the incident at the Metropolitan Correctional
Center, which occurred July 23, including whether it was a suicide attempt, an attack by a fellow detainee or
something else. His client is being held without bond.
Wednesday's hearing in New York City lasted just 15 minutes.
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Epstein, a financier who owns homes around the world, including a waterfront estate in Palm Beach, was
arrested July 6, nearly eight months after the Miami Herald published Perversion of Justice, a two-year
investigation of a much-reviled secret plea deal in 2007-2008 that spared Epstein a sweeping federal indictment
despite allegations of sexual abuse by nearly three dozen underage girls.
He had just arrived from France at New Jersey's Teterboro airport on his private jet when authorities met him
and took him into custody.
During the early- and mid-2000s, Epstein allegedly ran what amounted to a sexual pyramid scheme, using
recruiters to lure girls as young as 14 to his lavish Palm Beach and Manhattan mansions with the promise that
they would receive $200 to give a man a massage. The girls have alleged that they were coerced into sex.
The girls were paid additional money if they would recruit others girls, police and court records allege. Epstein
had assistants schedule as many as three visits a day.
Rather than face federal charges that could have put him away for life, Epstein pleaded guilty in state court to
minor prostitution charges and served just a year in the county stockade - which permitted him to leave the
lockup for his luxurious downtown West Palm Beach office for 12 hours a day, six days a week. This "work
release" arrangement, highly unusual for a sex offender, is now under criminal investigation by order of the Palm
Beach sheriff, Ric Bradshaw, who oversees the stockade and approved the work release.
Although Assistant U.S. Attorney
said it is important to move swiftly ahead with Epstein's court
case, his defense attorney said he needs time in light of the approximately one million pages of documents that
that comprise the evidence collected against his client.
Labor Secretary Alex Acosta held a press conference to defend his role in handling the Jeffrey Epstein sexual
abuse case. Acosta was a U.S. Attorney who approved the Epstein plea deal in 2008. By CSPAN
In the meantime, Epstein will be given a chance to argue that the non-prosecution agreement, executed in 2008,
gave him, his schedulers, his alleged madam and others immunity from federal charges and that the new charges
constitute impermissible double jeopardy.
In its series of articles, the Herald highlighted the role of Alexander Acosta, then-U.S. attorney for the Southern
District of Florida, in approving the immunity agreement, including a controversial stipulation that Epstein's
accusers not be told of the arrangement. Facing searing criticism after Epstein's arrest, Acosta resigned his post
as President Trump's labor secretary.
Jeffrey Epstein could face sex trafficking trial next June
Reuters
7/31/19
Financier Jeffrey Epstein could go to trial on charges of sex trafficking involving dozens of underage girls as
early as next June, though his lawyers told a court on Wednesday they may need more time.
At a hearing in Manhattan federal court, prosecutors sought a June 2020 trial date, while a lawyer for Epstein
asked that it wait another three months.
The lawyer, Martin Weinberg, said Epstein and his legal team needed more time to review evidence, expected to
total more than 1 million pages.
U.S. District Judge Richard Berman said he would tentatively set aside time for a trial beginning June 8, but
revisit the issue later. He said he normally allowed defendants more time to prepare if they wished.
Assistant U.S. Attorney
said a trial is expected to last four to six weeks.
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Prosecutors have accused Epstein of arranging for girls under the age of 18 to perform nude "massages" and
other sex acts, and of paying some girls to recruit others. Epstein has pleaded not guilty.
Wednesday's hearing occurred one week after Epstein was reportedly found unconscious and with neck injuries
in his jail cell at the Metropolitan Correctional Center in downtown Manhattan.
Epstein, dressed in blue jail scrubs, had no visible injuries on Wednesday. His lawyers declined to comment on
the reports after the hearing.
Epstein is appealing Berman's July 18 denial of his request to remain under house arrest in his $77 million
mansion on Manhattan's Upper East Side while awaiting trial.
The charges against Epstein focus on alleged misconduct from at least 2002 to 2005.
They followed Epstein's 2008 guilty plea to state prostitution charges in Florida, in exchange for the Justice
Department's agreement not to prosecute him on similar charges.
Epstein served 13 months in jail and agreed to register as a sex offender under the 2008 agreement, which is now
widely considered too lenient.
His lawyers have argued this month that the agreement barred federal prosecutors in Manhattan from pursuing
the current case over the same conduct. Weinberg said at Wednesday's hearing that they intended to file motions
on the issue.
U.S. Attorney Geoffrey Berman, whose office is overseeing the current case, has said there is no such bar.
Epstein Lawyers Ask for a Year to Review a Million Pages
Bloomberg
By Chris Dolmetsch, Bob Van Voris, and Patricia Hurtado
7/31/19
Jeffrey Epstein's lawyers say they need at least a year to review a blizzard of documents prosecutors have
gathered against the fund manager as they prepare to defend him against charges of sex trafficking in minors and
conspiracy.
Prosecutors asked a judge to schedule Epstein's trial for next June, but defense attorney Martin Weinberg said his
team wanted to wait until September 2020, because they haven't yet begun to receive documents from the
government.
"We need time to receive a million pages of discovery and prepare to defend a four- to six-week trial," Weinberg
said during a brief hearing in Manhattan on Wednesday. "We need time to assess events that occurred 14 to 17
years ago."
The judge set a tentative trial date of June 8 and asked the parties to keep him updated on their progress.
Epstein, who didn't speak in court, was arrested on July 6 after stepping off his private plane in New Jersey from
a trip to Paris. He has pleaded not guilty and said he has fully complied with the law for more than 14 years.
Marks on Neck
Epstein is accused of molesting teenage girls from 2002 to 2005. He pleaded guilty in 2008 to Florida state
charges of soliciting prostitution, after striking a non-prosecution agreement with the U.S. Federal prosecutors in
New York say they are not bound by the deal as they now pursue their own charges.
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In court Wednesday, there was no discussion of what happened to the 66-year-old Epstein last week at New
York's Metropolitan Correctional Center, where he has been held since his arrest. People familiar with the matter
said he was found injured and unresponsive in his cell, with marks on his neck. Authorities are investigating
whether he was assaulted, possibly by another inmate, or whether the injuries were self-inflicted. Weinberg
declined to respond to questions about the incident outside court.
Also in court was Gloria Allred, the activist lawyer who has represented women accusing Roy Moore, Bill
Cosby and President Donald Trump of sexual assault. After the hearing, she said she was representing other
Epstein accusers who "were not in the Florida case." She said other women have approached her about their
experiences with Epstein but were reluctant to discuss them for fear of retaliation.
The U.S. attorney in Manhattan, Geoffrey Berman, has urged others who may be victims to come forward and
cooperate with the government. Allred declined to say whether her clients have spoken to prosecutors.
The case is U.S. V. Epstein, 19-cr-490, U.S. District Court, Southern District of New York (Manhattan).
Collins
Editorial: Failures of ethics
Buffalo News
By News Editorial Board
7/29/19
The ethics specialists are right and so are the members of a special ethics panel, including both Democrats and
Republicans, who are paying attention. Good for them. The conduct of Rep. Chris Collins, R-Clarence, exposed
a range of issues Congress needs to treat as tumors, and cut them out.
Collins was indicted last year on allegations of insider trading. But he was routinely smashing ethical standards -
of both formal and common sense varieties - before he was ever charged with a crime.
A year before Collins was indicted, the Office of Congressional Ethics reported that it found "a substantial
reason to believe" that Collins violated federal law by touting the stock of Innate Immunotherapeutics, an
Australian biotech firm, based on inside information.
The office also said Collins may have broken House ethics rules by persuading National Institutes of Health
officials to meet with a staffer from that company.
At least as troubling are the actions Collins took that were not deemed to be ethical violations. Speaking to a
bipartisan House task force charged with drawing up new ethics rules based on Collins' arrest, ethics experts
worried about lawmakers who sit on the boards of privately owned companies, or who serve as partners in other
businesses or who are directors of nonprofit organizations. Collins still does all three.
Earlier this year, in response to Collins' arrest, the House barred lawmakers from serving on the boards of
publicly traded companies. Collins did that, too, as a board member - and leading stockholder - of Innate
Immunotherapeutics. It's how prosecutors say he obtained the insider information that led to his arrest.
There was more. Collins authored a provision of the 2016 "21st Century Cures Act" that sped drug approval for
companies like Innate. Collins, with a straight face, claimed there was no conflict because Innate had no business
before U.S. regulators. But in 2017, the company practically beamed that it had "received clearance from the
U.S. Food and Drug Administration for the Company's Investigational New Drug (IND) application lodged last
month."
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The fact that Collins' role in the legislation could also have benefited other companies - and may even have been
worthy of passage - does nothing to change the associated fact that he was pushing for legislation whose
adoption could have lined his pockets. It was classic self-dealing.
The drug in question was meant to treat multiple sclerosis. It failed in clinical trials in 2017 and prosecutors say
Collins illegally spread the word to family and others who were able to sell their stock before its price collapsed
on the bad news.
Collins has pleaded not guilty to the charges. His trial is scheduled for February. But regardless of what a judge
or jury ultimately decides about Collins, he has shown himself to be indifferent to the need for a member of
Congress to conduct himself in a way that reflects well on the institution and on the voters who entrust him with
public office.
In that, he has shown Congress that it needs to act. It can't count on its members using good judgment, especially
when millions of dollars are at stake.
The good news is that it seems ready to meet that public obligation. It is considering measures that would
prohibit lawmakers from serving as partners in limited liability corporations, joining committees that oversee
their business interests and serving on the boards of nonprofit organizations. Staff members would also be
barred.
Sadly, some Republican members have defended Collins, despite the clear conflicts of interest. But the
Republican on the ethics task force, Rep. Van Taylor of Texas, expressed no disagreement with the panel's
Democrat, Pennsylvania Rep. Susan Wild, who said she expected to move "rather quickly" on writing new rules.
Taylor sees the tasks as "very narrow," focused on preventing lawmakers from serving in outside positions that
could pose conflicts. The remarkable thing is that those restrictions need to be put in writing. Thank Collins for
that.
Securities and Commodities Fraud
Stewart
Southern District Will Pursue A Retrial Of "Silver Platter" Case
Forbes
By Walter Pavlo
7/30/19
Sean Stewart was indicted on insider trading charges back in May 2015 during U.S. Attorney Preet Bharara's
reign over the Southern District of New York. Now, over four years since his indictment, Sean can reflect back
on a wild journey of being convicted, sentenced to 3 years prison, having that conviction overturned, being
released from prison halfway through his term and, now, having a new date to go back to trial to face the charges
again.
Sean Stewart was indicted on insider trading for passing material non-public information on potential deals to his
father, Robert, who then passed it on to his former friend and trader, Richard Cunniffe. Sean, a Yale graduate
who had worked in investment banking at JPMorgan Chase and Perella Weinberg, mentioned some details about
his work while talking to Robert. Sean's information made it to Cunniffe who made over a million dollars on the
trades, sharing a small amount (less $100,000) with Robert. How much did Sean make on the trades? ZERO
dollars. He had no idea that Cunniffe traded because he did not even know who Cunniffe was.
It was a clear case of misappropriation where information was used without Sean's knowledge, so it was not a
"classical" insider trading case. However, Bharara's team of U.S. attorneys was looking for cases that targeted
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wealthy Wall Street traders who seemed to have an advantage over the average trader. Sean's case was a good
fit.
Cunniffe was busted by the FBI and soon became a government informant, taping calls and other meetings with
Robert. In one of those calls, Robert stated that Sean said of the information he had passed on to Cunniffe, "I
can't believe it. I handed you this on a silver platter and you didn't invest." So the primary evidence in the case,
the case that came to be known as the "silver platter" case, was based on a statement that was attributed to Sean.
It's a phrase that Sean's new defense team wants to be excluded from the proceedings.
When Robert was arrested, under duress of FBI questioning, he said nine (9) times that Sean was not in on his
scheme with Cunniffe (here is entire tape transcript here). Robert also admitted his own role and that of
Cunniffe's during the interrogation. When it came to trial, neither that tape nor Robert's testimony was allowed
because of legal maneuvering by prosecutors. The video tape was suppressed and Robert did not testify due to
threats from prosecutors that he would be charged for perjury due to his conflicting accounts. Here is what the
jury missed from that tape:
FBI AGENT: Tell me about the first time that Sean gave you information on a deal.
ROBERT STEWART: Well, uh, I wouldn't characterize any of these as
I mean Sean would mention stuff. I
don't think he had any idea that I would trade on any of this stuff. Uh, I've never mentioned that I did, to him.
Ummm
AGENT: If that's true, how do you explain the comment you made to Rick [Cunniffe] that Sean got angry with
you when he gave you this information on a silver platter and you didn't invest.
ROBERT: Uhh, I think I was just saying that to Rick because Sean said, oh, you know, ahh, all these deals, you
know, you
if you were trading you could make like millions of dollars. And I said, you know, Sean, no
one's going to trade and make millions of dollars on this stuff. That wasn't his intention.
Robert took the 5th but did submit an affidavit that if he were to testify he would have said Sean did not know
about the trades by Cunniffe.
Looking back at the trial, there was not a single email, document, or text message that suggested that Sean was a
knowingly participated in the trading scheme. This is interesting since there were so many incriminating
documents between Cunniffe and Robert. There were no witnesses who gave testimony on Sean's knowledge
and intent, including Cunniffe, the cooperator, who on the stand acknowledged that he never knew Sean.
Furtnermore, trading records and actions undertaken by Sean suggest he did not know trading had taken place.
Last fall, the 2nd Circuit overturned Sean's conviction, something rare in most cases, especially a reversal on an
evidentiary ruling, which suggests the 2nd Circuit felt that Sean may be innocent and the judge's mistakes
resulted in an unfair trial. The appellate court ruled that Robert's post-arrest video interrogation should have
been allowed. Sean was released from prison and has been in legal limbo until the SDNY decided that they
would move to move forward with another trial on the same charges.
Stewart will have a new judge this time around. U.S. District Judge Laura Taylor Swain was replaced by Judge
Rakoff, a man who seems to be on a mission to define insider trading laws himself. He also has new attorneys
Steven M. Witzel, Lawrence Gerschwer, R. David Gallo and Leigh G. Rome of Fried Frank Harris Shriver &
Jacobson LLP.
If Sean is found guilty, he would face the prospect of being sentenced to prison and returning to prison to
complete a term. On the other hand, it would not be out of the question for Judge Rakoff to give him "time
served" in prison even if Sean is found guilty. Rakoff, not a fan of the Federal Sentencing Guidelines, seems to
be one of those judges that uses common sense in his approach to sentencing. Earlier this week, Rakoff
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sentenced a man to 14 months in prison for knowingly leaking insider information on Sherwin Williams'
acquisition of Valspar.
While Sean may have made some mistakes, these could have been handled by the companies he worked for and,
at the most severe, an enforcement action by the Securities and Exchange Commission. The SDNY seems intent
on trying to interpret insider trading laws by putting on elaborate trials with the threat of putting people in prison
for years. It is a waste of resources.
It looks like the ghost of Bharara still haunts the SDNY.
Thompson
Easton man accused of stealing $7M via fake Bitcoin transactions
Lehigh Valley Live
By Sarah Cassi
7/30/19
An Easton man who headed a cryptocurrency escrow company was arrested last week on federal charges he
allegedly stole $7 million from two companies by lying about Bitcoin transactions.
Jon Barry Thompson, also known as J. Barry Thompson, was the principal of Volantis, which included a
cryptocurrency escrow company called Volantis Escrow Platform LLC and a related company, Volantis Market
Making LCC.
The 48-year-old Thompson was arrested in Easton, and was charged with two counts each of commodities fraud
and wire fraud. Easton police assisted in serving the arrest warrant at 6:15 a.m. Thursday at Thompson's West
Burke Street home on College Hill.
What happens to the money when a criminal's stash is in bitcoin?
When a criminal's stash is in bitcoin, the stakes are now much higher in forfeiture cases with the soaring value of
the virtual currency.
Thompson was released after posting $500,000 bond. Messages left for comment at a phone number listed for
Thompson and for his defense attorney, Matthew Siembieda, were not immediately returned.
Prosecutors said Thompson stole $7 million from two companies after lying about transactions of the peer-to-
peer digital currency Bitcoin -- $3 million from one company and $4 million from a second.
Thompson offered minimized settlement default risk in cryptocurrency transactions, and claimed there was no
risk of default, prosecutors allege.
In June and July 2018, Thompson convinced the first company to send Volantis more than $3 million for a
Bitcoin purchase, prosecutors allege. Thompson allegedly assured the company he had the Bitcoin in hand and
that money could not be lost.
Thompson took the money, but never provided the company the promised Bitcoin or returned its money,
prosecutors said.
Thompson allegedly gave the company a fake account statement showing he had the company's money but in
reality sent the more than $3 million to a third-party entity purportedly in exchange for Bitcoin without first
receiving any of the Bitcoin in hand.
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In July 2018, Thompson allegedly convinced a second company to send Volantis more than $4 million for
Bitcoin purchases. Again, Thompson is accused of sending a substantial portion of the money to a third party
without first receiving any Bitcoin in return, prosecutors allege.
Thompson never gave the second company any Bitcoin and did not return its money, prosecutors said.
"Jon Thompson induced investors to engage in cryptocurrency transactions through his company, Volantis
Market Making, by touting a transaction structure that would eliminate any risk of loss during the purchase,"
Manhattan U.S. Attorney Geoffrey S. Berman said in a news release. "As his clients soon realized, however,
Thompson's representations were false, and these cryptocurrency investors ultimately lost all of the money they
had entrusted with him because of his lies."
FBI Assistant Director-in-Charge Sweeney said Thompson used phrases and terminology that the victimized
companies didn't understand, and he "allegedly preyed on their ignorance of the emerging cryptocurrency."
"Thompson allegedly thought no one would ask where their actual money went when they trusted him to invest
in Bitcoin," Sweeney said.
The complaint doesn't identify the companies allegedly victimized by Thompson.
Forbes previously reported Symphony, an Irish investment company that specializes in trading cryptocurrencies,
gave Thompson 3.6 million Euros to purchase Bitcoin on its behalf.
Symphony never received any Bitcoin and its money was never returned.
In that case, the plaintiff withdrew the complaint it had brought in federal court in Pennsylvania and, instead,
reached a private settlement with Thompson. Thompson then breached the agreement by failing to make the first
settlement payment, Forbes reported.
Pinto-Thomaz
Popular Paint Brand Insider Trading Results In Prison Term: Feds
Patch
By Chris Dehnel
7/30/19
A former analyst for a major financial ratings agency is to spend more than a year in prison for an insider trading
scheme involving his hairdresser, a jeweler and two major paint brands sold prominently in Connecticut.
Geoffrey S. Berman, the United States Attorney for the southern district of New York, announced that Sebastian
Pinto-Thomaz, 34, a former credit ratings analyst at Standard & Poor's, was sentenced in Manhattan federal court
to 14 months in prison for participating in two schemes to trade on material, nonpublic information in advance of
the Sherwin-Williams Company's acquisition of the Valspar Corporation.
Valspar is the brand sold by Lowe's.
Pinto-Thomaz was convicted on April 26, following a jury trial before U.S. District Judge Jed S. Rakoff, who
also imposed Monday's sentence.
In summarizing the case, Berman said, "As an employee of Standard & Poor's, Sebastian Pinto-Thomaz was
privy to potentially lucrative information about business acquisition plans. Instead of protecting that information,
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=== Page 17 ===
as he had sworn to do, he shared it with a friend and with his hairdresser. In turn, they bet on a stock that they
knew to be a sure thing, and raked in nearly $300,000 in profits. Pinto-Thomaz painted himself into a corner
when he and his co-defendants exploited insider information to reap illegal profits. Now they all face time in
prison for their misdeeds."
When a company announces an acquisition, the acquiring company often seeks the opinion of a credit rating
agency regarding the potential impact that the acquisition could have on the acquiring company's
creditworthiness, Berman said. Therefore, companies often contact rating agencies before an acquisition is
publicly announced in order to secure the rating agency's views on how a possible acquisition could impact a
company's credit rating, he said.
All major rating agencies offer a service - sometimes known as a Rating Evaluation Service, or RES - that
provides the company with a rating committee decision with respect to a proposed acquisition.
In March 2016, Standard and Poor's, a credit rating agency in New York, assigned Pinto-Thomazto work on a
RES for the Sherwin-Williams Company in advance of its contemplated but unannounced acquisition of the
Valspar Corporation, according to casae records.
In connection with the assignment, Pinto-Thomaz received material, nonpublic or "inside" information the deal
about Sherwin-Williams's planned acquisition of Valspar prior to the public announcement of the acquisition.
S&P's written policies prohibited the unauthorized disclosure of confidential information, which included the
inside information, Berman said.
During his tenure at S&P, Pinto-Thomaz reviewed and certified his duties of loyalty and confidentiality to S&P
and its clients, according to case records.
In March 2016, Pinto-Thomaz passed the inside information about the paint merger to Jeremy Millul, a friend,
and to Abell Oujaddou, his hairdresser, so that they could "use it to make profitable trades in Valspar stock and
options.," Berman said.
On March 21, 2016, the first trading day after the public announcement of the acquisition, the price of Valspar
stock increased approximately 23 percent over the prior day's close.
Millul, a Manhattan jeweler opened a brokerage account on March 13, 2016, and shortly thereafter purchased
480 shares of Valspar common stock, case records show. On March 18, 2016, the last trading day before the
acquisition was publicly announced, Millul also purchased 75 out-of-the-money Valspar call options, according
to case records.
After the acquisition was publicly announced, Millul sold his Valspar stock and options for approximately
$106,806 in profits, Berman said.
Oujaddou, a Manhattan hairstylist and salon owner who has known Pinto-Thomaz for years and is a close friend
with his mother, was given inside information during a haircut on March 8 or 9, 2016, according to case records.
On March 10 through March 18, 2016, Oujaddou, who had never previously purchased Valspar or Sherwin-
Williams purchased 8,630 shares of Valspar stock, case records show.
After the acquisition was publicly announced, Oujaddou sold his Valspar shares for approximately $192,080 in
profits, according to case records.
Following the trading, Oujaddou met Pinto-Thomaz in the paint aisle of a hardware store and paid him a
kickback, Berman said.
Pinto-Thomaz denied having a relationship with anyone on the list of pre-merger trading.
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=== Page 18 ===
In addition to his prison term, Pinto-Thomaz was sentenced to three years of supervised release and ordered to
pay a fine of $15,000 and a forfeiture money judgment in the amount of $7,500.
Millul and Oujaddou each previously pled guilty and were to be sentenced on July 30.
Narcotics
Castro
Drug Dealer Forfeits Over $4M in Bitcoin as Part of a Guilty Plea
All Stocks
By Ravi Rd
7/31/19
According to a July 25 press release from the United States Attorney's Office of the Southern District of New
York, the very active Bitcoin drug dealer Richard Castro has pleaded guilty of committing illicit activities such
as money laundering and distributing three controlled substances through the dark web and encrypted emails.
Castro was charged by the US Department of Justice (DoJ) and agreed to forfeit more than $4 million including
cryptocurrency funds available in his seven different Bitcoin wallets.
Castro, 36-year-old based in Windermere, Florida, operated under multiple badges, such as "Chems_usa,"
"Chemical usa" and "Jagger109" to distribute three controlled opioid substances namely carfentanil, fentanyl,
and phenyl fentanyl. Dream Market and AlphaBay were two of his primary market places on the dark web,
where he sold drugs in exchange for cryptocurrency.
The three controlled opioid substances were sold from November 2015 to 2019 by Castro and another co-
conspirator, Luis Fernandez. Fentanyl, the first of these three is considered to be significantly stronger than
heroin while Carfentanil is believed to be 100 times stronger than fentanyl. Castro sold these substances under
the three aforementioned monikers which ultimately used to prove that he is indeed the leader of this conspiracy.
On Dream Market, Castro once boasted about 3,200 transactions that he had completed on various dark web
marketplaces. Out of these 3,200 transactions, 1,800 transactions were successfully completed on AlphaBay
alone. The conspirators apparently also received many positive reviews for the quality of synthetic opioid
substance they were selling.
In June 218, Castro informed his clients that he would only accept orders received by encrypted emails and
declared the organization is getting the business off from the dark web. Customers who wanted to buy narcotics
had to acquire the address of the encrypted email from "Chems_usa" by paying certain fees. Unfortunately for
Castro, an undercover law enforcement officer also obtained the encrypted email and placed an order, which
ultimately led to his arrest.
Castro was accepting the payments in Bitcoin which were later distributed in seven different BTC wallets.
Manhattan U.S. Attorney Geoffrey S. Berman said:
"As he admitted today, for years, Richard Castro used the dark web to distribute prolific quantities of powerful
opioids, including fentanyl and carfentanil. Castro thought he could hide behind the anonymity of the internet,
and use online pseudonyms to deal drugs - like "Chems_usa" and 'Chemical_usa.' Thanks to our law
enforcement partners, 'Chems_usa' is now in U.S. prison."
Castro has agreed to forfeit $4,156,198.18 including the funds on those seven Bitcoin wallets.
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Rochester Drug Company
Distributor Has Been Shipping Excess Opioids to Small Towns
Legal Reader
By Sara E. Teller
7/31/19
Miami-Luken Inc., an Ohio drug wholesale distributor, and four people including two former executives have
been charged with selling millions of pills amid the opioid epidemic despite knowing the dangers. The
indictment charged the Springboro, Ohio-based company; Anthony Rattini, the company's former president;
James Barlay, former compliance officer, and two pharmacists with "conspiring to distribute controlled
substances." Prosecutors have alleged "Miami-Luken ignored obvious signs that drugs were being diverted to
illegal users and dealers between 2011 and 2015." The company was shipping 4.9 million pills to Miller-West's
drugstore in Oceana, W.Va., where the population is just under 1,400.
"Miami-Luken and the executives failed to guard against the dangerous drugs it was shipping to pharmacies in
five states from being diverted for illegal uses or to report suspicious orders to the U.S. Drug Enforcement
Administration," they added.
The distributor shipped millions of pills to desolate and rural areas of Appalachia which was hit especially hard
by the epidemic. "Records show Miami-Luken also distributed 3.7 million hydrocodone pills from 2008 to 2011
to a pharmacy in Kermit, West Virginia, a town of just 400 people," prosecutors said. The pharmacists charged
were Devonna Miller-West, the owner of Oceana, West Virginia's Westside Pharmacy, and Samuel Ballengee,
owner of Williamson, West Virginia's Tug Valley Pharmacy.
The company was also shipping some to other "unnamed pharmacists and physicians," the indictment alleged.
"There's a need, in my opinion, to devote sufficient charges right here and now to stop the dying," United States
Attorney Benjamin C. Glassman said, adding investigators found "many overdose deaths that could arguably be
linked to the conduct of people accused in the conspiracy."
In April of this year, criminal charges were brought against Rochester Drug Co-operative. Geoffrey S. Berman,
the United States Attorney for the Southern District of New York, and Ray Donovan, the Special Agent in
Charge of the New York Division of the U.S. Drug Enforcement Administration (DEA), announced the charges.
Rochester Drug Co-Operative is one of the 10 largest pharmaceutical distributors in the United States. Charges
were also filed against Laurence F. Doud III, the company's former chief executive officer; and William
Pietruszewski, the company's former chief compliance officer. The indictment was specifically for "unlawfully
distributing oxycodone and fentanyl, and conspiring to defraud the DEA," according to court documents.
Berman said at the time, "This prosecution is the first of its kind: executives of a pharmaceutical distributor and
the distributor itself have been charged with drug trafficking, trafficking the same drugs that are fueling the
opioid epidemic that is ravaging this country. Our Office will do everything in its power to combat this
epidemic, from street-level dealers to the executives who illegally distribute drugs from their boardrooms." The
company paid $20 million to resolve the charges.
DEA Special Agent in Charge Ray Donovan said, "Today's charges should send shock waves throughout the
pharmaceutical industry reminding them of their role as gatekeepers of prescription medication. The distribution
of life-saving medication is paramount to public health; similarly, so is identifying rogue members of the
pharmaceutical and medical fields whose diversion contributes to the record-breaking drug overdoses in
America. DEA investigates DEA Registrants who divert controlled pharmaceutical medication into the wrong
hands for the wrong reason. This historic investigation unveiled a criminal element of denial in RDC's
compliance practices and holds them accountable for their egregious non-compliance according to the law."
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Civil
Life Spine
Lawsuit against Huntley-based medical device company alleges kickback scheme
Northwest Herald
By Drew Zimmerman
7/30/19
Life Spine, a medical technology manufacturer in Huntley, is the defendant in a federal lawsuit alleging
violations of the False Claims Act by offering lucrative incentives to surgeons in exchange for their use of Life
Spine products.
The suit, which was filed last week by the U.S. Attorney's Office in the Southern District of New York, alleges
that the company entered into agreements with dozens of surgeons as a means to pay more than $7 million in
illegal kickbacks - including consulting fees, royalties and intellectual acquisition payments - for the surgeon's
use of Life Spine's equipment.
The suit also alleges that these agreements, spanning an estimated seven-year period, were done with the
knowledge, involvement and participation of Life Spine President and CEO Michael Butler and Vice President
of Business Development Richard Greiber, who also are being charged.
"Defendants are liable for damages based on the payment of claims submitted to Medicare and Medicaid for
medical services and procedures involving Life Spine Products that were tainted by illegal kickbacks," the suit
reads.
About half of Life Spine's total domestic sales of spinal products between January 2012 and at least December
2018, were attributable to surgeries performed by these paid surgeons, according to the suit.
In addition to the consulting fees and royalties being paid, surgeons also were treated to dinners at high-end
restaurants, Chicago Cubs games and other perks.
"As alleged, Life Spine and its senior management flagrantly ignored the law by paying surgeons millions of
dollars in fees and royalties to get them to use Life Spine products during spinal surgeries," Manhattan U.S.
Attorney Geoffrey S. Berman said in a release. "Kickbacks to doctors can alter or compromise their judgment
about the medical care and services to provide to patients, and can increase healthcare costs."
For the first two counts of violating the False Claims Act - which are against Life Spine, Butler and Greiber -
the plaintiff is seeking treble damages and civil penalties to the maximum amount allowed by state law.
For the third count of unjust enrichment - which is only against Life Spine - the plaintiff is seeking damages to
the extent allowed by law.
The plaintiff also is seeking pre- and post-judgment interest, costs and any other relief the court deems
appropriate.
A statement from Life Spine said that both parties are engaged in discussions and look forward to resolving the
matter.
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=== Page 21 ===
Matters of Interest
The U.S. said a California cherry-picker went to Pakistan for terrorist training. Now the case has
collapsed.
Washington Post
By Meagan Flynn
7/31/19
It was a month after 9/11, and Osama bin Laden's face flashed across the news on Naseem Khan's TV screen.
The FBI was sitting in his living room in Bend, Ore., and Khan sensed an opportunity. The agents had come for
an entirely different purpose and were ready to leave - until Khan pointed at the screen and said he thought he
could help with something else. A few years ago, he said, he saw bin Laden's second-in-command, Ayman al-
Zawahiri, one of the most wanted terrorists in the world, at a mosque in the wine-country town of Lodi, Calif.
The agents perked up, intrigued by the possibility. Had they really just stumbled into a hot tip on al-Qaeda while
speaking to a 28-year-old McDonald's worker and convenience store clerk? The FBI thought Khan was onto
something - a possible "sleeper cell" of terrorism hidden in Lodi - and decided to dispatch him there as a
confidential informant.
Khan wouldn't find any associates of Zawahiri at the mosque in Lodi, and U.S. officials and terrorism experts
now doubt his initial claim about Zawahiri was ever true. But Khan would find 19-year-old Hamid Hayat - who
would soon become the face of homegrown terrorism in post-9/11 America.
They met at the mosque, and Khan learned Hayat was taking a trip to Pakistan with family. Over and over, in
recorded conversations, he returned to the same question: Would Hayat commit to attending a terrorist training
camp, as he had promised?
Now, a judge's order on Tuesday casts doubt on whether Hayat ever actually did.
Hayat, a cherry-picker and son of an ice cream truck driver, was convicted of attending the alleged terrorist
training camp and sentenced to 24 years in prison in 2006. Prosecutors, relying on Khan and Hayat's own
statements, alleged that he attended the camp for three to six months sometime in 2003. The case would become
one of the most high-profile examples of the government's fight against terrorism in the immediate aftermath of
9/11, especially because Hayat, after hours of interrogation by FBI agents, confessed to attending the camp.
But on Tuesday, U.S. District Judge Garland E. Burrell Jr. vacated his conviction and sentence, finding that
Hayat had inadequate defense during the 2006 trial while casting doubt on the facts of the case. Burrell
questioned whether jurors would have convicted him had they heard evidence from witnesses in Pakistan, which
the judge said likely would have "undermined" jurors' confidence in Hayat's confession alone. His attorneys
have maintained the confession was coerced during an exhausting interrogation.
Had the defense attorney actually interviewed any witnesses in Pakistan who spent significant time with Hayat
during his trip, she would have discovered that they recalled Hayat spent most of his time playing video games
and cricket and that the purpose of his visit was for his family to find him a wife, according to Burrell's order.
No one identified any prolonged disappearance that would have allowed him to visit a terrorist training camp for
three to six months as prosecutors alleged and Hayat said in the confession, Burrell noted. Burrell, who oversaw
Hayat's original trial, found the witnesses gave consistent statements and could have provided Hayat a credible
alibi.
"Showing that Hayat could not have been at a jihadi training camp for the 'period of months' specified in the
indictment would have been completely consistent with the defense that Hayat's confession should not be
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=== Page 22 ===
credited and the government lacked other supporting evidence," a U.S. magistrate wrote in making the
recommendation that Hayat's conviction be vacated. Burrell adopted most of the magistrate's findings of fact.
The government has not decided yet whether to appeal the decision, a spokeswoman in the U.S. attorney's office
in the Eastern District of California said in a statement, the Sacramento Bee reported. "We are in the process of
reviewing the district court decision and assessing what steps, if any, should be taken and considering all our
options," the statement said.
Hayat, now 36, is currently being held in a federal prison in Phoenix. His attorneys are seeking his immediate
release.
The case against Hayat and his father, Umer, who was accused of lying to the FBI, heaped international attention
on the Northern California town of Lodi. Seemingly overnight, the town went from the zinfandel capital of the
world to an alleged terrorism "sleeper cell" - a claim authorities would later walk back.
At the time he met Khan in August 2002, Hayat lived in his parents' garage and didn't have many friends, as the
Intercept recounted in a 2016 investigation. Posing as a radical Islamist, Khan nudged Hayat into conversations
that were anti-American and supportive of Islamic fundamentalist groups, and to his delight Hayat went along
with it, according to recorded conversations cited in federal court documents. Hayat approved of the beheading
of Wall Street Journal journalist Daniel Pearl by Pakistani militants. He told Khan he believed jihadists had
attended his grandfather's religious school in Pakistan and claimed his grandfather was so politically well
connected that the Pakistani president enlisted him in efforts to persuade the Taliban to turn over bin Laden after
9/11.
Then came the terrorist camps. Hayat said he had seen one in an online video - and expressed interest in going
himself. Khan, feeding the intel to the FBI, egged him on.
But once in Pakistan, Hayat kept making excuses, according to the judge's order. When Khan told him he was
being "lazy," Hayat claimed the climate had changed and it got too hot outside - the terrorist camp was
canceled, he said. Khan was starting to get mad. His nudges turned to threats.
"God willing, when I come to Pakistan and I see you, I'm going to force you to, get you from your throat and
throw you in the madrassa," Khan said in one expletive-laden recorded conversation, as the Intercept reported.
"I'm not going to go with that," Hayat said.
"Oh yeah, you will go," Khan told him. "Yeah, you will go. You know what? Maybe I can't fight with you in
America, but I can beat your a-- in Pakistan, so nobody's going to come to your rescue."
In their last conversation, according to the Intercept, which obtained all the recordings, Hayat said he "never
intended on going to a camp."
Hayat denied attending a camp in his first interview with the FBI in Japan, before flying to San Francisco. He
confessed during his second interview in California upon his return in June 2005.
"FBI: Al Qaeda plot possibly uncovered," rang a CNN headline in June 2005, saying those involved "Trained on
how to kill Americans."
Months after Hayat's arrest, then-director of national intelligence, John D. Negroponte, testified in a
congressional hearing that a "network of Islamic extremists in Lodi, Calif., for example, maintained connections
with Pakistani militant groups, recruited United States citizens."
But ultimately, no other terrorism cases arose from the investigation except for the one against Hayat. Two
imams were investigated but were never criminally charged with anything. They had overstayed religious worker
EFTA00018462

=== Page 23 ===
visas, authorities discovered.
A retired FBI agent who watched Hayat's interrogation and the resulting confession told the Los Angeles Times
it was "the sorriest interrogation, the sorriest confession, I've ever seen," believing the agents fed Hayat the
details they wanted to hear and that Hayat repeated them so he could leave. He was barred from offering his
testimony at trial. Burrell found that the failure to challenge the validity of the confession by presenting a false
confession expert also contributed to his finding that Hayat had ineffective counsel.
Khan was ultimately paid nearly $230,000 for assisting the FBI over three years. During Hayat's trial, his
defense attorney questioned how one fast-food worker's implausible claim that he saw the world's most wanted
terrorist in a small-town mosque could have "sparked this whole investigation with this ridiculous claim," the
Times reported in 2006.
Hayat's attorneys filed an appeal in 2014 and ultimately sought to interview numerous witnesses in Pakistan who
could account for his whereabouts during the trip from 2003 to 2005. They appeared for sworn depositions on
video in 2018. When Hayat's attorney, Dennis Riordan, asked his uncle whether he "would have known" if
Hayat disappeared from their rural hamlet, Muhammad Anas said, "Naturally, I would have noticed," the
Marshall Project reported then.
The judge found that the witnesses "corroborated each other on some important points," regarding trips the
family took throughout Pakistan and who they visited. Once or twice a month, they traveled to a hospital for his
mother's medical treatment.
On Tuesday, Hayat's family issued a statement applauding the judge's decision to throw out Hayat's conviction,
the Sacramento Bee reported.
"We have been waiting 14 long years for Hamid to be freed," the statement read. "Hamid cannot get those 14
years of his life back, but we are relieved to see the case take such a big step forward. We miss him and hope to
be reunited with him soon."
Fed Cuts Interest Rates for First Time Since 2008 Crisis
New York Times
By Jeanna Smialek
7/31/19
The Federal Reserve cut interest rates for the first time in more than a decade on Wednesday as it attempted to
guard the record-long economic expansion against mounting global risks.
The widely expected quarter-point move, the Fed's first since it cut rates to near zero in 2008, is meant to protect
the economy against the potentially harmful effects of a growth slowdown in China and Europe and uncertainty
from President Trump's trade war.
"In light of the implications of global developments for the economic outlook as well as muted inflation
pressures, the committee decided to lower the target range for the federal funds rate," according to the Federal
Open Market Committee's policy statement.
But the Fed did not indicate that this was the beginning of a rate-cutting campaign, suggesting instead that the
cut was a minor adjustment intended to help the economy weather any challenges from slowing global growth
and Mr. Trump's trade fights.
Subscribe to With Interest
EFTA00018463

=== Page 24 ===
Catch up and prep for the week ahead with this newsletter of the most important business insights, delivered
Sundays.
While Jerome H. Powell, the Fed chair, left the door open to additional rate moves if the economy showed signs
of sputtering, he did not indicate the central bank was poised to engage in the sort of deep cutting cycle that the
Fed has done in the past to avert or offset recessions.
"It's not the beginning of a long series of rate cuts - I didn't say it's just one," Mr. Powell said at a news
conference following the Fed's two-day policy meeting. "What we're seeing is that it's appropriate to adjust
policy to a somewhat more accommodative stance over time, and that's how we're looking at it."
The widely expected move from the central bank was initially greeted with a shrug in financial markets, where
investors have been factoring in a rate cut for months. But the stock market turned lower after Mr. Powell began
his news conference at 2:30 p.m., as investors absorbed the chair's comments as indicating the Fed was unlikely
to make additional cuts anytime soon, as investors had hoped.
By the end of the day, the S&P 500 was down 1.1 percent. It was the benchmark index's worst decline since May
31.
The Fed dropped its target rate to a range between 2 percent to 2.25 percent. Officials also announced an early
end to its efforts to shrink the Fed's balance sheet, another attempt to keep the economy moving. The central
bank's holdings of government-backed bonds swelled during the financial crisis as it bought assets to try to
reinvigorate growth. Policymakers have been slowly siphoning off securities to return their balance sheet to a
more normal size, and that process was slated to end in September. It will now conclude Aug. 1.
Why the Federal Reserve Cut Interest Rates
The move is what's called an "insurance cut" - one that central bankers are making to keep growth chugging
along.
Both Eric Rosengren, the president of the Federal Reserve Bank of Boston, and Esther George, the president of
the Federal Reserve Bank of Kansas City, voted against Wednesday's decision, preferring instead to leave rates
unchanged. Those dissents marked the second and third of Jerome H. Powell's term as chair.
While Fed officials said they expect economic expansion to continue and the labor market to remain strong
"uncertainties about this outlook remain."
Mr. Powell said the Fed's move was "intended to insure against downside risks from weak global growth and
trade tensions."
He said that manufacturing around the world was weakening and that Mr. Trump's trade dispute was continuing
to spook American businesses. "The ongoing uncertainty is making some companies more cautious about their
capital spending," he said.
Officials did not indicate in their statement whether this cut would be followed by additional moves. The Fed's
June economic projections suggest policymakers envision cutting rates slightly to shore up the economy, rather
than beginning an easing cycle that will return rates to zero.
"As the committee contemplates the future path of the target range for the federal funds rate, it will continue to
monitor the implications of incoming information for the economic outlook and will act as appropriate to sustain
the expansion," the Fed said in its statement, seemingly leaving its options open.
Mr. Powell said the committee viewed the move as a "mid-cycle adjustment to policy," suggesting that the Fed
sees this cut as more similar to two instances in the 1990s, during which the Fed moved rates down slightly to
get the economy through periods of uncertainty, rather than the beginning of a rate-cutting campaign.
EFTA00018464

=== Page 25 ===
The Fed's rate cut carries political risks, given Mr. Trump's attacks on the central bank. Mr. Trump has been
denouncing the Fed in speeches and on Twitter for the past year, criticizing its four 2018 rate increases and
blaming its policies for slowing the American economy. Some onlookers may see Wednesday's move as caving
to the president.
The Fed operates independently of the White House. It attributed the change, which officials have been signaling
for months and which investors fully expected, to growing economic concerns.
"We also don't conduct monetary policy to prove our independence," Mr. Powell said.
The central bank is trying to extend a record-long economic expansion, because officials believe that doing so
will allow the Fed to achieve its goals of maximum employment and slow but steady inflation. The
unemployment rate is hovering around its lowest level in 50 years, but that has yet to push wages dramatically
higher in a way that forces companies to lift prices more quickly.
Inflation has run shy of the Fed's 2 percent goal since the central bank formally adopted it in 2012. A little
inflation helps to grease the wheels of a healthy economy, allowing businesses to raise wages faster and lifting
interest rates, giving the central bank more room to cut in the event of a downturn.
Prices picked up just 1.6 percent in the year through June, not counting volatile food and fuel costs.
Wages are growing only moderately. An index of employment costs climbed by 2.7 percent in the second quarter
from a year earlier, less than expected and a slowdown from earlier in 2019, according to data released on
Wednesday.
Global policy uncertainty has also increased, and manufacturing is slumping the world over. Growth is slowing
in China and Europe, and Mr. Trump's trade war with China and threats of further tariffs on United States trading
partners are stoking uncertainty and causing businesses to hold off on investment.
Those developments threaten the economic outlook, even as growth remains solid, consumer spending is robust
and the job market holds up for now.
EFTA00018465


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Cite-checked omnibus MOL
Date: Fri, 26 Feb 2021 16:04:05 +0000
Attachments: 2021.02.26_GM_Omnibus_Opposition_to_Defense_Motions.rd.docx
Team, truly excellent work on this.
and I split up our review, so I took pages 3-116 of the motion
sections), and
S reviewing the rest. Two items to note - I tried to change subsequent cites to string cites where I
caught them, but I wasn't reviewing closely for that, so make sure the paras are reviewing for that. Second, as I discussed
with
please take a look at the redactions in her section. I tried to conform them to the general principal that
redactions should apply to the subpoena and the ex parte proceeding, and un-redactions should apply to the description
of the article, her brief making general allegations, and our indictment. If that's not how you are envisioning the
redactions, happy to discuss.
Again, fantastic work. This is a very strong brief.
From:
Sent: Friday, February 26, 2021 4:08 AM
To:
Cc:
Subject: Cite-checked omnibus MOL
Attached please find the cite-checked omnibus memorandum of law in opposition to Maxwell's motions. The team will be
working with the paralegals tomorrow to proofread (which will include cleaning up the TOA), get out the discovery that
we reference in the MOL, and deal with redactions before filing. You'll see that we have highlighted portions that we
tentatively expect to redact in green.
Thanks,
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=== Page 1 ===
Event: Accepted: Call w/ Andy Tomback and Marc Weinstein (Epstein estate)
Start Date: 2021-04-05 19:30:00 +0000
End Date: 2021-04-05 20:00:00 +0000
Location:
1996301807##
Class: X-PERSONAL
Comment:
Date Created: 2021-03-31 18:36:13 +0000
Date Modified: 2021-03-31 18:36:13 +0000
Priority: 5
DTSTAMP: 2021-03-31 18:17:20 +0000
Attendee:
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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: September 8, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No: 20 Cr. 330 (AJN)
USAO No: 2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must exactly
match the witness's driver's license or other travel ID or TSA will not permit the witness to fly.)
Witness Address:
Witness TelNos (
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: September 30, 2021
Time: 10 AM
Witness Needed to Appear for:
Trial ( )
Date:
Grand Jury ( )
Date:
Trial Prep (X)
Date: September 30, 2021 at 10 a.m., October 1, 2021 at 10 a.m.
Estimated Dates Witness will Arrive:
September 29, 2021 (any time)
Depart:
October 1, 2021 (late afternoon/evening)
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Yes
Current Federal Civilian or Military Employee?
(Yes/No):
No
Is the Witness Facing Criminal Charges?
(Yes/No):
No
Does the Witness Reside Outside the Continental United States?
(Yes/No):
No
Is this Witness a Victim-Witness?
(Yes/No):
No
Hotel Required?
(Yes/No):
Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No):
No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
kennel fees for pets
rev. 2019.11.19
EFTA00017865

=== Page 2 ===
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: TC with USM re Epstein
Date: Mon, 19 Aug 2019 19:48:34 +0000
I spoke with
There is no "suicidal tendencies" form that the USM have or would have made Epstein sign.
She reviewed USM's entire Epstein file and other than the standard intake documents, it contained copies of his DL and
insurance cards and credit card. There were no other forms.
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject: RE: Jane Doe 43 V. Epstein, et al., 17 Civ. 616 (JGK)(SN)
Date: Thu, 14 Mar 2019 18:56:17 +0000
Importance: Normal
Attachments: 2019-03-14,_JE,_unsealing_proposed_order_(as_submitted_2019-02-05).docx
I,
Yes of course - please see the attached, and please let me know if any additional information would be useful.
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Thursday, March 14, 2019 14:29
To:
Subject: Jane Doe 43 V. Epstein, et al., 17 Civ. 616 (JGK)(SN)
Mr.
Judge Netburn was wondering if you have a Word version of the Sealed Order that you can email?
Let me know when you get the chance.
Thank you,
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Thu, 29 Nov 2018 19:13:01 +0000
Importance: Normal
And here's the non-pros:
https://www.scribd.com/document/342637849/Acosta-Epstein
From:
Sent: Thursday, November 29, 2018 2:13 PM
To:
Cc
Subject: Epstein
Here's the article:
https://www.miamiherald.com/news/local/article220097825.html
Sent from my iPhone
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=== Page 1 ===
From:
"
)"
To:
)"
Cc:
)"
,
)"
"
,
(NY) (FBI)"
Subject: RE: Subpoena Revised-
Date: Mon, 07 Oct 2019 21:48:54 +0000
Attachments: 2019-10-07,_subpoena_to
pdf
Subpoena attached, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Original Message
From:
)
Sent: Monday, October 7, 2019 4:52 PM
To:
)
Subject: FW: Subpoena Revised-
Maurene,
Please use the original rider I sent you (which is attached).
Sorry for the confusion.
Best
Original Message
From:
)
Sent: Monday, October 07, 2019 4:47 PM
To:
i
Cc:
(NY) (FBI)
Subject: RE: Subpoena Revised-
Please use the attached rider. I was able to find an account number.
Thanks
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=== Page 2 ===
Original Message
From:
)
Sent: Monday, October 07, 2019 2:59 PM
To:
Cc:
(NY) (FBI)
Subject: Subpoena -
Please prepare and return to me a subpoena for CapitalOne regarding
I have attached the rider for
the subpoena. I will serve the subpoena.
Additionally, please utilize the following text in the subpoena:
If you have any questions, please contact Forensic Accountant
at
(
).
Please forward the results in an electronic format to Special Agen
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
If you have any questions or comments, please contact me.
Thanks
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
EFTA00019745


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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019032.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Thu, 25 Mar 2021 20:32:09 +0000
Hi
-
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
EFTA00019032

=== Page 2 ===
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
EFTA00019033

=== Page 3 ===
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
EFTA00019034

=== Page 4 ===
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
EFTA00019035

=== Page 5 ===
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
EFTA00019036

=== Page 6 ===
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00019037

=== Page 7 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com> "Donnini, George B." <donnini@butzel.com>
Cc:
)"
>,
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best,
EFTA00019038

=== Page 8 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
EFTA00019039

=== Page 9 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00019040


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c7: images
c0:
=== Page 1 ===
From:
Subject: RE:
Date: Thu, 15 Aug 2019 18:08:08 +0000
Safe Horizon has two people that WILL GIVE SUPPORT AND COUNSELING TO Epstein Victims.
Victoria Dexter (VP, Mental Health Treatment) and Sherri Papamihalis (Clinical Director - Counseling Center.) Our
Counseling Center has available slots, so perhaps you guys can all connect and see if that would be the right fit for the
victims in the Epstein case. Thanks! Sherri phone number is 718 9286914
I hope this helps. I know she is in Florida but thought if anyone else asks you this is a great resource.
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
From:
Subject: RE:
Yes we will reach out. Thanks.
On Aug 15, 2019 1:49 PM,
wrote:
Thanks
I'm cc'ing
would you be able to please reach out to
?
From:
Subject:
EFTA00019821

=== Page 2 ===
She called and said " hey I am in Palm beach and need counseling."
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
EFTA00019822


c1: EFTA00020167
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=== Page 1 ===
Citibank N.A.
Legal Services Intake Unit
701 East 60th Street North
Sioux Falls, SD 57117
Fax: 347-809-6937
Attention: Legal Intake Unit
Delivered via: FedEx
Rider
ALL OPEN AND CLOSED ACCOUNTS
Please provide all images of documents in Adobe PDF files on CDs.
Please provide from account inception to present any and records pertaining to the following
accounts(s)/organization(s)/individuals(s) whether held jointly or severally or as trustee or fiduciary as
well as custodian, executor or guardian:
A. Please use the following identifiers:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBERS:
EFTA00020167

=== Page 2 ===
B. Records to be produced should include but are not limited to the items listed below:
1. DATA TRANSACTION FILES
2. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting additions
and/or subtractions to the account and how the account balances are being satisfied on a monthly
basis;
3. Signature cards;
4. Proof of identification (including but not limited to copies of identification used to open the
account);
5. Opening account(s) documents with attachments, including any and all applications, internal
documents generated to open account(s), and identification information or other documentation
provided by Customer; and Customer's email address
6. "Know your customer" documentation;
7. Wire transfer records (incoming and outgoing, and any and all applications and instructions);
8. Safe deposit records, including applications, signature cards, and sign-in records;
9. Trust accounts;
10. Monthly statements;
11. Credit card statements;
12. Bank, travelers, or cashier checks drawn on account or purchased with an account check;
13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks;
14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports,
applications, and payments made on loans;
15. Online banking information- All information regarding the electronic use of banking systems to
include the following: username, registration IP address, online account creation date, online
account status and IP logs/history, MAC addresses and online session times and duration;
16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or
partnership agreements; and
17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text
messages, that reference or concern items (1) through (16), above, and/or any financial interests
involving the individuals and/or entities identified in Section A.
If you have any questions or comments, please contact
Forensic Accountant, a
EFTA00020168


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 Page 1 of 3
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 7/30/2020
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
MEMORANDUM
Defendant.
OPINION & ORDER
ALISON J. NATHAN, District Judge:
Both parties have asked for the Court to enter a protective order. While they agree on
most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language
allowing her to publicly reference alleged victims or witnesses who have spoken on the public
record to the media or in public fora, or in litigation relating to Ms. Maxwell or Jeffrey Epstein.
Second, Ms. Maxwell seeks language restricting potential Government witnesses and their
counsel from using discovery materials for any purpose other than preparing for the criminal trial
in this action. The Government has proposed contrary language on both of these issues. For the
following reasons, the Court adopts the Government's proposed protective order.
Under Federal Rule of Criminal Procedure 16(d)(1), "[a]t any time the court may, for
good cause, deny, restrict, or defer discovery or inspection, or grant other appropriate relief."
The good cause standard "requires courts to balance several interests, including whether
dissemination of the discovery materials inflicts hazard to others
whether
the
imposition
of
the protective order would prejudice the defendant," and "the public's interest in the
information." United States V. Smith, 985 F. Supp. 2d 506, 522 (S.D.N.Y. 2013). The party
seeking to restrict disclosure bears the burden of showing good cause. Cf. Gambale V. Deutsche
Bank AG, 377 F.3d 133, 142 (2d Cir. 2004).
1
EFTA00018562

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 Page 2 of 3
First, the Court finds that the Government has met its burden of showing good cause with
regard to restricting the ability of Ms. Maxwell to publicly reference alleged victims and
witnesses other than those who have publicly identified themselves in this litigation. As a
general matter, it is undisputed that there is a strong and specific interest in protecting the
privacy of alleged victims and witnesses in this case that supports restricting the disclosure of
their identities. Dkt. No. 29 at 3 (acknowledging that as a baseline the protective order should
"prohibit[] Ms. Maxwell, defense counsel, and others on the defense team from disclosing or
disseminating the identity of any alleged victim or potential witness referenced in the discovery
materials"); see also United States V. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at
*11 (S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished for
individuals who have spoken on the public record about Ms. Maxwell or Jeffrey Epstein, because
they have voluntarily chosen to identify themselves. But not all accusations or public statements
are equal. Deciding to participate in or contribute to a criminal investigation or prosecution is a
far different matter than simply making a public statement "relating to" Ms. Maxwell or Jeffrey
Epstein, particularly since such a statement might have occurred decades ago and have no
relevance to the charges in this case. These individuals still maintain a significant privacy
interest that must be safeguarded. The exception the Defense seeks is too broad and risks
undermining the protections of the privacy of witnesses and alleged victims that is required by
law. In contrast, the Government's proffered language would allow Ms. Maxwell to publicly
reference individuals who have spoken by name on the record in this case. It also allows the
Defense to "referenc[e] the identities of individuals they believe may be relevant to Potential
Defense Witnesses and their counsel during the course of the investigation and preparation of the
defense case at trial." Dkt. No. 33-1, " 5. This proposal adequately balances the interests at
2
EFTA00018563

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 Page 3 of 3
stake. And as the Government's letter notes, see Dkt. No. 33 at 4, to the extent that the Defense
needs an exception to the protective order for a specific investigative purpose, they can make
applications to the Court on a case-by-case basis.
Second, restrictions on the ability of potential witnesses and their counsel to use
discovery materials for purposes other than preparing for trial in this case are unwarranted. The
request appears unprecedented despite the fact that there have been many high-profile criminal
matters that had related civil litigation. The Government labors under many restrictions
including Rule 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and
other policies of the Department of Justice and the U.S. Attorney's Office for the Southern
District of New York, all of which the Court expects the Government to scrupulously follow.
Furthermore, the Government indicates that it will likely only provide potential witnesses with
materials that those witnesses already have in their possession. See Dkt. No. 33 at 6. And of
course, those witnesses who do testify at trial would be subject to examination on the record as to
what materials were provided or shown to them by the Government. Nothing in the Defense's
papers explains how its unprecedented proposed restriction is somehow necessary to ensure a
fair trial.
For the foregoing reasons, the Court adopts the Government's proposed protective order,
which will be entered on the docket.
This resolves Dkt. No. 29.
so ORDERED.
Dated: July 30, 2020
New York, New York
Alim D.Nitto
ALISON J. NATHAN
United States District Judge
3
EFTA00018564


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c0:
=== Page 1 ===
From:
To:
Subject: RE: US V Epstein
Date: Sun, 18 Aug 2019 02:16:08 +0000
It's just outrageous.
From:
Sent: Saturday, August 17, 2019 22:15
To:
Subject: Re: US V Epstein
Boils my blood
Sent from my iPhone
On Aug 17, 2019, at 10:03 PM,
wrote:
I don't believe it's public, or at least not that I could find anywhere. His attorneys just sent it to us.
From:
Sent: Saturday, August 17, 2019 22:02
To:
Cc:
is
is
Subject: Re: US V Epstein
That is incredible. This is a public document?
Sent from my iPhone
On Aug 17, 2019, at 9:50 PM,
wrote:
It's extremely notable that his attorneys are talking about how they're not satisfied with the medical examiner's
conclusion that his death was by suicide when they know full well, as reflected in the attached, that he updated his will
the day before he died. (He also appears to have reorganized the structure of his assets also on August 8 - see the
references to the "1953 Trust" apparently established on that date; note that 1953 is the year he was born.)
In terms of other useful information, for all the cloak and dagger about who the executor was, it turns out it's his two
main lawyers, Indyke and Kahn, who handle virtually all of his business activities (and of whom we were already well
aware). It appears that those executors have the ability to deal with claims against the estate or its assets.
As for where his assets actually go, it all goes to the "acting Trustees of the 1953 Trust" - i.e., nobody is named herein.
From:
Sent: Saturday, August 17, 2019 14:20
To:
Cc:
is
is
EFTA00019322

=== Page 2 ===
Subject: RE: US V Epstein
Sure - I just emailed them to ask.
From:
Sent: Saturday, August 17, 2019 14:17
To:
Cc:
is
is
Subject: Re: US V Epstein
Can we ask for copies?
Sent from my iPhone
On Aug 17, 2019, at 2:08 PM,
wrote:
FYI below, re: probating the estate. Based on a quick search I don't see any place where a probate petition would be
publicly filed, though entirely possible it's somewhere I couldn't find.
From: Martin G. Weinberg
Sent: Friday, August 16, 2019 08:30
To:
is
>;
>; 'Martin G. Weinberg'
>; 'Michael Miller'
Subject: US V Epstein
during our telephone conversation yesterday you asked for information regarding the status of the
estate. Yesterday in the Virgin Islands there was a fiing of a Petition to Probate the Epstein Estate and Will.
Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law
Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the
addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use
of the contents of this message is prohibited.
<Probate Petition and Will_pdf>
EFTA00019323


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c0:
=== Page 1 ===
From:
To:
Subject: MOI-
2019-010614.pdf
Date: Tue, 01 Oct 2019 15:55:02 +0000
Attachments: MOI-
2019-010614.pdf
Please find the signed report attached for the interview of
I will also upload the report into iManage. Let me know how you want me to get the notes to you.
Thanks in advance.
V/R,
EFTA00019743


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: Time sensitive RE: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Sat, 20 Nov 2021 21:36:45 +0000
Attachments: 2021.11.20_MDC - Maxwell_PASSWORD.pdf
It is possible to upload the Rule 16 production except for SDNY_GM_02774100-SDNY_GM_02774104. I have uploaded it
to USAfx in the same folder as the USAfx production folder shared with defense counsel earlier today (so they have access
to it but you should flag that it's been added since the GX and 3500 was produced).
FedEx tracking for drive to CO: 8166 1429 9380
FedEx tracking for drive to MDC: 8166 1445 3318
FedEx tracking for pw to MDC: 8166 1445 3307
Drive for
is done and l'll leave for pick up on my way out momentarily.
Pw cover letter is attached if you want to send to
in case for some reason the pw arrives a day later like it did one
other time.
From:
(USANYS)
Sent: Saturday, November 20, 2021 4:06 PM
To:
(USANYS) [Contractor]
Cc:
is
)
is
)
Subject: Re: Time sensitive RE: US V. Maxwell, 20 Cr. 330 (AJN)
Thanks very much. When you have a chance, please send me the tracking number for Maxwell at the MDC, and for
Colorado. (I think we have to send that to defense counsel). I will also let
know when the drive is ready for pickup,
just let me know. Do you think there are materials we can share via USAfx from the discovery?
On Nov 20, 2021, at 4:02 PM,
(USANYS) [Contractor]
wrote:
I conferred W
and ran to make the 4pm pick up for FedEx. One drive was sent to CO to Laura and the other to
MDC W pw under separate cover. I'll load one of the drives dropped off today for
and leave it W the CSOs for pick
up.
Sent from my iPhone
On Nov 20, 2021, at 3:59 PM,
(USANYS)
wrote:
Hi - sorry I was tied up from 3-4 and just seeing this. Is there anything that we can share via USAfx since we can't make
the 4 pm deadline? In other words, can we produce most of the production via USAfx and just tell them we can't
produce materials with certain bates ranges given the size?
EFTA00019454

=== Page 2 ===
On Nov 20, 2021, at 3:38 PM,
(USANYS) [Contractor]
wrote:
Hi, I just called FedEx to confirm their last pick up time, and it is actually 4pm today since it is a weekend (I thought it
was 6pm). Would it be possible for one of you to give defense counsel a call to ask if they want it sent via FedEx
today? Would need to run it over to FedEx in like 10 minutes if so. So sorry for the firedrill, I thought since pick up
was 6pm on the last few federal holidays it would be the same on Saturdays.
From:
(USANYS)
Sent: Saturday, November 20, 2021 2:53 PM
To:
;
>; Laura Menninger
>; Jeff Pagliuca
Cc:
is
>;
is
(USANYS) [Contractor]
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Counsel,
We have an additional discovery production ready to send to you. Attached please find the accompanying cover
letter. That will be produced on a hard drive to you. In addition, a supplemental production of testifying witness and
non-testifying witness material and exhibits are also ready to send to you. Attached please find the accompanying
cover letter and indices. Those materials will be on the hard drive as well. We will also produce the testifying
witness and non-testifying witness material and exhibits via USAfx.
Please let us know if you would like to pick up the drive today or if you would like us to FedEx it (and if so, to where).
Please let us know if you would like us to send today via FedEx a hard drive with these materials to Ms. Maxwell at
the MDC or bring the hard drive to court on Tuesday.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00019455


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=== Page 1 ===
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
)
Ghislaine V Maxwell
)
)
Case No. 20CR330 (AJN)
)
Defendant
)
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR
OBJECTS IN A CRIMINAL CASE
To: Jordana Feldman
(Name of person to whom this subpoena is directed)
YOU ARE COMMANDED to produce at the time, date, and place set forth below the following books, papers,
documents, data, or other objects:
See Attachment A
Place: United States District Court
Date and Time:
11/29/2021 8:30 am
Southern District of New York, Courtroom 318
40 Foley Square, New York, NY 10007
Certain provisions of Fed. R. Crim. P. 17 are attached, including Rule 17(c)(2), relating to your ability to file a
motion to quash or modify the subpoena; Rule 17(d) and (e), which govern service of subpoenas; and Rule 17(g),
relating to your duty to respond to this subpoena and the potential consequences of not doing so.
(SEAL)
Date:
CLERK OF COURT
Signature of Clerk or Deputy Clerk
The name, address, e-mail, and telephone number of the attorney representing (name of party)
Ghislaine Maxwell
, who requests this subpoena, are:
Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203,
Notice to those who use this form to request a subpoena
Before requesting and serving a subpoena pursuant to Fed. R. Crim. P. 17(c), the party seeking the subpoena is advised to
consult the rules of practice of the court in which the criminal proceeding is pending to determine whether any local rules
or orders establish requirements in connection with the issuance of such a subpoena. If no local rules or orders govern
practice under Rule 17(c), counsel should ask the assigned judge whether the court regulates practice under Rule 17(c) to
1) require prior judicial approval for the issuance of the subpoena, either on notice or ex parte; 2) specify where the
documents must be returned (e.g., to the court clerk, the chambers of the assigned judge, or counsel's office); and 3)
require that counsel who receives produced documents provide them to opposing counsel absent a disclosure obligation
under Fed. R. Crim. P. 16.
Please note that Rule 17(c) (attached) provides that a subpoena for the production of certain information about a victim
may not be issued unless first approved by separate court order.
EFTA00018214

=== Page 2 ===
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)
Case No. 20CR330 (AJN)
PROOF OF SERVICE
This subpoena for (name of individual and title, if any)
was received by me on (date)
.
I served the subpoena by delivering a copy to the named person as follows:
on (date)
; or
I returned the subpoena unexecuted because:
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
$
My fees are $
for travel and $
for services, for a total of $
0.00
I declare under penalty of perjury that this information is true.
Date:
Server's signature
Printed name and title
Server's address
Additional information regarding attempted service, etc.:
Print
Save As...
Add Attachment
Reset
EFTA00018215

=== Page 3 ===
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure 17 (c), (d), (e), and (g) (Effective 12/1/08)
(c) Producing Documents and Objects.
(1) In General. A subpoena may order the witness to produce any books, papers, documents, data, or other objects the subpoena
designates. The court may direct the witness to produce the designated items in court before trial or before they are to be offered in
evidence. When the items arrive, the court may permit the parties and their attorneys to inspect all or part of them.
(2) Quashing or Modifying the Subpoena. On motion made promptly, the court may quash or modify the subpoena if compliance
would be unreasonable or oppressive.
(3) Subpoena for Personal or Confidential Information About a Victim. After a complaint, indictment, or information is filed, a
subpoena requiring the production of personal or confidential information about a victim may be served on a third party only by court
order. Before entering the order and unless there are exceptional circumstances, the court must require giving notice to the victim so that
the victim can move to quash or modify the subpoena or otherwise object.
(d) Service. A marshal, a deputy marshal, or any nonparty who is at least 18 years old may serve a subpoena. The server must deliver a copy
of the subpoena to the witness and must tender to the witness one day's witness-attendance fee and the legal mileage allowance. The server
need not tender the attendance fee or mileage allowance when the United States, a federal officer, or a federal agency has requested the
subpoena.
(e) Place of Service.
(1) In the United States. A subpoena requiring a witness to attend a hearing or trial may be served at any place within the United
States.
(2) In a Foreign Country. If the witness is in a foreign country, 28 U.S.C. $ 1783 governs the subpoena's service.
(g) Contempt. The court (other than a magistrate judge) may hold in contempt a witness who, without adequate excuse, disobeys a subpoena
issued by a federal court in that district. A magistrate judge may hold in contempt a witness who, without adequate excuse, disobeys a
subpoena issued by that magistrate judge as provided in 28 U.S.C. $ 636(e).
EFTA00018216

=== Page 4 ===
ATTACHMENT A
DEFINITIONS
1. "You" or "Your" means any owner, shareholder, partner or employee of the Epstein Victim's
Compensation Program ("EVCP"), and any former owner, shareholder, partner or employee
of the EVCP.
2. "Accusers" or "Accuser" means
and
3. Attorneys means legal counsel for any Accuser or the EVCP.
4. "Communication" means all forms of correspondence, including regular mail, email, text
message, memorandum, or other written communication of information of any kind.
5. "EVCP Material" refers to any submission to the Epstein Victim's Compensation Program
made by an Accuser, including any claims on behalf of persons who have accused Jeffrey
Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their
Attorneys, and any compensation received by an Accuser.
INSTRUCTIONS
1. Production of documents and items requested herein shall be made in person to United States
District Court, Southern District of New York, 40 Foley Square, New York, NY 10007,
Courtroom 318.
2. This Request calls for the production of all responsive Documents in Your possession,
custody or control without regard to the physical location of such documents.
3. If any Document was in your possession or control, but is no longer, state what disposition
was made of said Document, the reason for the disposition, and the date of such disposition.
4. In producing Documents, if the original of any Document cannot be located, a copy shall be
produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the
original.
5. Any copy of a Document that is not identical shall be considered a separate document.
6. All Documents shall be produced in the same order as they are kept or maintained by You in
the ordinary course of business.
7. Responsive electronically stored information (ESI) shall be produced in its native form; that
is, in the form in which the information was customarily created, used and stored by the
native application employed by the producing party in the ordinary course of business.
8. Defendant does not seek and does not require the production of multiple copies of identical
Documents.
9. This Request is deemed to be continuing. If, after producing these Documents, you obtain or
EFTA00018217

=== Page 5 ===
become aware of any further information, Documents, things, or information responsive to
this Request, you are required to so state by supplementing your responses and producing
such additional Documents to Defendant.
DOCUMENTS OR THINGS TO BE PRODUCED
1. Any and all EVCP Material submitted by each Accuser, not limited to Claim Forms and
supporting submissions made by each Accuser;
2. Communications between the EVCP to each of the Accusers and/ or their Attorneys;
3. Copies of any payments to the Accusers and their Attorneys;
4. Any and All Releases executed by the Accusers.
EFTA00018218


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein OCME
Date: Fri, 16 Aug 2019 18:49:06 +0000
Thanks for the update.
From:
(USANYS)
Sent: Friday, August 16, 2019 2:48 PM
To: Berman, Geoffrey (USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: Epstein OCME
The team has just learned from the City Medical Examiner that OCME has officially concluded Epstein's cause of death
was hanging and the manner of death was suicide.
OCME plans to issue a press release and the official death certificate indicating as much later this afternoon.
EFTA00018899


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "New Case ADDED"
Date: Mon, 29 Mar 2021 20:54:24 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 03/29/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
NEW CASE 21-770, on behalf of Ghislaine Maxwell, FILED.[3065988] [21-58]
Notice will be electronically mailed to:
Ms.
Mr.
Assistant U.S. Attorney:
managingclerksoffice@cohengresser.com
Assistant U.S. Attorney:
Assistant U.S. Attorney:
Ms. Bobbi C. Sternheim, -:
ecf@sternheimlaw.com
Notice will be stored in the notice cart for:
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: New Case ADDED
Original Filename: 21-770.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=03/29/2021] [FileNumber=3065988-0]
[670c2ef56fa125f90a4151319a0a4ad10ef2de972f6dc392e4c86f30d51b3a9240b9613bec9a407ab3bb4aa161b1a9
9a9c0808de1f4428883108589c5e26d000]]
EFTA00020425


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=== Page 1 ===
From: Bruce Marshall
To: Callie Meier
)"
Cc:
)"
X
(USANYS)"
>, , Suzanne Pruitt
Subject: [EXTERNAL] RE: Subpoena to AIC Title Part 4
Date: Mon, 11 Oct 2021 17:55:00 +0000
Attachments: N722JE - Order_44814_Part4.pdf
Inline-Images: image001.jpg
Bruce Marshall
EVP & General Counsel
AIC
TITLE SERVICE
AIC Title Service
Tel:
or
Fax:
f
in
www.aictitle.com
From: Bruce Marshall
Sent: Monday, October 11, 2021 12:54 PM
To: 'Callie Meier'
is
)'
Cc:
)'
>;
(USANYS)'
>; 'Suzanne
Pruitt'
Subject: RE: Subpoena to AIC Title Part 3
Bruce Marshall
EVP & General Counsel
AIC
TITLE SERVICE
AIC Title Service
Tel:
or
Fax:
f
in
www.aictitle.com
From: Bruce Marshall
Sent: Monday, October 11, 2021 12:52 PM
To: 'Callie Meier'
V.
)'
Cc:
)'
>;
(USANYS)'
>; 'Suzanne
Pruitt'
Subject: RE: Subpoena to AIC Title Part 2
EFTA00020095

=== Page 2 ===
Bruce Marshall
EVP & General Counsel
AIC
TITLE SERVICE
AIC Title Service
Tel:
or
Fax:
f
in
www.aictitle.com
From: Bruce Marshall
Sent: Monday, October 11, 2021 12:50 PM
To: 'Callie Meier'
is
)'
Cc:
)'
i
(USANYS)'
>; Suzanne
Pruitt
Subject: RE: Subpoena to AIC Title Part 1
I am sending the response in multiple files due to size.
Best Regards,
Bruce Marshall
EVP & General Counsel
AIC
TITLE SERVICE
AIC Title Service
Tel:
or
Fax:
f
in
www.aictitle.com
From: Callie Meier
Sent: Friday, October 8, 2021 2:15 PM
To:
)
Cc:
is
(USANYS)
V.
Subject: RE: Subpoena to AIC Title
Hi
I have completed the requested subpoena for N722JE and sent it to our general counsel for review. I should hear back
from him next week and will forward directly to you. Thank you and please contact me with any questions. Have a great
weekend.
The FAA and AIC will be closed Monday, 11 September in honor of Indigenous Peoples' Day.
AIC
Callie Meier
TITLE SERVICE
Document Specialist
f
in
EFTA00020096

=== Page 3 ===
AIC Title Service
Tel:
or
Fax:
www.aictitle.com
Ask me about Title Insurance for your aircraft!
From:
)
^
Sent: Thursday, September 30, 2021 2:13 PM
To:
Cc:
is
(USANYS)
Subject: Subpoena to AIC Title
Hi Callie,
Thank you again for the call this afternoon. Attached is the subpoena we discussed. Please feel free to give me a call if
you have any questions.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00020097


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=== Page 1 ===
From:
To:
Subject: Text messages 5
Date: Sat, 21 Dec 2019 14:34:40 +0000
Inline-Images: IMG_2435.jpg; IMG_2436.jpg
EFTA00018609

=== Page 2 ===
8:52
...
No SMS connection
Today
Ok
Thursday, Aug 8. 4:29 PM
Hi
how are you
doing? I'm reaching out
to you to see if you have
been bothered my the
media or others.
Saturday, Aug 10 . 10:36 AM
Hey, just on social media.
What a coward, if he's
really dead, or someone
probab
as was
Text
message
SMS

=== Page 3 ===
EFTA00018611

=== Page 4 ===
8:52
...
No SMS connection
been bothered my the
media or others.
Saturday, Aug 10
10:36
AM
Hey, just on social media.
What a coward, if he's
really dead, or someone
probably had him killed. He
was a very bad man
Sunday, Aug 11 8:37 AM
Yes I know. I spoke with
and she will let me
know the decision of the
civil case.
Aug 11, 8:37 AM SMS
Text
+
message
SMS

=== Page 5 ===
Sent from my iPhone
EFTA00018613


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=== Page 1 ===
Event: Accepted: Meet re: Epstein Investigation
Start Date: 2018-12-06 21:30:00 +0000
End Date: 2018-12-06 22:30:00 +0000
Organizer:
Location: Conference Room 646
Class: X-PERSONAL
Comment:
Date Created: 2018-12-05 00:29:43 +0000
Date Modified: 2018-12-05 00:29:43 +0000
Priority: 5
DTSTAMP: 2018-12-05 00:22:27 +0000
EFTA00019428


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=== Page 1 ===
From:
To:
Cc:
Subject: SDNY Opposition to Epstein Bail Motion
Date: Fri, 12 Jul 2019 21:29:13 +0000
Importance: Normal
Attachments:2019-07-12,_JE_government_opposition_to_bail_motion_(with_exhibits).pdf
Please see the attached.
Kind regards,
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00018268


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=== Page 1 ===
From: Bruce Barket
To:
Cc:
(USANYS"
"Aida Leisenring"
"
"
i
,
"
Subject: Re: Ex parte order
Date: Sat, 13 Jun 2020 10:42:31 +0000
Received. Thank you.
Bruce A. Barket
Barket, Epstein, Kearon, Aldea & LoTurco
On Jun 12, 2020, at 4:44 PM,
wrote:
Dear Defense Counsel and Firewall Counsel.
Attached, please find a brief ex parte order from Judge Karas. The same will be filed under seal.
--Chambers of Judge Karas
<16cr832_ex parte order.pdf>
EFTA00019111


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=== Page 1 ===
From: Alex Conlon
To:
, "Kate L.
Doniger"
Cc: Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
Date: Mon, 16 Dec 2019 15:55:47 +0000
Attachments: Epstein_November_21,_2019.pdf
Hi
Attached please see the transcript from the first appearance in front of Judge Freeman. On page 15 (lines 7-15), Robbie
mentions that she has been told that Mark Epstein is the beneficiary of the estate.
Thanks,
Alex
Alex Conlon I Kaplan Hecker & Fink LLP
From:
Sent: Friday, December 13, 2019 5:53 PM
To: Kate L. Doniger
Cc: Alex Conlon
>; ; Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
Received, thanks. And Alex, if you have the transcript from the prior proceeding before Judge Freeman, I'd be grateful if
you could send it, though no rush at all on that - anytime early next week would be totally fine.
From: Kate L. Doniger
Sent: Friday, December 13, 2019 17:12
To:
Cc: Alex Conlon
>; ; Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
Attached is the draft protocol we received from Feinberg and CO. Also attached are two documents the Estate filed in the
USVI today.
Kate
Kate L. Doniger I Kaplan Hecker & Fink LLP
1827
EFTA00019570

=== Page 2 ===
From: Roberta Kaplan
Sent: Friday, December 13, 2019 4:53 PM
To:
>; Alex Conlon
Cc: Kate L. Doniger
Subject: RE: Transcript from yesterday's conference
That is what Bennet Moskowitz said (I believe) at the earlier conference before M.J. Freeman
Alex: can you pls check the transcript? I know they have also said it to me directly and he certainly didn't disagree with
me when I said it before J Failla.
Also: we got the Feinberg draft protocol today; its exactly as much of a disaster as we expected.
Kate: psl send to
along with their recent VI filings.
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
From:
Sent: Friday, December 13, 2019 1:09 PM
To: Alex Conlon
>; Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
This is helpful and interesting, thanks very much for sending. Among other things, notable that Judge Failla assumes, even
were punitive damages to be excluded, a claim "for millions upon millions of dollars."
Separately, Robbie, I noticed near the end of the conference you mentioned, at p. 27, that: "They [the estate and/or the
trustees?] have identified the sole beneficiary as Mr. Epstein's brother." I'm wondering if you might have a recollection of
what the estate has said or represented to you about that? And if you recall whether any discussion of beneficiaries was
in connection with the will versus the trust versus the estate, etc. Just if you feel comfortable sharing any of that
information, of course-no obligation at all. And if it's more convenient to relay in real time, rather than drafting up an
email, please don't hesitate to give a call. No emergency or rush, but did want to ask.
thanks,
From: Alex Conlon
Sent: Thursday, December 12, 2019 18:34
To:
Cc: Roberta Kaplan
Subject: Transcript from yesterday's conference
Hi there,
Attached is the transcript from yesterday's conference that Robbie described in the call today.
Take care,
Alex
Alex Conlon I Kaplan Hecker & Fink LLP
EFTA00019571

=== Page 3 ===
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00019572


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Mon, 20 Sep 2021 15:26:13 +0000
Hi
Hope you're both doing well. We'd like to speak with both of you about the upcoming trial in this case. Could you please
let us know your availability for a call this week?
Thanks very much,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00017997


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
(USANYS)"
Cc:
"
(USANYS)"
Bcc:
"
Subject: RE: GM -- search warrant returns
Date: Tue, 20 Oct 2020 02:36:33 +0000
Embedded: RE:_GM__search_warrant_returns.msg
Sender:
Subject: RE: GM -- search warrant returns
Message-Id:
<SN5P110MB05420A89DD7BFA1EC9C5AA6A921F0@SN5P110MB0542.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
To:
Cc:
EFTA00017946


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=== Page 1 ===
From: Jason Foy
To:
Cc: Eric Sarraga
Subject: RE: US V. Noel
Date: Fri, 26 Feb 2021 21:09:26 +0000
Attachments: Tova_Cover_Page.pdf,Tova_Noel_Deferred_Prosecution_Submission_(Final).pdf;
Tova_Noel-_Exhibits.pdf
Here is the electronic copy. Please confirm receipt.
Jason
Jason E. Foy
FOY & SEPLOWITZ LLC
105 Main Street
Hackensack, NJ 07601
www.foyseplowitz.com
From:
Sent: Friday, February 26, 2021 3:58 PM
To:
; Jason Foy
Subject: RE: US V. Noel
Hi Jason,
Thanks for sending. Is there any way you could also send it to us digitally?
Thanks
From:
Sent: Friday, February 26, 2021 3:43 PM
To: Jason Foy
Cc:
Subject: RE: US V. Noel
Thanks Jason, l'll keep a look out. Have a nice weekend.
From: Jason Foy
Sent: Friday, February 26, 2021 3:42 PM
To:
EFTA00018834

=== Page 2 ===
Cc:
Subject: US V. Noel
,
Our deferred prosecution application has been sent via FedEx to the attention of IN
There are 5 copies in
total. I spoke with co-counsel today and he will have something to you next week. I did my best to give him my
recommendations on the proper approach. Let me know if you have any questions or concerns. Please send me an email
or give me a call when you receive our materials. Have a great weekend.
Jason
Jason E. Foy
FOY & SEPLOWITZ LLC
105 Main Street
Hackensack NJ 07601
EFTA00018835


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=== Page 1 ===
Case 19-2221, Document 18, 08/20/2019, 2637473, Page1 of 1
UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT
)
UNITED STATES OF AMERICA,
)
)
Plaintiff-Appellee,
)
Appeal No. 19-2221-cr
)
V.
)
)
JEFFREY EPSTEIN
)
)
Defendant-Appellant
)
)
IT IS HEREBY STIPULATED by counsel for Jeffery Epstein, Defendant-
Appellant, and the United States of America, Appellee, that, pursuant to Federal
Rule of Appellate Procedure 42, this appeal shall be dismissed with prejudice. The
parties understand and agree that, once dismissed, the appeal may not be reinstated.
IT IS FURTHER STIPULATED that neither party shall be entitled to
recover costs, expenses or fees from the other party.
EXECUTED on August 20, 2019.
/s/ Reid Weingarten
Reid Weingarten
Martin G. Weinberg
Counsel to Defendant- Appellant
Jeffrey Epstein
Alex An Rossmiller
Counsel to Appellee
United States of America
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=== Page 1 ===
From:
To:
Cc:
Subject: FW: [EXTERNAL] Re: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL,
FRIDAY, NOVEMBER 26, 2021
Date: Fri, 26 Nov 2021 15:18:39 +0000
Inline-Images: image001.png
We circulated Tuesday's guidance to some additional UK reporters this morning. The additional guidance we drafted on
Wednesday will go out shortly, we'll blind copy you.
From:
Sent: Friday, November 26, 2021 10:14 AM
To: Gadher, Dipesh <dipesh.gadher@sunday-times.co.uk>
Cc:
Subject: RE: [EXTERNAL] Re: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021
In accordance with the previously provided court order, any victim or witness testifying under a pseudonym should not
be identified, and should be referred to under their pseudonym, regardless of any previous identifications or waivers that
might have been made.
Best,
From: Gadher, Dipesh <dipesh.gadher@sunday-times.co.uk>
Sent: Friday, November 26, 2021 9:58 AM
To:
Subject: [EXTERNAL] Re: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021
Hi - can I please clarify if I'm allowed to identify
by name as she has previously waived her right to
anonymity? How will she be identified in future proceedings? Thanks.
Best
Dipesh
The Sunday Times
1 London Bridge Street
London SE1 9GF
Tel: +44 (0)20 7782 5745
Mob: +44 (0)7956 142 227
On Fri, 26 Nov 2021 at 14:48
wrote:
EFTA00019461

=== Page 2 ===
In order meet the demand for the high volume of media requests we are already receiving, the following guidance is
being provided in advance of the trial to ensure efficient communications. Please take careful note.
OF JUSTICE QUI PRO SUBTOTAL
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
OF
PRESS GUIDANCE
Friday, November 26, 2021
*OFF-THE-RECORD, AND FOR GUIDANCE ONLY: Several of the government's anticipated witnesses will be testifying in
this trial using a pseudonym or first name. The Court granted a Government motion [attached] requesting that they
be able to do so, because the victim witnesses are expected to describe alleged sensitive, explicit and personal events
concerning illegal sexual abuse, sexual contact and other acts of which they have been victims. I believe most, if not
all, news media outlets have a policy against identifying sex crime victims without their consent, and urge you to
abide by that policy with our witnesses and respect their privacy.
9:30 a.m. - Final pretrial conference U.S. V. Ghislaine Maxwell - the defendant is charged in connection to conspiring
with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity - before Judge Alison Nathan
(Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S.
Courthouse]).
EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share. If you are unable to access
this link to the file share (USAFx), you must establish an account to access the files. To establish an account, request
access by email to me or my colleague, Jim Margolin, Cc'd here, prior to Wednesday, November 29, 2021.
Please also note that all case filings in U.S. V. Maxwell are available in the Court's electronic filing system; we encourage
media representatives to establish a free PACER account, if they have not done so already. Credentialing and other
matters relating to in-person attendance for the trial are handled by the SDNY District Executive's Office.
Periodic updates to follow.
Follow us on Facebook I Follow us on Twitter I SDNY website YouTube
FOR PLANNING PURPOSES ONLY
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE AT (212) 637-2600.
"Please consider the environment before printing this e-mail"
This e-mail and any attachments are confidential, may be
legally privileged and are the property of News Corp UK & Ireland
Limited on whose systems they were generated. News Corp UK
EFTA00019462

=== Page 3 ===
& Ireland Limited is the holding company for the News UK group,
is registered in England & Wales under number 81701, has its
registered office at 1 London Bridge Street, London, SE1 9GF and
is registered with VAT number GB 243 8054 69. If you have received
this e-mail in error, please notify the sender immediately and do not
use, distribute, store or copy it in any way. Statements or opinions in
this e-mail or any attachment are those of the author and are not
necessarily agreed or authorised by News Corp UK & Ireland Limited
or any member of its group. News Corp UK & Ireland Limited may
monitor outgoing or incoming emails as permitted by law. It accepts
no liability for viruses introduced by this e-mail or attachments.
News Corp UK & Ireland Limited and its titles are committed to abiding by
IPSO's regulations and the Editors' Code of Practice that IPSO enforces.
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=== Page 1 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No. 20 MAG 6719
2 electronic devices seized on July 6, 2019 from Jeffrey Epstein;
)
33 electronic devices seized on July 11, 2019 from 9 East 71st
)
Street, New York, NY; 27 electronic devices seized on August 12, 2019
from Little Saint James in the Virgin Islands
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
18 U.S.C. 1591; 18 U.S.C. 2422; 18 USC 2423; 18 U.S.C. 371
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
30 days (not to exceed 30).
Juntil, the facts justifying, the later specific date of
Date and time issued: 6/26/2020 9:11 am
Judge's signature
City and state:
New York, NY
Hon. Gabriel W. Gorenstein, U.S. Magistrate Judge
Printed name and title
EFTA00018586

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
20 MAG 6719
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00018587

=== Page 3 ===
Attachment A
I. Devices Subject to Search and Seizure
The devices that are the subject of this search and seizure warrant (the "Subject Devices")
are described as follows:
Two of the Subject Devices were seized from JEFFREY EPSTEIN's person during the
course of his arrest by the FBI on or about July 6, 2020 (the "Arrest Subject Devices"). The Arrest
Subject Devices are particularly described as follows:
a. A silver iPad with serial number DLXQGM3KGMW3 ("Subject Device-1"); and
b. A black iPhone with IMEI number 357201093322785 ("Subject Device-2").
33 of the Subject Devices were recovered from a search of JEFFREY EPSTEIN's private
residence located at 9 East 71st Street, New York, New York, which took place on July 11, 2019
(the "New York Subject Devices"). The New York Subject Devices are particularly described as
follows:
a. Two black hard drives, which were seized by Special Agent Kelly Maguire from a
blue suitcase on or about July 11, 2019 ("Subject Device-3");
b. An Apple desktop computer, which was seized from in a cardboard box along the
right wall of a room on the first floor of the New York Residence, and which has
been assigned internal FBI barcode number E6515034 ("Subject Device-4");
c. A silver iPad, which was seized from a shelf in the right corner of a room on the
third floor of the New York Residence under a television, and which has been
assigned internal FBI barcode number E6515033 ("Subject Device-5");
d. A gray Apple iPad, which was seized from under a sink in a room on the third floor
of the New York Residence, and which has been assigned internal FBI barcode
number E6515032 ("Subject Device-6");
e. A gray Apple iPad, which was seized from under a sink in a room on the third floor
of the New York Residence, and which has been assigned internal FBI barcode
number E6515031 ("Subject Device-7");
f. A Sony Vaio laptop, which was seized from inside a desk drawer in the drawing
room on the second floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515026 ("Subject Device-8");
g. A Dell Precision Tower 5810, which was seized from a storage area in the basement
of the New York Residence, and which has been assigned internal FBI barcode
number E6515025 ("Subject Device-9");
2017.08.02
EFTA00018588

=== Page 4 ===
h. A Seagate Barracuda 7200 hard drive, which was seized from a storage area in the
basement of the New York Residence, and which has been assigned internal FBI
barcode number E6515024 ("Subject Device-10");
i. A MSI PC Computer, which was seized from a storage area in the basement of the
New York Residence, and which has been assigned internal FBI barcode number
E6515023 ("Subject Device-11");
j. A Sony Camera with a black case, which was seized from in a drawer inside a room
on the sixth floor of the New York Residence, and which has been assigned internal
FBI barcode number E6515022 ("Subject Device-12");
k. A gray Apple desktop computer, which was seized from a desk inside a room on
the sixth floor of the New York Residence, and which has been assigned internal
FBI barcode number E6515021 ("Subject Device-13");
1. A Seagate Backup Plus portable drive, which was seized from a shoebox on top of
a desk in a room on the fifth floor of the New York Residence, and which has been
assigned internal FBI barcode number E6515020 ("Subject Device-14");
m. A white Apple iPhone 5, which was seized from the lower left shelf of a white
wooden cabinet in a room on the fifth floor of the New York Residence, and which
has been assigned internal FBI barcode number E6515019 ("Subject Device-15");
n. An Apple desktop computer, which was seized from on top of a desk inside the
drawing room on the second floor of the New York residence, and which has been
assigned internal FBI barcode number E6515018 ("Subject Device-16");
O. An Apple desktop computer, which was seized from on top of a desk in a room on
the fifth floor of the New York Residence, and which has been assigned internal
FBI barcode number E6515017 ("Subject Device-17");
p. A SPIEF 2014 silver USB, which was seized from a cabinet on the back wall of a
storage closet on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6515016 ("Subject Device-18");
q. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515015 ("Subject Device-19");
r. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515014 ("Subject Device-20");
2
2017.08.02
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=== Page 5 ===
S. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515013 ("Subject Device-21");
t. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515012 ("Subject Device-22");
u. A blue EMTEC USB, which was seized from a small tray on the floor of the dining
room on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515011 ("Subject Device-23");
V. An EMTEC USB, which was seized from a small tray on the floor of the dining
room on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515010 ("Subject Device-24");
W. A silicone power micro SD adaptor, which was seized from a drawer inside a table
in the dining room on the First Floor of the New York Residence, and which has
been assigned internal FBI barcode number E6515008 ("Subject Device-25");
X. A DELL Machine, which was seized from a desk in a room on the first floor of the
New York Residence, and which has been assigned internal FBI barcode number
E6515007 ("Subject Device-26");
y. A Cube 9000 Siteserver, which was seized from a desk in a room on the first floor
of the New York Residence, and which has been assigned internal FBI barcode
number E6515006 ("Subject Device-27");
z. An HP Compaq Machine, which was seized from a desk in a room on the first floor
of the New York Residence, and which has been assigned internal FBI barcode
number E6515005 ("Subject Device-28");
aa. A Mentor Media USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E6515004 ("Subject Device-29");
bb. A Data Traveler USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E6515003 ("Subject Device-30");
cc. A Data Traveler USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E6515002 ("Subject Device-31");
3
2017.08.02
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=== Page 6 ===
dd. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6515001 ("Subject Device-32");
ee. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6515000 ("Subject Device-33");
ff. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433827 ("Subject Device-34"); and
gg. A silver Apple desktop computer, which was seized from a desk in an oval study
on the first floor of the New York Residence, and which has been assigned internal
FBI barcode number E6433828 ("Subject Device-35").
27 of the Subject Devices were recovered from a search of a private island in the U.S.
Virgin Islands, known as Little Saint James, which is an approximately 75 acre island located
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands
Residence") on or about August 12, 2019 (the "Virgin Islands Subject Devices"). The Virgin
Islands Residence consists of multiple structures, including a main residence as well as several
other smaller structures on the island, including a pool house, sheds, a beach house, an office, and
multiple cabanas. The Virgin Islands Subject Devices are particularly described as follows:
a. A gray Mac desktop computer labeled "kitchen mac," which was recovered from a desk
in the main residence on the island ("Subject Device-36");
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89111772QT,
which was recovered from a desk in the main residence on the island ("Subject Device-
37");
c. A silver MacBook Pro bearing serial number c02qm0gugwdp, which was recovered
from a desk in the main residence on the island ("Subject Device-38");
d. A silver iPad model A1567 bearing serial number dmpql25ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-39");
e. A silver iPad model A1567 bearing serial number dmpqL1rmg5y, which was recovered
from a desk in the main residence ("Subject Device-40");
f. A silver Mac desktop computer bearing serial number c02nm1m0fy14, which was
recovered from a desk in the pool house on the island ("Subject Device-41");
g. A silver Mac desktop computer, which was recovered from a desk in a cabana on the
island ("Subject Device-42");
4
2017.08.02
EFTA00018591

=== Page 7 ===
h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a shed
on the island ("Subject Device-43");
i. An HP laptop bearing serial number cnd81368v5, which was recovered from a desk in
a shed on the island ("Subject Device-44");
j. A silver Mac desktop computer, which was recovered from a desk in a cabana on the
island ("Subject Device-45");
k. A silver Macbook desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-46");
1. A Dell Inspiron Tower computer model D19M QCNFA335, which was recovered from
a desk in the beach house on the island ("Subject Device-47");
m. A silver Mac desktop computer model A1311 bearing serial number W804736DDAS,
which was recovered from a desk in the beach house on the island ("Subject Device-
48");
n. A Unfi video bearing mac ID 1829fb4fbe426ea90, which was recovered from a server
rack inside a shed on the island ("Subject Device-49");
O. A Unifi Server bearing mac ID 1735K 788A20463234-8uuu9f, which was recovered
from a server rack inside a shed in on the island ("Subject Device-50");
p. An HP server with four 500 GB drives, bearing serial number MXQ3220187, which
was recovered from a shed on the island ("Subject Device-51");
q. A Panasonic KX TDE100 computer bearing serial number KX-TDa0104
9LCCD005398, which was found on a server rack in a shed on the island ("Subject
Device-52");
r. A 6 bay with 146 GB drives bearing serial number MXQ824A1R, which was found on
a server rack in a shed on the island ("Subject Device-53");
S. A silver Mac desktop computer, which was recovered from a desk in a cabana on the
island ("Subject Device-54");
t. An HP desktop tower model 260-A010, bearing serial number cnv7160050, which was
recovered from the maintenance office on the island ("Subject Device-55");
u. An HP tower model 260-A010, bearing serial number cnv716004y, which was
recovered from the maintenance office on the island ("Subject Device-56");
V. A Mac desktop computer model A1312, bearing serial number w89524czspj, which
was recovered from the maintenance office on the island ("Subject Device-57");
5
2017.08.02
EFTA00018592

=== Page 8 ===
W. A Lenovo tower machine type 90J0, bearing serial number mj07yg6u, which was
recovered the maintenance office on the island ("Subject Device-58");
X. A Lenovo tower bearing serial number 153306g2umjxekgx, which was recovered the
maintenance office on the island ("Subject Device-59");
y. An HP Tower bearing serial number CNV74213M3 570-P056, which was recovered
the maintenance office on the island ("Subject Device-60");
z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID
1843kb4fbe4d30c69-dcrgm9, which was found on a server rack in a shed on the island
("Subject Device-61"); and
aa. A red Nikon digital camera, which was recovered on a file cabinet next to a desk in a
cabana on the island ("Subject Device-62").
II. Review of ESI on the Subject Devices
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Device for evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors), 2422 (transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to
commit sex trafficking, transportation of minors, and enticement to travel) (the "Subject
Offenses"), for the period 1994 through August 8, 2019, described as follows:
1.
Evidence concerning the identity or location of the owner(s) or user(s) of the
Subject Devices.
2.
Evidence concerning the identity or location of co-conspirators of JEFFREY
EPSTEIN, including
and GHISLAINE MAXWELL.
3.
Evidence concerning communications to, from, by, and/or among co-conspirators
of JEFFREY EPSTEIN, including
and GHISLAINE MAXWELL.
4.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses.
5.
Documents or records reflecting payments to victims and/or co-conspirators
including but not limited to bank and financial records, spreadsheets, ledgers, account listings,
check and wire records, and documents reflecting cash withdrawals.
6.
Documents or records reflecting travel plans or arrangements for victims or
potential victims of the Subject Offenses, or co-conspirators in those Subject Offenses, including
6
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EFTA00018593

=== Page 9 ===
but not limited to itineraries, tickets, receipts, flight manifests, passport or identification
information, and related records.
7.
Any photographs of victims or potential victims of the Subject Offenses.
8.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
9.
Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usernames and passwords, user profiles, e-mail contacts, and photographs.
10.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. $ 2256(8).
If the Government determines that any of the Subject Devices is no longer necessary to retrieve
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject
Device, upon request.
7
2017.08.02
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=== Page 1 ===
Event: Accepted: Epstein
Start Date: 2020-02-04 22:30:00 +0000
End Date: 2020-02-04 23:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-02-04 04:16:15 +0000
Date Modified: 2020-02-04 04:16:15 +0000
Priority: 5
DTSTAMP: 2020-02-04 04:05:10 +0000
Attendee:
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=== Page 1 ===
From:
"
)"
To:
"
)"
Subject: To read on train 4
Date: Fri, 17 Sep 2021 15:21:43 +0000
Attachments:
;
;
; 2021-01-
19,
Interview_302.pdf; 2021-01-
20,
, Interview_302.pdf; 2021-01-
21,
Interview_302.pdf; 2007-08-
07,
Interview_302.pdf; 2007-08-
13,
, Interview_302.pdf; 2007-08-
14,
, Interview_302_(mentions,
).pdf; 2019-03-
19,
interview_302.pdf; 2020-07-
17,
, interview_302.pdf; 2020-08-
11,
, interview 302.pdf; 2021.06.07
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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=== Page 1 ===
From:
(USANYS)"
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>, Mark Steward <Mark.Steward@fca.org.uk>
Cc:
(USANYS)"
>, Kelly Eldred <Kelly.Eldred@fca.org.uk>, "Harry Caldecott"
<Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Date: Wed, 04 Dec 2019 23:58:17 +0000
Inline-Images: image001.png; image002.png; image003.png
That should be fine.
From: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Sent: Wednesday, December 4, 2019 1:15 PM
To:
(USANYS)
>; Mark Steward <Mark.Steward@fca.org.uk>
Cc:
is
(USANYS)
>; Kelly Eldred
<Kelly.Eldred@fca.org.uk>; Harry Caldecott <Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Many thanks
I have spoken to Mark's business support today and we will need to push back to next
week if ok. Does 3pm on Tuesday (UK time) work?
From:
(USANYS) [mailto:
Sent: 03 December 2019 18:33
To: Mark Steward <Mark.Steward@fca.org.uk>; Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc:
;
(USANYS)
>; Kelly
Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott <Harry.Caldecott@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>;
Harry Caldecott <Harry.Caldecott@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Thanks, Mark. And that's fine -- no rush on our end - happy to push this to next week if you prefer. Otherwise, Friday at
3p/10a should work for us. Just let us know. Thanks
From: Mark Steward <Mark.Steward@fca.org.uk>
Sent: Tuesday, December 3, 2019 1:06 PM
To:
(USANYS)
>; Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc:
is
(USANYS)
>; Kelly Eldred
<Kelly.Eldred@fca.org.uk>; Harry Caldecott <Harry.Caldecott@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry
Caldecott <Harry.Caldecott@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
We've only received the additional material today; it is voluminous which means we won't be in a position
for any meaningful conversation tomorrow. I suspect not before Friday either. Can we pencil in 3-4 pm on
Friday and will confirm on Thursday ?
Cheers
Mark Steward
EFTA00018136

=== Page 2 ===
Executive Director
Enforcement and Market Oversight
FCA
FINANCIAL
CONDUCT
AUTHORITY
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
in
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
(USANYS) [mailto:
Sent: 03 December 2019 17:18
To: Mark Steward <Mark.Steward@fca.org.uk>; Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc:
(USANYS)
>; Kelly
Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott <Harry.Caldecott@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>;
Harry Caldecott <Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Mark - Hope you had a good weekend and just wanted to circle back on this. Realizing it is starting to get a bit late in the
day in London, would tomorrow morning (New York time) work for a follow up call on this? Perhaps around 10am our
time/3pm in London? If so, we can circulate another dial in.
Thanks,
From: Mark Steward <Mark.Steward@fca.org.uk>
Sent: Thursday, November 28, 2019 12:59 PM
To:
(USANYS)
>; Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc:
is
(USANYS)
>; Kelly Eldred
<Kelly.Eldred@fca.org.uk>; Harry Caldecott <Harry.Caldecott@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry
Caldecott <Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Thanks for taking the call today and look forward to speaking again early next week. And happy
Thanksgiving !
Kind regards
Mark Steward
Executive Director
Enforcement and Market Oversight
FCA
FINANCIAL
CONDUCT
AUTHORITY
12 Endeavour Square
London
EFTA00018137

=== Page 3 ===
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
in
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
(USANYS) [mailto:
Sent: 28 November 2019 15:57
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <Mark.Steward@fca.org.uk>;
;
(USANYS)
>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
To allow a few of my colleagues to join, can we instead use a dial in:
Thanks, and talk soon.
Sent from my iPhone
On Nov 28, 2019, at 10:31 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
Great much appreciated thanks
From:
(USANYS) [mailto:
Sent: 28 November 2019 15:30
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <Mark.Steward@fca.org.uk>;
;
(USANYS)
>; ; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Okay, please call my cell
Sent from my iPhone
On Nov 28, 2019, at 10:25 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
H
I have spoken to Mark's business support and he is available at 4.15pm (UK time) today (ie in just
under an hour's time). It is quite urgent so if we could speak then it would be greatly appreciated.
If that does work please let us know what number to call you on?
Many thanks
EFTA00018138

=== Page 4 ===
From:
(USANYS) [mailto:
Sent: 28 November 2019 14:53
To: Mark Steward <Mark.Steward@fca.org.uk>
Cc:
;
(USANYS)
>; Kate
Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Hi Mark - Thanks for reaching out. We do have an active investigation and would be happy to talk. As you likely know,
today is a holiday in the US. Is this something we could discuss on Monday or is it more urgent than that? Thanks,
Sent from my iPhone
On Nov 28, 2019, at 9:28 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Dear
,
Can I ask whether this is still an active matter ? if so, I wonder if we could speak
when it is convenient.
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
Sent: 28 November 2019 14:25
To: Mark Steward <Mark.Steward@fca.org.uk>;
(USANYS)
^
is
(USANYS)
Cc: Kate Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Looping in
They run our
unit and oversee the Epstein case.
Sent from my iPhone
On Nov 28, 2019, at 8:30 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
EFTA00018139

=== Page 5 ===
H
Can you let me know, urgently, whether anyone in your office is handling the investigation into
Jeffery Epstein, especially anything in relation to JP Morgan (he was a client of their private wealth
division) and, if so, who, as we need to have a chat. If this is not in SDNY, do you know who is
handling ongoing work into Mr E's world ?
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
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This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
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Further information on the classification and handling of FCA information can be found on the FCA website
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The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
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communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
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Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
EFTA00018140

=== Page 6 ===
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
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This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have received this
email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further
information on the classification and handling of FCA information can be found on the FCA website
(http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA
Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-
privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish,
rely on or otherwise use it without our consent. Some of our communications may contain confidential information
which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error
please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on
the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-
info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
EFTA00018141

=== Page 7 ===
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and why
we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy
Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-and-
data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish,
rely on or otherwise use it without our consent. Some of our communications may contain confidential information
which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error
please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on the
classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-
info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered
office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all
EFTA00018142

=== Page 8 ===
email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all
email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
EFTA00018143

=== Page 9 ===
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all
email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
EFTA00018144


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c6: pdf
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c0:
=== Page 1 ===
From:
To
Cc: "Berman, Geoffrey (USANYS)"
Subject: Epstein Indictment
Date: Fri, 12 Jun 2020 14:48:05 +0000
Attachments: 2019-07-01,_JE,_first_indictment_final.docx
EFTA00018557


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c3: VOL00008
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c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: U.S. V. Maxwell 20 Cr. 330 (AJN)
Date: Tue, 02 Mar 2021 17:38:11 +0000
Attachments: MAXWELL_BAIL_APPLICATION_with_EXHIBIT_2-23-17.pdf
Hi
Do you have a moment today or tomorrow to discuss the financial condition Maxwell has proposed in her most recent
bail application? It's unusual, so I was hoping to talk through our proposed response before drafting, if possible.
Thanks,
From:
(USANYS)
Sent: Tuesday, February 23, 2021 3:00 PM
To:
)
Cc:
(USANYS)
is
>;
(USANYS)
Subject: Re: U.S. V. Maxwell 20 Cr. 330 (AJN)
Unbelievable.
Sent from my iPhone
On Feb 23, 2021, at 2:54 PM,
)
wrote:
FYI
From: BOBBI C STERNHEIM
Sent: Tuesday, February 23, 2021 2:44 PM
To:
)
is
)
i
(USANYS)
Cc: Christian Everdell
>; Laura Menninger
>; Jeff Pagliuca
Subject: U.S. V. Maxwell 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
EFTA00018718

=== Page 2 ===
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.
<MAXWELL BAIL APPLICATION with EXHIBIT 2-23-17.pdf>
EFTA00018719


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c3: VOL00008
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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein estate
Date: Wed, 08 Jul 2020 15:00:44 +0000
We're all available then - if you could please send a dial-in, we'll join at 1:00. Thanks.
From:
Sent: Wednesday, July 08, 2020 10:44
To:
Cc:
Subject: Epstein estate
Would you have time for a relatively quick call today around 1:00?
Thanks,
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
New York, NY 10004-1482
Office
Cell
I Fax
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00020366


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c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Fri, 12 Mar 2021 17:22:19 +0000
Attachments: 2021.03.12_Maxwell_Discovery_Letter_v2.pdf
Hey
I'm so sorry to do this but I just caught something on the cover letter. The initial bates range in the index reads
SDNY_GM_02742936 when it should instead be SDNY_GM_02742963. I'm terribly sorry. Would you like me to
email the updated cover to defense?
Thanks,
From:
Sent: Friday, March 12, 2021 12:14 PM
To: Christian R Everdell - Cohen & Gresser LLP
(
)
>; Mark S.
Cohen
>; Bobbi Sternheim
>; 'BOBBI c STERNHEIM'
>; Laura Menninger
>; Jeff Pagliuca
Cc:
is
(USANYS)
>;
(USANYS) [Contractor]
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Counsel,
Pursuant to the Court's Order dated November 18, 2020, today we are producing materials regarding victims who are not
referenced in Indictment number S1 20 Cr. 330 (AJN). Attached please find the accompanying cover letter. The
production is small enough to produce via an FTP site. Would you please send us a link to use for this production?
We
send a CD containing a copy of this production to the MDC for your client to review as well.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00018988


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=== Page 1 ===
From: Jill Shellow
To:
(USANYS)"
Cc: Andrew Patel
(USANYS)"
Subject: Re: Johnny Contreras - Investigation of Jeffrey Epstein Death
Date: Wed, 21 Aug 2019 21:16:41 +0000
,
I am traveling today. Andy and I will get back to you by phone tomorrow sometime in the afternoon. Thanks,
j-
Jill R. Shellow, Esq.
Law Offices of Jill Shellow
80 Broad Street, Suite 1900
New York, NY 10004
Please excuse all typos and auto correct
On Aug 21, 2019, at 3:35 PM,
(USANYS)
wrote:
Hi Andy/Jill,
We understand that Mr. Contreras is willing to meet with us in a proffer session, and that the proffer would be limited
only to the information he has regarding Mr. Epstein's death. If so, when would be convenient to meet? Let us know if
you'd like to discuss anything by phone. Thanks.
From: Andrew Patel
Sent: Wednesday, August 21, 2019 4:20 PM
To:
(USANYE)
is
(USANYE)
>;
(USANYE)
Cc: 'Donald Yannella
(
)'
>; ; 'Jill Shellow'
is
;
(USANYS)
is
(USANYS)
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Many thanks. Talk to you soon.
Andy
Andrew G. Patel
Attorney at Law
80 Broad Street, Suite 1900
New York, NY 10004
Tel:
Fa
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=== Page 2 ===
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act,
18 U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is intended
only for the use of the individual or entity named above. If the reader of this message is not the intended recipient,
or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copying of the communication is strictly prohibited. If you have received this e-mail
in error, please notify me immediately by telephone at (212) 349-0230 and by return e-mail, and delete all copies of
the message from your computer. Thank you.
From:
(USANYE) [mailto:
Sent: Wednesday, August 21, 2019 4:16 PM
To: Andrew Patel;
(USANYE);
(USANYE)
Cc: Donald Yannella (
); 'Jill Shellow';
(USANYS);
(USANYS)
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Hi Andy:
I've spoken with my wonderful former colleagues in SDNY who are handling the investigation, and who are cc'd here.
I
passed along the information you and Jill provided to us yesterday, and they will reach out to you directly to set up a
proffer on this topic.
Thanks, and best,
From: Andrew Patel
Sent: Monday, August 12, 2019 3:15 PM
To:
(USANYE)
is
(USANYE)
is
(USANYE)
Cc: Donald Yannella
>; 'Jill Shellow'
>;
Andrew Patel
Subject: Johnny Contreras - Investigation of Jeffrey Epstein Death
Dear
nd
:
This email concerns the investigation into the death of Jeffrey Epstein in
the MCC. We realize that it is unlikely your office is involved, but we
thought that we should inform the government of the following so you can
take whatever action you believe is appropriate.
Jhonny Contreras was recently returned to the SHU in the MCC. At the
time of Mr. Epstein's death, it is my understanding that Mr. Contreras was
housed in a cell on the same tier and across the hall from Mr. Epstein's
cell. Mr. Contreras did not see Mr. Epstein hang himself, but he would be
EFTA00018960

=== Page 3 ===
willing to speak to investigators, in the presence of counsel, about his
observations.
Please let us know if there is anything further we should do to follow-up.
Andy
Andrew G. Patel
Attorney at Law
80 Broad Street, Suite 1900
New York, NY 10004
Tel:
Fax:
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act,
18 U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is intended
only for the use of the individual or entity named above. If the reader of this message is not the intended recipient,
or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copying of the communication is strictly prohibited. If you have received this e-mail
in error, please notify me immediately by telephone at (212) 349-0230 and by return e-mail, and delete all copies of
the message from your computer. Thank you.
EFTA00018961


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=== Page 1 ===
From:
To:
Cc:
Subject: revised search warrant
Date: Sat, 10 Aug 2019 23:53:07 +0000
Attachments: Exhibit_D.pdf; Exhibit_A.pdf; Exhibit_B.pdf; Exhibit_C.pdf; USVI_SW.v6.docx
Thanks again for your help today, and for being flexible while we evaluated how to proceed today. Attached is the revised
application. The exhibits are the same as before, but I'm attaching them again just so you have the complete package. l'll
call you in a moment to discuss logistics.
is copied here. The FBI would greatly appreciate it if we could swear out the warrant first thing in the
morning, if at all possible
Thanks very much--
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From:
To:
Cc:
Subject: FW:
Date: Tue, 20 Jul 2021 13:24:11 +0000
Attachments: Fact_Witness_Travel_Request.docx
Good morning,
l'll be handing this travel. I usually directly reach out to the witness. If yu would like to give the attorney a heads up before
I call or even if they'd like to be on the line let me know. It's just a few routine questions we ask over the phone.
From:
Sent: Tuesday, July 20, 2021 9:13 AM
To:
Subject: Fwd:
Travel
Sent from my iPhone
Begin forwarded message:
From:
Date: July 19, 2021 at 4:43:00 PM EDT
To:
Cc:
Subject: RE:
Thanks,
Attached is the form for this witness. We are meeting with her on July 29th, and she is coming from
For next steps, will you be connecting with her directly? If so, I'll let her attorney know.
Thanks!
From:
Sent: Monday, July 12, 2021 9:38 AM
To:
Cc:
Subject: RE:
Three ways to bring someone in. GJ pre trial or trial. Pick one.
We cannot pay for interviews.
From:
Sent: Monday, July 12, 2021 8:40 AM
EFTA00019652

=== Page 2 ===
To:
Cc:
Subject:
Hi
and
and are scheduled to interview a witness on July 29th in the Maxwell case. She's currently based in
and will need to travel here for the interview. Could you please let me know what steps I should take for us to
arrange for her travel?
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019653


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=== Page 1 ===
From:
USANYS)"
To:
(USANYS)"
USANYS)"
Cc: "
(USANYS)"
Subject: Tova Noel DP Application
Date: Sun, 28 Mar 2021 14:08:39 +0000
Attachments: 2021.03.28_Noel_DP_Memo.docx;
Tova Noel Deferred_Prosecution Submission_(Final).pdf; Tova_Noel-_Exhibits.pdf;
Exhibit _A_(expired_EMT_certificate).pdf; Tova_Cover_Page.pdf; 3-
8_collateral_consequences_letter.pdf
Chiefs -
Attached is our revised memorandum on Tova Noel's deferred prosecution application. Thank you.
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:
(
)"
Cc:
(
)"
Subject: RE: MCC New York (Procedural Review)
Date: Fri, 17 Jan 2020 18:49:04 +0000
Hi
I will give you a call today but would it be possible to have the discussion early next week and include
who is our
SAC of Operations in HQ also participate as he deals directly with the BOP/HQ staff regarding BOP case matters and has
spoken directly to
of the BOP OIA about this matter? Thanks.
From:
(
)
Sent: Friday, January 17, 2020 1:12 PM
To:
Cc:
(
Subject: RE: MCC New York (Procedural Review)
- sorry for the delayed response on this. Do you have a few minutes to chat this afternoon or early next week?
Thanks,
From:
Sent: Thursday, January 9, 2020 4:55 PM
To:
(
i
is
(
V.
Cc:
Subject: FW: MCC New York (Procedural Review)
Hello Everyone,
Our HQ staff was contacted by the Federal Bureau of Prisons (BOP) in association with the matters concerning the
Epstein/MCC case, and informed that they would like to convene a Board of Inquiry that would review the operations at
the MCC NY. I have been asked to share this with the investigative and prosecution team for opinion and consideration. I
requested that the BOP provide us with some specific information and details about what this would include and we were
provided with the below information and attached Program Statement. Can you all please review this information and
then can one representative from the FBI and one representative from the U.S. Attorney's Office, SDNY, let us know your
EFTA00019233

=== Page 2 ===
office's position regarding this matter? I have included SAC
and ASAC
of our Operations Branch I
(OPS I) in this email as they deal directly with the BOP HQ. Thank you all.
Special Agent in Charge
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
From:
Sent: Wednesday, January 8, 2020 11:44 AM
To:
Subject: MCC New York
Hi
-
The BOP would like to convene a Board of Inquiry (relevant Program Statement attached) that would review operations
generally at MCC New York. Among other issues, it will look at local policy and procedures related to special housing, review
camera operations, and review training and staffing issues. This will not, of course, be a misconduct investigation. Should the
Board come across anything that appears to be new misconduct allegations, they will be reported consistent with normal
misconduct reporting requirements.
We are mindful of the on-going criminal investigation, and are aware that administrative charges may also arise connected to
the criminal case. We will studiously avoid creating any sort of conflict with that case. Please let me know if you have
additional questions or would like to discuss. Thanks in advance.
U.S. Department of Justice
Federal Bureau of Prisons
Office of Internal Affairs
320 First Street, N.W., Room 600
Washington, D.C. 20534
EFTA00019234


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From: "Miller, Michael"
To:
)"
N
"Martin G. Weinberg"
)"
)"
>, "Weingarten, Reid"
Subject: RE: US V Epstein
Date: Sat, 10 Aug 2019 13:09:50 +0000
- Where can I reach you? Newspapers are reporting that Jeffrey Epstein died last night. Can you
confirm? I'm at
Mike
From:
Sent: Friday, July 26, 2019 6:24 PM
To: Martin G. Weinberg
is
i
>; Weingarten, Reid
>; Miller, Michael
Subject: RE: US V Epstein
Received, thanks.
From: Martin G. Weinberg
Sent: Friday, July 26, 2019 15:36
To:
is
)
V.
>; Reid Weingarten
>; 'Miller, Michael'
Cc:
Subject: US V Epstein
a more formal preservation/production request for NPA-related materials that have been the subject of our email
exchange up to now. If there are questions, let me know.
Thanks
Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
EFTA00019937


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
Subject: RE: Travel
Date: Wed, 28 Aug 2019 13:08:23 +0000
Good morning
and
Before I reserve the conference room, please send me approval from
to reserve a conference room for
this trip to West Palm Beach, FL from 9/3 to 9/4/19. I'll get started on booking your airfare and hotel rooms
shortly. Thanks as always!
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
Original Message
From:
Sent: Wednesday, August 28, 2019 9:03 AM
To:
(USANYS)
Cc:
)
Subject: Travel
,
and I are traveling to West Palm Beach next week for the Epstein case. Could you please help book our
travel? Here is my information-
can let you know whether she would like the same arrangements.
Thanks so much for your help.
Hotel: Hilton Palm Beach, 600 Okeechobee Blvd, West Palm Beach. Checking in on 9/3 and checking out 9/4.
Conference Room: please book a conference room at the Hilton for both Tuesday and Wednesday. If they have a
room called "the social" available, that would be great.
Flights:
Outbound, leaving at 920 am on 9/3 from EWR to PBI
Inbound, leaving at 6:12 pm on 9/4 from PBI to JFK
Thanks!
Sent from my iPhone
EFTA00019683


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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
PERSONAL APPEARANCE IS REQUIRED
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
July 13, 2021
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
Assistant United States Attorney
OUTRICT FOR THE YORK
One St. Andrew's Plaza
New York, New York 10007
Email:
Telephone:
rev. 02.01.12
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From:
(USANYS)"
To:
)"
)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Relativity batch request & recap re Maxwell/Epstein
Date: Wed, 21 Oct 2020 20:37:57 +0000
Embedded: RE:_Relativity_batch_request_&_recap_re_Maxwell_Epstein.msg
Sender:
Subject: RE: Relativity batch request & recap re Maxwell/Epstein
Message-Id:
<SN5P110MB0336A58CF9A42AE914B97DC38A1C0@SN5P110MB0336.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
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=== Page 1 ===
From:
Subject: GJ outline and PPT
Date: Sun, 28 Mar 2021 02:32:50 +0000
Attachments: 2021.03.29_GM_S2_GJ_Presentation_Outline_v3.docx, 2021.03.29_GM_GJ_PPT.pptx
Hi team,
Attached are the script and PowerPoint for Monday's grand jury presentation. If you have the time/interest, I'd welcome
any thoughts/suggestions. Also, hopefully this goes without saying, but if any of you would like to join for the
presentation, you are of course welcome, but no pressure!
Thanks,
EFTA00019593


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=== Page 1 ===
From:
To:
Cc:
Subject: bail application
Date: Thu, 03 Dec 2020 01:36:01 +0000
We wanted to let you know that Ghislaine Maxwell's attorneys intend to file a new bail application. The application has
not yet been filed, and we don't have a specific briefing schedule or hearing date. We will make sure to keep you updated,
but we wanted to touch base in advance to make sure you were aware. As always, please feel free to give us a call if you
have any questions or if you'd like to discuss this.
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From: "Weinstein, Marc A."
To:
Cc: "Tomback, Andrew"
Subject: Epstein estate subpoenas
Date: Fri, 01 Nov 2019 20:39:18 +0000
n:
Are any of you available for a quick chat? I'm preparing to send you the documents we discussed shortly, but we'd like to
give you a heads up on something first.
Thanks,
Marc
Marc A. Weinstein | Partner
Co-Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00019684


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=== Page 1 ===
From:
(NY) (FBI)"
@fbi.gov>
To:
SANYS)"
Subject: Time to chat?
Date: Thu, 05 Dec 2019 18:37:22 +0000
Hi Ted,
Any time this afternoon for a quick status call on Epstein?
On Nov 25, 2019 3:29 PM,
(USANYS)"
wrote:
Let me know if you have a few minutes to connect later today or tomorrow. Thanks
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00018226


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
Subject: RE: Epstein search warrant documents
Date: Mon, 13 Jul 2020 13:51:47 +0000
Inline-Images: image002.png; image003.png
easystore (F:) > Island Macs
Sea
Name
Date modified
Type
Size
documents
6/30/2020 1:40 PM
File folder
email
6/30/2020 1:44 PM
File folder
NYC024363
7/8/2020 10:35 AM
File folder
presentations
6/30/2020 2:00 PM
File folder
spreadsheets
6/30/2020 1:43 PM
File folder
readMe.txt
6/30/2020 12:51 PM
Text Document
1 KB
From:
(USANYS) [Contractor]
Sent: Monday, July 13, 2020 9:43 AM
To:
Subject: FW: Epstein search warrant documents
From:
(USANYS) [Contractor]
Sent: Monday, July 13, 2020 9:05 AM
To: Flatley, Stephen R. (NY) (FBI)
Subject: RE: Epstein search warrant documents
easystore (F:) > IDE drives
Name
Date modified
Type
documents
6/25/2020 10:41 AM
File folder
email
6/25/2020 11:50 AM
File folder
presentations
6/25/2020 11:44 AM
File folder
spreadsheets
6/25/2020 12:43 PM
File folder
ReadMe.txt
7/7/2020 12:23 PM
Text Document
EFTA00019466


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=== Page 1 ===
From:
)"
To:
Cc:
(NY) (FBI)"
Subject: RE: [EXTERNAL] Re: Call
Date: Thu, 16 Sep 2021 20:36:17 +0000
Attachments: 2021.09.15_Court_Subpoena_ -
pdf
Hello
Thank you again for the helpful call today. Please do send the business records certification for the
records you previously provided us.
As I mentioned, attached is a trial subpoena. If we end up needing you to testify, I'll be in touch in late-October to talk
about logistics and to do some prep.
Thanks,
From:
Sent: Thursday, September 16, 2021 4:13 PM
To:
)
Cc:
(NY) (FBI)
Subject: Re: [EXTERNAL] Re: Call
I'm available now.
Specialist
Student Records & Subpoenas
Information Technology Enterprise Applications/Records Management
FAX
On Thu, Sep 16, 2021 at 3:48 PM
)
wrote:
Hi
It's a follow-up conversation to the ones you had with
and some of my colleagues about
subpoenas for student records a few months ago. Happy to explain more on the phone. When is a good time to talk?
Thanks,
From
Sent: Thursday, September 16, 2021 3:41 PM
EFTA00017881

=== Page 2 ===
To:
)
Subject: Re: [EXTERNAL] Re: Call
What is it about?
Specialist
Student Records & Subpoenas
Information Technology Enterprise Applications/Records Management
FAX
On Thu, Sep 16, 2021 at 3:04 PM
)
wrote:
Thank you,
Is there a time that works best for you?
Thanks,
From
Sent: Thursday, September 16, 2021 1:14 PM
To:
)
Subject: [EXTERNAL] Re: Call
Okay
Specialist
Student Records & Subpoenas
Information Technology Enterprise Applications/Records Management
FAX
PX
On Thu, Sep 16, 2021 at 10:46 AM
)
wrote:
Hello
I hope you're doing well. I think a few months back you spoke with my colleague,
Do you have a few minutes sometime for a short follow up call? We are generally available today if that works for
you.
Thank you,
Assistant United States Attorney
Southern District of New York
EFTA00017882

=== Page 3 ===
1 Saint Andrews Plaza
New York, New York 10007
Disclaimer: Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released
in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone
or in writing.
Disclaimer: Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Disclaimer: Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
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From:
)"
To:
)"
Ce:
(USANYS)"
Subject: Re: Epstein investigation
Date: Wed, 28 Oct 2020 23:07:58 +0000
Ok, thanks. Anything else you'd like me to do about these slips in the FOIA scans that note CDs weren't scanned?
Sent from my iPhone
On Oct 28, 2020, at 6:59 PM,
wrote:
Yes, we have all of these saved here on the share:
I've reviewed all of these files, and either produced them, noted the technical difficulties to the FBI, or noted them in the list of folders to review for witness statements.
Thanks so much for confirming.
From:
Sent: Wednesday, October 28, 2020 4:29 PM
To:
Cc:
(USANYS)
Subject: Fwd: Epstein investigation
Is this just the media that, based on
email and our conversations,
you've already reviewed? I don't think this answers our question about CDs with things like subpoena returns, but let me know what you think.
Sent from my iPhone
Begin forwarded message:
From:
(IMD) (FBI)"
Date: October 28, 2020 at 2:03:00 PM EDT
To:
Cc:
>,
(NY) (FBI)"
(NYPD)"
(USANYS)"
Subject: RE: Epstein investigation
Good afternoon AUSA
The FOIA media team advised they downloaded media from file number 31E-MM-108062, including audio and video. However, there seem to be some technical issues,
as they are unable to listen to 48 audios located in the 1A Vol 3. Per our Document Conversion Unit, this is a "codec problem," meaning there was probably some sort of
user error from The AUSA's office when they exported the media to the disc. This issue cannot be resolved on our end. It would have to be addressed with whomever
sent us the media. With this one exemption, the rest of the media we downloaded to OPWAN is viewable. Please see below a list with a brief description of the items.
I'm not sure if this is all the media contained in the file though. Hope this helps. Please let me know if you have questions or need further assistance.
File
Type of Media
Length (hr. min, sec)
Description
31E-MM-108062-1A Vol. 3
48 Grand Jury Testimony audio files dated 7/19/2006 (media
(located in GJ-1A Sec. 03, FDPS Pg. 250
Audio
3:08:54
received from the PB State Attorney's Office).
on T-drive)
31E-MM-108062-1A43
(located in 1A Sec. 05, FDPS Pg. 194 on
Audio
4/24/2007 interview of
1:13:05
by FBI SAs
T-drive)
and AUSA
(media received from SA
31E-MM-108062-1A91
(located in 1A Sec. 11, FDPS pg. 83 on
Video
3:26:21
2/17/2010 deposition of Jeffrey Epstein
vs. Jeffrey
T-drive)
Epstein). Media received from attorney Brad Edwards.
Thanks,
Unit Chief
Litigation Support Unit/RIDS
EFTA00018647

=== Page 2 ===
Confidentiality Statement: This message is transmitted to you by the Litigation Support Unit of the FBI's Information Management Division. This message,
along with any attachments, may be confidential, law enforcement sensitive, and legally privileged. If you are not the intended recipient of this message,
please destroy it without further retention or dissemination (unless otherwise required by law). Please notify the sender of the error by separate e-mail or by
calling (540) 868-4843.
From:
Sent: Monday, October 26, 2020 5:46 PM
To:
(IMD) (FBI)
Cc:
is
(NY) (FBI)
is
(NYPD)
>;
(USANYS)
Subject: [EXTERNAL EMAIL] - Re: Epstein investigation
Hi
Thanks very much for looking into this, we appreciate it.
Best,
Sent from my iPhone
On Oct 26, 2020, at 3:57 PM,
(IMD) (FBI)
wrote:
Good afternoon AUSA
My apologies for the delay. I'm looking into this matter. Waiting for a response from the FOIA team that process media. I should have a response shortly.
Thanks,
Unit Chief
Litigation Support Unit/RIDS
Confidentiality Statement: This message is transmitted to you by the Litigation Support Unit of the FBI's Information Management Division. This
message, along with any attachments, may be confidential, law enforcement sensitive, and legally privileged. If you are not the intended recipient of this
message, please destroy it without further retention or dissemination (unless otherwise required by law). Please notify the sender of the error by separate e-
mail or by calling (540) 868-4843.
From:
Sent: Monday, October 26, 2020 3:41 PM
To:
(IMD) (FBI)
Cc:
(NY) (FBI)
(NYPD)
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein investigation
Hi
Just following up on this, thanks. Any information you could provide would be very helpful.
Thanks,
From:
Sent: Monday, October 19, 2020 6:34 PM
To:
(IMD) (FBI)
Cc:
(NY) (FBI)
(USANYS)
Subject: RE: Epstein investigation
Hi
Hope you're doing well. As our team is reviewing these materials in connection with discovery, we wanted to follow up with you about this project. In particular, we
were hoping you could tell us how your office approached CDs that were in the boxes of materials from Florida. We noticed in the scans we received some documents
that looked like the attached file - which looks like a photocopy of the CD. Were those materials downloaded by your office? If not, no worries at all, we have them
from the primary file, but we wanted to check with you to make sure we had the complete set of materials you sent.
Thanks very much,
EFTA00018648

=== Page 3 ===
From:
Sent: Wednesday, February 13, 2019 9:53 AM
To:
(IMD) (FBI)
Cc:
is
(USANYS)
(NY) (FBI)
Subject: RE: Epstein investigation
Hi
Wanted to quickly check in to follow up on our conversations last week and earlier this week - I think you were able to transmit the scanned records to
but I'm
not sure whether that was just the 16,000 pages you mentioned when we last spoke, or if you were able to get all 29,000 to her? And we're also hoping to confirm for
sure that all the materials you received were definitely scanned in, and to get an index or catalog of those materials (including what media was included).
Another person on our team,
who's copied, is jumping in to coordinate on this, so if it's easier to chat via phone her number is
and please
let us know if anything would be helpful on our end.
thanks again!
From:
Sent: Wednesday, January 30, 2019 17:19
To:
(IMD) (FBI)
Cc:
is
(USANYS)
is
(NY) (FBI)
Subject: RE: Epstein investigation
Following up on our conversation from yesterday, wanted to send a quick email as promised so you have my full contact info - I'm reachable at this email address or by
phone at
(office) or
(cell). Please don't hesitate to reach out anytime day or night if we can provide any useful info, or if you have any
questions at all, and we appreciate you talking with us about the records information. Let us know if it makes sense to set up another call for Friday or early next week
to check in on the questions we had, and thanks very much for your help.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00018649


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=== Page 1 ===
From:
"
)"
To:
"
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Ghislaine Maxwell
Date: Mon, 04 Jan 2021 23:09:33 +0000
Embedded: RE:_Ghislaine_Maxwell.msg
Sender:
Subject: RE: Ghislaine Maxwell
Message-Id:
<BN3P110MB0339950D70078DBF12D68DEA92D20@BN3P110MB0339.NAMP110.PROD.OUTLOOK.CO
M>
EFTA00018696


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Hammad Memo
Date: Mon, 19 Aug 2019 19:28:09 +0000
Hammad Memos under NY Rule of Professional Conduct 4.2 are approved seriatim by the Unit Chief (criminal) or Deputy Chief (civil); Civil or
Criminal Professional Responsibility Officer; and Division Chief.
Requesting AUSA
USAONo: 2019R01059
Investigation/Complaint/Arrest/Indictment Investigation
Covert or Overt Contact: Overt
Ongoing, Additional, Different Crime (Yes/No):Yes
Any Special Precautions (discuss below) (Yes/No): Yes
Bar(s) of Admission: New York
Discussion:
We are currently investigating the circumstances surrounding the August 10, 2019 suicide of Jeffrey Epstein while in the
custody of the Bureau of Prisons ("BOP") at the Metropolitan Correctional Center ("MCC"). In particular, we are
investigating MCC staff's (i) decision not to reassign a cellmate to Epstein on August 9, 2019, contrary to regular BOP
practice and direct orders from the Warden; (ii) the failure of correctional officers assigned to the Special Housing Unit
("SHU") at which Epstein was housed the night of August 9, 2019, to perform the required overnight counts and 30-
minute checks; and (iii) the falsification of records related to those count slips and 30-minute checks, in violation of Title
18, United States Code, Section 1519.
We are also investigating any efforts, following Epstein's death, to obstruct justice by destroying relevant records at MCC.
In particular, we learned today that all institutional count slips for dates prior to August 10, 2019, which we requested on
August 12, 2019, are apparently "missing." Today, we received a tip from a guard at MCC that while the guard was
stationed at the rear gate, inmate
brought down bales of shredded paper on Thursday and Friday of last
week (August 15 and 16), and reported that he had been asked to shred documents by the BOP after-action team
(although it is not clear from the tip whether
took part in any shredding) and that "they are shredding everything."
We would like to interview
regarding these events.
is a sentenced defendant who was prosecuted out of the
District
and is currently serving a
term of imprisonment related to
The assigned AUSA has no objection to us interviewing
Investigating agents will seek to interview
at
MCC, and will direct him not to discuss his prior criminal case or VOSR. We believe that
will be more likely to
cooperate and be forthcoming in this setting, rather than going through his attorney. The proposed contact is permissible
under Hammad for several reasons. First,
is not represented in connection with his status as a potential witness.
Second, agents will be instructed not ask
any questions about his prior criminal case. Accordingly, the proposed
contact is permissible.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00018131


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=== Page 1 ===
METROPOLITAN
POLICE
Deputy Assistant Commissioner
Geoffrey S. Berman
Specialist Operations Headquarters
United States Attorney
Southern District of New York
New Scotland Yard
1- - 8 Richmond Terrace
Victoria Embankment
By hand
London
SW1A 2JL
Telephone:
Email:
Reference: 53/DACSO/2019/RW
9th December 2019
Dear Mr. Berman,
I am writing regarding your investigation into the allegations of sexual exploitation and abuse by
Jeffrey Epstein as detailed in the case of United States V. Jeffrey Espstein, 19 Cr. 490 (RMB).
I have been advised that US Embassy representatives in London have made contact with Metropolitan
Police Colleagues on your behalf, requesting the contact details for the solicitor for HRH The Duke of
York, Prince Andrew. These contact details are:
Gerrard Tyrrell
Harbottle & Lewis LLP
7 Savoy Court
London WC2R OEX
Email:
Telephone:
The above is supplied for your information.
Yours sincerely,
Deputy Assistant Commissioner - Specialist Operations
Metropolitan Police Service
EFTA00018922


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=== Page 1 ===
From:
(NY) (OGA)"
To
(USANYS)"
(USANYS)"
Subject: Epstein interview notes
Date: Fri, 30 Aug 2019 17:02:59 +0000
Attachments: Scanned_from_a_Xerox_Multifunction_Printer.pdf
Attached are all the interview notes. 302s will be prepared during the week.
Forwarded message
From:
@nypd.org>
Date: Aug 30, 2019 12:54 PM
Subject: Scanned from a Xerox Multifunction Device
To:
@nypd.org,
(NY) (OGA)"
Cc:
Please open the attached document. It was scanned and sent to you using a Xerox Multifunction Printer.
Attachment File Type: pdf, Multi-Page
Multifunction Printer Location: 290 Broadway 9th FL; Joint Bank Robbery T/F
Device Name: P290BWAY-JBRTF-MFD
Scanned from a Xerox Multifunction Device
EFTA00018550


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
Subject: Epstein
Date: Tue, 05 Nov 2019 14:27:51 +0000
Can you swing by whenever you have a few minutes? Want to talk a bit more about tomorrow's meeting. Thanks
EFTA00017908


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Epstein Pros Memo
Date: Wed, 14 Aug 2019 17:55:02 +0000
Attachments: 2019-07-09,_initial_conference.pdf,2019-07-09,_presentment.pdf,2019-07-
15_bail_hearing.pdf,2019-07-18,_bail_decision.pdf; 2019-07-31,_conference.pdf
Transcripts for each attached. The first three were related to presentment and arraignment, and then bail; the most
recent was a scheduling conference.
From:
(USANYS)
Sent: Wednesday, August 14, 2019 13:52
To:
Subject: RE: Epstein Pros Memo
Thanks. And last thing, sorry, can you send me the court dates and what happened at them?
From:
Sent: Wednesday, August 14, 2019 1:48 PM
To:
(USANYS)
Subject: RE: Epstein Pros Memo
19-490
From:
(USANYS)
Sent: Wednesday, August 14, 2019 13:48
To:
Subject: RE: Epstein Pros Memo
Thanks! What was the docket?
From:
Sent: Wednesday, August 14, 2019 1:45 PM
To:
(USANYS)
Cc:
is
Subject: RE: Epstein Pros Memo
Sure, attached. Depending on what exactly you're looking for, the ODAG memo and UMR from when we were charging,
also attached, may also be useful.
From:
(USANYS)
Sent: Wednesday, August 14, 2019 13:15
To:
V.
)
V.
)
Subject: Epstein Pros Memo
Can you send it to me?
EFTA00020183

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00020184


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=== Page 1 ===
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR Teftrey
FOR Teffrey
DATE 02/26/05 TIME 11:15 P.M. A.M.
DATE 02/25/05 TIME 05.50AM P.M. A.M.
M
OF
OF
PHONE
PHONE/
MOBILE
You none it
TELEPHONED
PLEASE CALL
TELEPHONED
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
Please call has
Going Bust to
back in 1430
constitution
She is on the way
what about
to the yym
Pouris on Saturday
SIGNED
1184
SIGNED
1184
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR Teffoey
FOR Jefficy
DATE 2/26/05 TIME K.CP P.M. A.M.
DATE 2/76/05 TIME 12:21 A.M. M
M
M
OF
OF
PHONE/
PHONE/
FORM
MOBILE
MOBILE
TELEPHONED
PLEASE CALL
TELEPHONED
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE Rlease call
MESSAGE
Please call
her
has Back
J184 10/01
SIGNED
Page 1184
SIGNED
1184
01/22/2015
Public Records Request No.: 10 10-208
EFTA00019866


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
)"
Subject: Re: media has it
Date: Thu, 02 Jul 2020 13:47:13 +0000
The suspense is killing me! Thanks
Sent from my iPhone
On Jul 2, 2020, at 9:40 AM,
)
wrote:
We just got the unsealing order. They are working on the wheel out.
Sent from my iPhone
On Jul 2, 2020, at 9:22 AM,
(USANYS)
wrote:
So aggravating. Okay, hopefully Parker will sign the unsealing order very soon.
From:
)
Sent: Thursday, July 2, 2020 9:20 AM
To:
(USANYS)
>;
>;
Subject: media has it
Tom Winter per usual - he has some great source at FBI
https://www.nbcnewyork.com/news/local/crime-and-courts/ghislaine-maxwel-arrested-jeffrey-epstein-
aide/2495762/
Assistant U.S. Attorney
Southern District of New York
EFTA00019414


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=== Page 1 ===
From:
To:
Cc:
)"
Subject: Re: Phone call
Date: Sun, 11 Aug 2019 19:35:18 +0000
Warden is good for 10:00 am tomorrow at SDNY. Please provide me location details with in SDNY so I can
forward it to him. Thank you
Sent from mobile device, please excuse typos.
Special Agent
Office of the Inspector General
1 Battery Park Plaza, 29th floor
New York, NY 10004
Cell
Office
> On Aug 11, 2019, at 3:08 PM,
wrote:
V
>
Understood, thanks.
V
>
Can we set up a meeting with the warden for tomorrow?
and I are free any time. Thank you.
V
>
Original Message
> From:
> Sent: Sunday, August 11, 2019 2:53 PM
> To:
i
> Subject: Phone call
V
V
It appears there is new information about the phone call at 7:17pm Friday night.
V
> The Warden briefed OIG SAC Modano that the call was 19 minutes long. I did not brief the Warden on any
information regarding that call.
V
V
Epstein was never in general population, because of that he did not need an approved list of people to call.
>
> On Friday he had a legal visit that lasted from 8:00ish an until almost 7:00pm. He was supervised the entire
time by BOP staff.
V
V
Sent from mobile device, please excuse typos.
V
V
V
Special Agent
V
Office of the Inspector General
EFTA00018981

=== Page 2 ===
> 1 Battery Park Plaza, 29th floor
^^^^^^^^^ > > > >
New York, NY 10004
Cell
Office
EFTA00018982


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=== Page 1 ===
From:
To: Jack Scarola
Cc:
Subject: Rule 17(c) subpoena
Date: Tue, 16 Nov 2021 02:28:42 +0000
Attachments:2021.11.14_Mtn_for_Order_Auth_a_Sub_Pursnt_to_F.R.Crim.P_17(c)
(3)_re.Feldman_Redacted_for_Scarola.pdf 2021.11.14_Ex._1_Redacted_for_Scarolapdf
Jack,
Attached is a motion that Maxwell's has counsel filed seeking to subpoena information from the Epstein Victim
Compensation Fund, including information about
We intend to file a motion to quash the subpoena later this
week. Happy to have a call if you would like to discuss or have any questions.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00018192


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=== Page 1 ===
From:
(NY) (FBI)"
To: 'Gloria Allred'
)"
Cc:
)"
Subject: RE: Urgent. I have a new alleged victim of EI have a new client who was a victim of
Epstein. She is willing to fly to New York for the victim meeting on Oct. 23. May I call you
at 5:45 P.M. to discuss ?
Date: Mon, 21 Oct 2019 16:23:24 +0000
Inline-Images: image001.jpg; image002.png; image005.jpg; image006.png
Thanks Gloria.
From: Gloria Allred [mailto:
Sent: Monday, October 21, 2019 12:12 PM
To:
(NY) (FBI)
is
>;
Cc:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
It is
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
ALLRED. MAROKO & GOLDBERO
2019
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Leve
of Professional Excellence
2019
From:
(NY) (FBI)
Sent: Monday, October 21, 2019 9:02 AM
To:
)
>; ; Gloria Allred
i
)
Cc:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Hi Gloria,
Is this client
?1 know you've already forward
information to Victim Services. If it is not
and your client
wants to attend, we will need that info ASAP. Can you let me know.
Thanks,
EFTA00019703

=== Page 2 ===
FBI New York
VCAC/Human Trafficking
C:
O:
From:
) [mailto:
Sent: Monday, October 21, 2019 9:40 AM
To: Gloria Allred
i
)
Cc:
is
(NY) (FBI)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
We will make ourselves available to meet with your new client on 10/23. Because the victim meeting is being run by the
FBI, their victim services folks are handling travel logistics. I'm cc'ing
who should be able to hopefully help
coordinate travel. Would you please provide
with your new client's name as it appears on her ID, date of birth,
email address, and phone number?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Friday, October 18, 2019 5:02 PM
To:
Cc:
Subject: Urgent. I have a new alleged victim of EI have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
EFTA00019704

=== Page 3 ===
www.amglaw.com
www.gloriaallred.com
ALLRED. MAROKO & GOLDBERO
2019
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00019705


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=== Page 1 ===
From:
To:
Bcc:
Subject: discovery/brady letter
Date: Tue, 27 Oct 2020 18:55:00 +0000
Embedded: discovery_brady_letter.msg
Sender:
Subject: discovery/brady letter
Message-Id:
<SN5P110MB0336078161A852D19F6A4FE98A160@SN5P110MB0336.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
EFTA00018285


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=== Page 1 ===
From:
)"
To: "Moyne, Parvin"
Cc: "Moyer, Thomas"
)"
)"
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Date: Thu, 22 Aug 2019 16:03:05 +0000
We received it, thanks, and we will.
From: Moyne, Parvin
Sent: Thursday, August 22, 2019 12:02
To:
Cc: Moyer, Thomas
>;
>;
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Sounds good.
We made another production last night. If it is helpful for us to run through that with you before the proffer, let us know
and we can jump on a call.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
One Bryant Park
New York, NY 10036-6745
USA
Direct:
+1
Internal:
Fax: +1
akingump.com
Bio
From:
Sent: Wednesday, August 21, 2019 11:29 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
i
is
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Thanks, let's do 10:30 a.m. on Thursday the 12th. Please let us know if your schedule changes, or if it's useful to talk
substantively in the interim, and we look forward to seeing you then.
From: Moyne, Parvin
Sent: Wednesday, August 21, 2019 20:01
To:
Cc: Moyer, Thomas
i
is
EFTA00020120

=== Page 2 ===
Subject: Re: 2019.8.15 - SDNY Production Index.xlsx
Either works for us so please choose what is most convenient for you.
Best,
Parvin
On Aug 21, 2019, at 6:45 PM,
)
> wrote:
Parvin,
Not a problem. We could do any time after noon on that Tuesday (the 10th) or any time on the Thursday (the 12th).
Would either of those work?
thanks,
From: Moyne, Parvin
Sent: Wednesday, August 21, 2019 09:25
To:
Cc: Moyer, Thomas
>;
)
i
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
I'm so sorry for the inconvenience but those dates are not good on our end.
The following week is relatively clear. Might September 9th work? Or other dates that week?
Best,
Parvin
From:
Sent: Tuesday, August 20, 2019 11:58 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
is
i
)
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early
September, if we can - is there a time during the afternoon of September 5 or the morning of September 6 that would
work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the
following week.
thank you,
EFTA00020121

=== Page 3 ===
From: Moyne, Parvin
Sent: Tuesday, August 20, 2019 14:03
To:
is
>;
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from DB Legal) deliver a
presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with
Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have
noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we
have provided so you can more readily identify whatever information you are most interested in. Following the proffer,
if there are particular accounts or transactions of interest, we can identify the person within DB who can best answer
questions on those areas and that person would then meet with you.
In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.)
Best,
Parvin
From:
Sent: Monday, August 19, 2019 8:14 PM
To: Moyne, Parvin
is
is
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out
scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with
Deutsche Bank personnel, etc? And approximately how long should we be planning to block out?
thanks,
From: Moyne, Parvin
Sent: Monday, August 19, 2019 12:04
To:
is
>;
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Hi
The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most
sense on your ends.
EFTA00020122

=== Page 4 ===
We have time this week (Thursday or Friday afternoon) and next week (Monday - Wednesday), and we have time in
September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends.
Best
Parvin
From:
)
Sent: Saturday, August 17, 2019 1:59 PM
To: Moyne, Parvin
is
is
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
EXTERNAL Email
Parvin,
We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think
we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and
trials in the next couple weeks, but we could do early September if that works on your end. Thoughts?
thanks,
From: Moyne, Parvin
Sent: Thursday, August 15, 2019 09:48
To:
is
)
V.
)
Cc: Moyer, Thomas
Subject: 2019.8.15 - SDNY Production Index.xlsx
&
Please find attached an index to our productions to date. This is a work in progress - we will update it as we gather and
produce additional documents.
Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
EFTA00020123

=== Page 5 ===
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00020124


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=== Page 1 ===
ANTMENT
DRAFT
U.S. Department of Justice
Southern District of New York
One St. Andrews Plaza
OM
JUSTITIA
New York, NY 10007
Phon
Fax:
July 01, 2020
Re: Case Number 2018R01618 and Court Docket Number
Dear
The enclosed information is provided by the United States Department of Justice Victim Notification System
(VNS). As a victim witness professional, my role is to assist you with information and services during the
prosecution of this case. You have been designated to receive notifications on behalf of the following victim(s)
(or potential victims) identified by law enforcement during the investigation of the case:
Defendant Ghislaine Maxwell was arrested and charged as the result of a criminal investigation conducted by
the United States Attorney's Office for the Southern District of New York. These charges arise out of an
investigation into potential co-conspirators of Jeffrey Epstein. The main charge is categorized as Project Safe
Childhood. Additional information regarding the case is set forth below. The lead prosecutors on the case are
Victim's Rights
Although the current charges against Maxwell may not contain allegations involving you personally, the
Southern District of New York previously identified you as a victim or potential victim in a related case involving
Jeffrey Epstein.
Victims of all crimes under federal investigation are entitled to services under the Victims' Rights and
Restitution Act (VRRA), including notification of court events. For further details, please refer to Title 34 United
States Code section 20141 or the VRRA link posted at https://www.notify.usdoj.gov.
Although you may not have been identified as a victim of the specific conduct charged in the Indictment
against Maxwell, for your awareness, this letter provides details regarding the rights of crime victims in federal
cases. Now that charges have been filed in federal court, victims of the charges filed are, in addition, entitled
to the following rights, according to the Crime Victims' Rights Act, Title 18 United States Code section 3771:
(1) The right to be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely
notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or
escape of the accused; (3) The right not to be excluded from any such public court proceeding, unless the
court, after receiving clear and convincing evidence, determines that testimony by the victim would be
materially altered if the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at
any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5)
The reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely
EFTA00020237

=== Page 2 ===
restitution as provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be
treated with fairness and with respect for the victim's dignity and privacy; (9) The right to be informed in a
timely manner of any plea bargain or deferred prosecution agreement; and (10) The right to be informed of the
rights under this section and the services described in section 503(c) of the Victims' Rights and Restitution Act
of 1990 (34 U.S.C. 20141(c)) and provided contact information for the Office of the Victims' Rights
Ombudsman of the Department of Justice. If you want to inform the prosecutors of your views regarding any
aspect of the case, please contact one of the prosecutors listed above or me at
Please understand that these rights apply only to victims of the specific counts charged in federal court, and
thus you may not be able to exercise all of these rights if the crime of which you are a victim is not within the
scope of the Indictment.
Because you have not been identified as a victim of the charges filed against Maxwell, we will not provide
you with additional individualized notifications about this specific case unless you request such
notifications. If you wish to receive ongoing notifications regarding this case, please contact me a
Even if you do not receive individualized notifications regarding this case, we will make our best efforts to
ensure you are provided the rights and services to which you are entitled. You may contact the Victim/Witness
Coordinator at the office listed above if you have questions about the progress of your case, your rights or the
services to which you are entitled, or how you can assert them during the proceedings. If you believe that a
Justice Department employee has not provided you with these rights, you may file a complaint with the Justice
Department's Victims' Rights Ombudsman. For more information, go to
http://www.justice.gov/usao/resources/crime-victims-rights-ombudsman. If you have questions about filing a
complaint against an employee, you may contact the Ombudsman by email at
usaeo.VictimOmbudsman@usdoj.gov. Questions concerning this case should be directed to office listed
above.
It is important to keep in mind that the defendant(s) are presumed innocent until proven guilty and that
presumption requires both the Court and our office to take certain steps to ensure that justice is served. While
our office cannot act as your attorney or provide you with legal advice, you can seek the advice of an attorney
with respect to the rights above or other related legal matters.
Hearing Information
[INSERT MAXWELL NEXT HEARING INFORMATION]. If you plan on attending please call me at
in case there are any last-minute changes.
Information Regarding the Victim Notification System (VNS)
If, and only if, you elect to receive additional notifications regarding this case, then through the Victim
Notification System (VNS) we will continue to provide you with updated scheduling and event information as
the case proceeds through the criminal justice system.
The FBI's Victim Services Division (VSD) is committed to providing services and support to victims of crimes
committed by Jeffrey Epstein. Though this particular indictment is focused on specific individuals, you are still
entitled to your rights, resources, and referrals as a federal victim independent of this indictment. An overview
of these services is available at www.fbi.gov/resources/victim-services. If you would like to speak with a Victim
Specialist, or if you have any questions regarding your rights to victim services and referrals, please email
victimservices@fbi.gov.
Please note that certain documents (i.e. indictment, judgment, etc.) may become available periodically on the
internet at WWW.Notify.USDOJ.GOV under the field "downloads/links." You will need to log in using your VIN
number and password to access any existing documents.
EFTA00020238

=== Page 3 ===
Through the Victim Notification System (VNS) we will continue to provide you with updated scheduling and
event information as the case proceeds through the criminal justice system. You may obtain current
information about this case on the VNS website at https://www.notify.usdoj.gov or from the VNS Call Center at
1-866-DOJ-4YOU (1-866-365-4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition,
you may use the Call Center or Internet to update your contact information and/or change your decision about
participation in the notification program.
You will use your Victim Identification Number (VIN) '1478369' and Personal Identification Number (PIN)
'5828' anytime you contact the Call Center and the first time you log into VNS on the website. You are
associated with multiple cases. You will need only this victim ID/PIN code to access all case information. If you
are receiving notifications with multiple victim ID/PIN codes please contact the VNS Call Center. In addition,
the first time you access the VNS website, you will be prompted to enter your last name (or business name) as
currently contained in VNS. The name you should enter is Allred.
Remember, VNS is an automated system and cannot answer questions. If you have other questions which
involve this matter, please contact this office at the number listed above.
Sincerely,
United States Attorney
Victim Witness Coordinator
EFTA00020239


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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell
Date: Mon, 13 Jul 2020 20:28:45 +0000
Attachments: 6653181.Maxwell,_Ghislaine.pdf
Good Afternoon-
There was a minor typo with some of the dates. Final report with the changes attached. Please disregard the report
attached in the prior email.
U.S. Pretrial Services Officer Specialist - Intake Coordinator
Southern District of New York
Office:
Fax:
EFTA00019468


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=== Page 1 ===
From:
To:
Subject: To read on train 2
Date: Fri, 17 Sep 2021 15:19:08 +0000
Attachments: 2019-12-17,
interview_302.pdf; 2020-02-
27
Interview_302.pdf;,2020-04-
03
interview_notes_(no_302).pdf; 2019-09-
19
Interview_302.pdf;2019-11-14,
interview_302.pdf
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00018228


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=== Page 1 ===
7/19/2021
Student Info
Enrollment
Enrollment Code
Drop Date
Drop Code
View
(R02) Re-entry from another school same district
03/07/2002
(W26) W/D
View
(R02) Re-entry from another school same district
10/11/2001
(W02) In Dis
View
(EA1) Original Entry of Adult
09/20/2001
(W32) Adult
View
(EA1) Original Entry of Adult
08/13/2001
(W47) Adult
View
(EA1) Original Entry of Adult
08/15/2000
(W47) Adult
View
(E01) In District Previous Year
08/16/1999
(W03) In or
View
(E01) In District Previous Year
06/09/1999
(W02) In Dis
View
(E01) In District Previous Year
08/20/1997
(W22) Whe
View
(E01) In District Previous Year
06/10/1998
(W01) In Scl
View
(R03) Re-entry Unexpected same Dist after wd
06/11/1997
(W02) In Dis
View
(E01) In District Previous Year
08/22/1994
View
(E01) In District Previous Year
06/10/1994
(W02) In Dis
View
(E01) In District Previous Year
06/11/1993
(W01) In Scl
View
(E01) In District Previous Year
06/11/1992
(W01) In Scl
View
(E01) In District Previous Year
06/13/1991
(W01) In Scl
View
(E01) In District Previous Year
06/13/1990
(W02) In Dis
https://sis.palmbeachschools.org/focus/Modules.php?modname-Students/Student.php&search_modfunceresut&student_
1/1
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=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
Appearance Time:
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 371, 1001, 1519
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
Personal appearance is required unless excused by the U.S. Attorney's Office for the Southern
District of New York. Please see the attached riders.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 28, 2019
Geoffey S. Bermine
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
Assistant United States Attorneys
One St. Andrew's Plaza
New York, New York 10007
Telephone:
Email:
rev. 02.01.12
EFTA00018874

=== Page 2 ===
RIDER
(Grand Jury Subpoena to
,
dated August 28, 2019)
Advice of Rights
1. You may refuse to answer any question if a truthful answer to the question would tend to
incriminate you.
2. Anything that you do say may be used against you by the grand jury or in a subsequent legal
proceeding.
3. If you have a lawyer, the grand jury will permit you a reasonable opportunity to step outside the
grand jury room to consult with your lawyer if you so desire.
4. If you would like a lawyer but do not have funds to retain one, you may make an application to
the United States Magistrate Judge who will decide whether to appoint a lawyer to represent you.
Instructions and Definitions:
1. This subpoena calls for the production of categories of documents, records, correspondence,
other written material (including electronically stored material), and physical items, as specified
below, in your possession, custody or control.
2. This subpoena covers all responsive documents wherever they may be found, including on
computers, email accounts, iCloud accounts, servers, cellphones, and other personal electronic
devices, whether in the United States or any foreign jurisdiction.
3. This subpoena does not call for the production of any documents protected by a valid claim of
privilege, although any responsive document over which privilege is being asserted must be
preserved. Any documents withheld on grounds of privilege must be specifically identified on a
privilege log with descriptions sufficient to identify their dates, authors, recipients, and general
subject matter.
Materials to be Produced:
1. All materials relating to Jeffrey Epstein including, but not limited to, any text messages, emails,
social media messages or posts, documents, or notes.
EFTA00018875


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=== Page 1 ===
From:
To:
Subject: epstein
Date: Tue, 27 Aug 2019 21:12:53 +0000
Attachments: J8RpEPSf.pdf
EFTA00019993


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=== Page 1 ===
From:
To: "Berman, Geoffrey (USANYS)"
Subject: RE:
Date: Wed, 15 Apr 2020 14:45:25 +0000
Attachments: show_temp.pdf
From her complaint (attached):
62. Epstein, Maxwell, and
returned to Epstein's ranch. Upon returning from the
movie, Maxwell repeatedly told
that she wanted to give her a massage.
was very
uncomfortable with the idea of Maxwell touching her, but realized that she was completely alone
with Epstein and Maxwell.
feared what would happen if she did not comply with their
demands.
said that she had never had a massage and tried to avoid having Maxwell touch
her body, but Maxwell continued to pressure her. Maxwell directed
to take off all of her
clothes and lay on the massage table.
was extremely scared to be naked in front of
Epstein and Maxwell.
63. Maxwell left the door open so that Epstein could view
naked body during the
massage.
64. Maxwell touched intimate parts of
body against her will for the sexual benefit of
Maxwell and Epstein.
65. Maxwell exposed
breasts and groped her.
66.
was extremely distressed and afraid. She was a child in a massive ranch in New
Mexico, away from her family in Arizona, and isolated from any source of help. She was alone
with Epstein and Maxwell. She had no way to access a phone or other method of
communication without Epstein or Maxwell knowing. She had no way of leaving.
Original Message
From: Berman, Geoffrey (USANYS)
Sent: Wednesday, April 15, 2020 10:38 AM
To:
Subject: Re:
So massaging her chest is as explicit as it gets? What about her complaint?
> On Apr 15, 2020, at 10:24 AM,
wrote:
>
> In the article version accompanying the daily it is written like this:
(
)
V
>
also recalled Ms. Maxwell repeatedly asking whether she wanted a massage. Eventually relenting,
followed directions by taking off her clothes and bra and getting under a sheet on a massage table.
Ms. Maxwell performed the massage, at one point having
lie on her back as Ms. Maxwell pulled
down the sheet to massage her chest.
V
> "I don't think there was any reason for her to be touching me that way,"
said.
>
V
Original Message
> From:
> Sent: Wednesday, April 15, 2020 10:23 AM
> To: Berman, Geoffrey (USANYS)
> Subject: RE:
EFTA00019246

=== Page 2 ===
>
> From the daily:
)
V
V
Mike Baker
>
then remembers Ghislaine repeatedly asked whether -
V
V
>
Have you ever gotten a massage?
>
V
Mike Baker
>
wanted a massage.
V
>
>
I'm very skilled in massage, right, and so I want to make sure you get a massage.
>
>
Mike Baker
> She said that she was very -
>
>
>
She was skilled in massage. Yeah.
V
> Mike Baker
> And she eventually relents.
>
V
> But I had never had a professional massage before. So I didn't know what really was involved in that. And so
she said that I would take off my clothes and lay under the sheet.
>
> Mike Baker
>
Ghislaine performs the massage.
>
>
> She had me, you know, flip over to my back. And then she pulled the sheet down so that my breasts were
exposed.
>
> Mike Baker
> And she remembers how Ghislaine then went on to massage her chest.
V
>
>
Like it just - this feels weird. This feels uncomfortable. I don't think this is probably right, but I don't know.
V
> Mike Baker
> And all this time, she's struggling to figure out what's going on. Jeffery Epstein, she says, wasn't participating
in the massage. But she has this sense that he's in the area, that the doors are open, it's kind of an open area where
she's getting the massage.
V V V V V V V
I could feel his presence, like, oh, I'm sure he can see me from where he is.
Original Message
> From: Berman, Geoffrey (USANYS)
EFTA00019247

=== Page 3 ===
> Sent: Wednesday, April 15, 2020 10:08 AM
> To:
> Subject:
>
> Can you resend me the
quote from NYT about Maxwell massaging her breasts.
EFTA00019248


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=== Page 1 ===
From:
To:
Subject: Epstein
Date: Fri, 30 Nov 2018 15:39:08 +0000
Importance: Normal
Attachments: Plaintiffs_Motion_08_Civ_80736.pdf; 11.29.18_Memo.docx;
Government_Reply_08_Civ_80736.pdf;_NPA.pdf
Materials attached.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019530


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=== Page 1 ===
Gail S. Goodman, Professor
Federal Court Testimony
US Attorney:
Washington DC and Portland, OR
Case: US V. Daniel Stephen Johnson
Case: US V. Yusef Abramov
US Attorney:
, Portland, OR
Case: US V. Shane Britton
US Attorney:
New Mexico
,
Case: US V. Arthur Perrault
US Attorney:
San Francisco
Case: US V. Kealon Dyer-Hogan
US Attorney:
San Francisco
Case: US V. Michael Lindsay
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re:
Date: Mon, 11 Mar 2019 18:30:55 +0000
Importance: Normal
Epstein OK
Sent from my iPhone
> On Mar 11, 2019, at 2:12 PM,
(USANYS)
wrote:
>
> Russell and I have been asked by Laura to present on our campaign finance cases. We're doing NRA, PIC and
GEP, all of which have POTUS ties. Do we need to ask
to step out?
>
> Sent from my iPhone
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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Thu, 04 Apr 2019 15:17:25 +0000
Importance: Normal
We wait with bated breath
From:
(USANYS)
Sent: Thursday, April 04, 2019 11:17
To:
Subject: Epstein
Did we ever get a ruling from CM?
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
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=== Page 1 ===
From:
To:
)"
Subject: FW: [EXTERNAL] Ghislaine Maxwell 02879-506
Date: Wed, 20 Oct 2021 19:21:39 +0000
From: BOBBI C STERNHEIM
Sent: Wednesday, October 20, 2021 3:19 PM
To:
is
Cc: Christian Everdell
Subject: [EXTERNAL] Ghislaine Maxwell 02879-506
Good afternoon-
A telephonic court conference will be held tomorrow at noon.
Please confirm that arrangements are in place for Ms. Maxwell's participation.
Please contact me with any questions.
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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.
EFTA00018559


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=== Page 1 ===
From:
=
(USANYS)"
To:
)"
Subject: Accepted: Call re: Epstein FOIA
Date: Thu, 11 Mar 2021 20:29:34 +0000
Importance: Normal
Attachments: unnamed
EFTA00017901


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: REVEALED: We Found Billionaire Pedophile Jeffrey Epstein's Secret Charity
Date: Tue, 16 Apr 2019 21:38:32 +0000
Importance: Normal
https://www.thedailybeast.com/jefrey-epstein-has-a-secret-charity-heres-who-it-gave-money-to
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=== Page 1 ===
1
J8RsEPS1
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
3
UNITED STATES OF AMERICA,
4
V.
19 CR 490 (RMB)
5
JEFFREY EPSTEIN,
6
Defendant.
7
X
8
New York, N.Y.
August 27, 2019
9
10:30 a.m.
10
Before:
11
HON. RICHARD M. BERMAN,
12
District Judge
13
14
APPEARANCES
15
GEOFFREY S. BERMAN
United States Attorney for the
16
Southern District of New York
BY:
17
Assistant United States Attorneys
18
MARTIN G. WEINBERG, PC
19
Attorney for Defendant
BY: MARTIN G. WEINBERG
20
STEPTOE & JOHNSON, LLP
21
Attorneys for Defendant
BY: REID WEINGARTEN
22
MICHAEL MILLER
23
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00019994

=== Page 2 ===
2
J8RsEPS1
1
(Case called)
2
THE COURT: Good morning, everybody. Please be
3
seated.
4
So just some housekeeping. We have a podium here for
5
both attorneys and others who may be speaking, and so we would
6
like you, attorneys and others who are speaking, to come up to
7
the podium. This room is a little cavernous. We thought the
8
podium over there would be more comfortable.
9
For starters, and for this you don't have to go up to
10
the podium, if you could just indicate your names. This table
11
in front to my left, your right, are defense counsel, and that
12
table to my right, your left, are government attorneys.
13
If we could just ask the attorneys to introduce
14
themselves.
15
MS.
: Good morning, your Honor.
16
and
for the government. Joining us at counsel table
17
are Special Agent
of the FBI and Detective Paul
18
Byrne of the NYPD.
19
MR. WEINGARTEN: Good morning, your Honor.
20
Reid Weingarten.
21
MR. WEINBERG: Martin Weinberg.
22
Good morning, your Honor.
23
THE COURT: Good morning.
24
MR. MILLER: Good morning, your Honor.
25
Michael Miller from Steptoe & Johnson on behalf of the
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defendant.
2
THE COURT: Great.
3
Again, good morning to all of you. This hearing that
4
we're having today considers the government's motion to dismiss
5
the indictment in this case.
6
I must add that it also serves as the opportunity for
7
me to thank all of you, the attorneys and the victims who are
8
here today, among others, for your very hard work and
9
dedication in this case.
10
We also have here today the U.S. Attorney for the
11
Southern District of New York, Geoffrey Berman, who has also
12
been very helpful and indispensable in this matter.
13
The news on August 10, 2019, that Jeffrey Epstein had
14
been found dead in his cell at the Metropolitan Correctional
15
Center, at the MCC, was certainly shocking. Most of you, and
16
myself for that matter, were anticipating that the next steps
17
in this case would be defense motion practice, including a
18
motion to dismiss, followed by a trial on the merits before a
19
jury, if the motions were not successful, and through which the
20
accusers and the accused would come face to face, allowing
21
everyone to get their day in court. Mr. Epstein's death
22
obviously means that a trial in which he is a defendant cannot
23
take place. It is a rather stunning turn of events.
24
The government's motion to dismiss the indictment
25
because of Jeffrey Epstein's death on August 10, 2019, is
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relatively straightforward. In my view, a public hearing
2
clearly is nevertheless the preferred vehicle for its
3
resolution.
4
Incidentally, while I'm on this subject, I got some
5
help today from the New York Law Journal from two professors
6
who write that a hearing is -- let me tell you exactly what
7
they said. They say, in part, that this is an odd moment for
8
transparency in a criminal case. I think that is an odd
9
sentence to hear about, transparency in a criminal case.
10
They go on to say that normally, if a prosecutor seeks
11
to dismiss an indictment for such an obviously worthy reason,
12
the court would simply grant the request. As to that
13
statement, I respectfully say it is incorrect as a matter of
14
law.
15
They go on to say the judge would not schedule a
16
hearing and he definitely would not allow the victims to speak.
17
If he did hold a hearing, whatever informational interests the
18
victims may have would be served by affording them a chance to
19
attend the hearing, not by giving them a speaking role.
20
I read it. It was incredulous. I'm still
21
incredulous. I don't quite understand at all. There is a
22
suggestion in the article that the reason they are making these
23
suggestions has to do with minimization of drama in this case.
24
In the Jeffrey Epstein case, there has not been much a
25
minimization of drama, and what little drama might happen
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today, I don't think it would be very significant.
2
On a somewhat more serious note, don't quote me on
3
this, but it is my understanding that one of the authors of
4
that article is himself counsel in one of the Epstein-related
5
cases. I was surprised to learn that very recently. I'm
6
certain it is true. I was also surprised that that aspect was
7
not disclosed in the Law Journal.
8
But in any event, I think you know where I'm heading.
9
I respectfully disagree with the Law Journal piece. I was
10
saying that the government's motion is relatively
11
straightforward, and in my view, a public hearing is clearly,
12
nevertheless, the preferred vehicle for its resolution. I'm
13
still convinced of that.
14
A few may differ on this, but public hearings are
15
exactly what judges do. Hearings promote transparency and they
16
provide the court with insights and information which the court
17
may not otherwise be aware of.
18
The victims have been included in the proceeding today
19
both because of their relevant experiences and because they
20
should always be involved before rather than after the fact.
21
Indictment 19 CR 490 charges Jeffrey Epstein with sex
22
trafficking and with conspiracy to commit sex trafficking. The
23
U.S. Attorney, on August 19, 2019, requested that the court
24
approve the government's proposed order of nolle prosequi. I
25
think that's a rough justice. That means nolle prosequi,
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discontinuance by the prosecutor of all or of a part of the
2
case that he or she has commenced.
3
The government in its motion concludes that Epstein's
4
death abates these proceedings. In accordance with Federal
5
Rule of Criminal Procedure 57 (b), I determined to hold a public
6
hearing and I notified the victims that they would be given the
7
opportunity to be heard before any final action on the motion.
8
That is the purpose also of today's proceeding. I would do
9
that every time.
10
Also, recognized that Epstein, Mr. Epstein died before
11
any judgment of conviction against him had been obtained, and
12
that the government's proposed order appears, in form and
13
substance, to be appropriate.
14
Federal Rule of Criminal Procedure 48 (a) codifies the
15
nolle prosequi process. It is entitled dismissal, and it
16
states in relevant part that the government may, with leave of
17
the court, dismiss an indictment, information, or complaint,
18
and that leave of the court proviso, you should know, was added
19
as an amendment to the original draft of Rule 48, which had
20
originally provided for automatic dismissal upon the motion of
21
the government.
22
This proviso, in my judgment, is clearly directed
23
toward an independent judicial assessment of the public
24
interest in dismissing the indictment. Thus, even whereas, in
25
this case, the standard of court review is deferential, the
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court must still make its own independent determination. A
2
conclusory statement from the government that dismissal is
3
appropriate does not satisfy the court's obligations.
4
It is also, in my view, required that the court
5
consider the views of the victims in the case at the hearing
6
and before deciding whether to grant the motion. This is being
7
done here both as a matter of law and as a measure of respect
8
that we have for the victims' difficult decisions to come
9
forward in this matter.
10
In a case called United States V. Heaton,
11
H-e-a-t-o-n-, the government filed a Rule 48 motion for leave
12
to dismiss a charge against a defendant who allegedly committed
13
a sexual offense against a young victim. Although I should
14
point out, very importantly, that that defendant was still
15
alive, which distinguishes it from our case.
16
Nevertheless, I think it is irrelevant because in
17
evaluating the Rule 48 motion, then district Judge Paul G.
18
Cassell -- who is now a law professor at the University of Utah
19
and is regarded to be a noted expert in victims' rights --
20
concluded that under the Crime Victims' Rights Act, victims
21
have broad rights that extend to a court's decision whether to
22
grant a government motion to dismiss under Rule 48.
23
I completely share that viewpoint in these
24
circumstances, even though the facts of our case, as I said,
25
are somewhat different from those in Heaton. I believe it is
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the court's responsibility, and manifestly within its purview,
2
to ensure that the victims in this case are treated fairly and
3
with dignity.
4
The fundamental substantive principle which applies in
5
considering the government's motion is termed the rule of
6
abatement. This principle originated in the English common
7
law. It was adopted by most U.S. federal courts, but more
8
recently, it has faced some appropriate criticism. The rule of
9
abatement is best explained in the Second Circuit case of
10
U.S. V. Wright.
11
In that Wright case, two defendants had pled guilty to
12
embezzlement and tax evasion. Both defendants appealed, but
13
one of the defendants died while his appeal was pending in the
14
Second Circuit. The Court of Appeals rule that under the rule
15
of abatement, the judgment of conviction against the deceased
16
defendant was required to be vacated and the indictment was to
17
be dismissed. The Wright court held that when a convicted
18
defendant dies while his direct appeal as of right is pending,
19
his death abates not only the appeal, but also proceedings had
20
during the course of the prosecution.
21
The Second Circuit incidentally has also held that
22
when a criminal conviction abates upon the death of a
23
defendant, any restitution ordered as a result of that
24
conviction must also abate, and it is also ruled the same with
25
respect to associated forfeiture orders.
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This latter application of the rule of abatement
2
regarding forfeiture has not been universally accepted among
3
federal courts, but it certainly is the law in this circuit.
4
Some of you may be interested to know that some United States
5
courts, state courts, have criticized the rule of abatement,
6
particularly in the face of growing recognition of victims'
7
rights in the criminal justice system, including the Crime
8
Victims' Rights Act.
9
It has been written and contended in the Brooklyn Law
10
Review -- I can give you the cite later -- that when courts
11
abate criminal convictions, they reimpose a burden on victims
12
that legislatures intended to alleviate through these victim
13
rights statutes. The state Supreme Court has even concluded
14
that the expansion and codification of victims' rights provides
15
the changed conditions needed for overruling the rule of
16
abatement. It has also been stated that Alaska's statute and
17
its constitution now require the criminal justice system to
18
accommodate the rights of crime victims. Further, that the
19
abatement of criminal convictions has important implications
20
for these rights.
21
But coming back to our case, which is what you are
22
concerned about and I am as well, it is appropriate to conclude
23
that if the rule of abatement applies to a convicted defendant
24
as in the Wright case, it should also apply a fortiori in the
25
Epstein case, which was still in the pretrial phase when
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Mr. Epstein died, when there had been no conviction.
2
So that's just some background I wanted to share with
3
you. At this point in time, I would like to turn to the
4
government prosecutors to hear from them in support of their
5
Rule 48 application to dismiss the Epstein indictment.
6
MS.
: Thank you, your Honor.
7
Would you like me to address the court from the
8
podium?
9
THE COURT: If you wouldn't mind.
10
MS.
: Thank you, your Honor.
11
I believe your Honor has accurately summarized the
12
state of the law, as set forth in our papers, in light of the
13
clear Second Circuit law, that upon the death of a defendant
14
before a final entry of a judgment of conviction, all
15
proceedings must be abated.
16
In light of that clear law, the government is legally
17
obligated to seek dismissal of the pending indictment against
18
Jeffrey Epstein, and we respectfully submit, likewise, that the
19
entry of the proposed order is similarly required by law.
20
A few notes to make about that, though, your Honor.
21
To be very clear, dismissal of this indictment as to Jeffrey
22
Epstein in no way prohibits or inhibits the government's
23
ongoing investigation into other potential coconspirators, nor
24
does it prevent the bringing of a new case in the future or the
25
prosecution of new defendants.
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It also does nothing to prevent the government from
2
continuing to explore the possibility of seeking civil
3
forfeiture of any assets that were used to facilitate the
4
crimes charged in this indictment. Indeed, as has been stated
5
publicly, investigations into those matters have been ongoing,
6
remain ongoing, and will continue following dismissal of the
7
indictment here.
8
I would also like to note that, as the government has
9
previously mentioned, this dismissal in no way lessens the
10
government's resolve to stand up for the victims in this case,
11
both those who have come forward and those who have yet to do
12
SO. We agree with your Honor's sentiment that those victims
13
should be respected, and we appreciate your Honor's recognition
14
of that.
15
One housekeeping matter that I did want to reference
16
for your Honor. The protective order in this case requires
17
destruction or return of any and all discovery material upon
18
conclusion of the case. We have been in communication with
19
defense counsel, who have confirmed that they have returned all
20
physical copies that they have of discovery that the government
21
has produced to date, and they are in the process of deleting
22
any copies that they may have made. So the parties are in
23
compliance with the protective order.
24
Finally, I just wanted to say a word about the victims
25
in this case, and particularly those who are here in court
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today. I'll note that in light of the court's order indicating
2
that the victims and their counsel would be permitted to be
3
heard in court here today, the government has endeavored to
4
provide notice to all known victims of today's proceeding. We
5
did so either directly where a victim was not represented by
6
counsel or through counsel where a victim is represented by an
7
attorney.
8
The government does not know exactly how many victims
9
or their attorneys are here today and we do not know how many
10
of them or their counsel would like to speak. To the extent
11
any individuals do wish to speak, we do not know the substance
12
of what they would like to say. We have left that entirely up
13
to the individual decisions of the victims and their attorneys.
14
I will note, though, that throughout this case, the
15
government has endeavored and done our utmost to fulfill our
16
obligations under the Crimes Victims' Rights Act. We have done
17
so by trying to keep as many victims as we are aware of up to
18
date about the ongoing case and about any developments in the
19
case.
20
We will continue to provide services and offer
21
services to any of the victims in this case, even after the
22
indictment is dismissed. Both the U.S. Attorney's office and
23
the FBI have been in touch with all known victims or have
24
attempted to be in touch with all known victims, either again
25
directly where victims are not represented by counsel or
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through counsel where they have attorneys. We have expressed
2
to them that services are available for those who wish to take
3
advantage of them.
4
Unless the court has any questions for me, the
5
government will otherwise rest on its papers.
6
THE COURT: I just have one question.
7
The protective order, is that self-executing or do I
8
need to do something?
9
MS.
: It is self-executing, your Honor.
10
THE COURT: Thanks very much, Ms.
.
11
MS.
: Thank you, your Honor.
12
THE COURT: Yes.
13
I'll turn to counsel for the defense at this time.
14
Mr. Weingarten, I'm happy to hear from you.
15
MR. WEINGARTEN: Thank you.
16
Your Honor, I think it is an understatement of the
17
year to say the world looks and feels differently today than it
18
did the last time I was before you. For us, the elephant in
19
the room is what happened to our client. I would like to tell
20
you how we see the world and where we are on that subject.
21
We start with the Attorney General's statements,
22
public statements, that there were very serious improprieties
23
in the jail. We obviously read the press. We see that the
24
warden has been taken out. We see that the guards on duty at
25
the time have been put on leave. We understand guards are
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refusing to cooperate with the investigation. We have heard
2
allegations that people at the time who had responsibility for
3
protecting our client falsified information. We understand
4
that there were orders out there that Jeffrey Epstein was never
5
to be left alone and that the orders were ignored by many of
6
the employees of the prison.
7
In a word, yikes. In addition, obviously we followed
8
the medical examiner's report, or we haven't followed the
9
report, we haven't seen it, but heard conclusions, initially
10
not enough evidence to come to a conclusion, wanted to see
11
more. We assumed she was talking about the videotapes, but
12
then came to the conclusion that it was suicide.
13
We report to the court that --
14
THE COURT: Suicide by hanging --
15
MR. WEINGARTEN: Yes.
16
THE COURT: -- was her conclusion?
17
MR. WEINGARTEN: Yes.
18
And we report to the court that we had a doctor there
19
at the time, and we also have been in receipt of a tremendous
20
amount of medical and scientific evidence volunteered to us
21
opining that the injuries suffered, as reported, were far more
22
consistent with assault than with suicide, and we are happy to
23
supply the court with all the information that we have.
24
Now, in addition, as the court noted, we were underway
25
with our pretrial motions, and as the court obviously
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understands, the NPA and the role of the NPA was going to be
2
critically important. And I would simply like to report that
3
we went pretty far along.
4
We interviewed all of the relevant lawyers on the
5
defense side who participated in the NPA, and we were satisfied
6
that we had a very strong argument that every one of those
7
lawyers believed with an objective basis that the deal was
8
global. That is, at the time --
9
THE COURT: I'm sorry, that?
10
MR. WEINGARTEN: The deal of the NPA was global. That
11
is, more specifically, at the time, the Florida prosecutors and
12
agents knew of conduct in New York, and that no competent
13
defense counsel negotiating in good faith with the prosecutors
14
would have ever agreed to a deal back then that allowed New
15
York prosecutors to indict for precisely the same conduct in
16
the future, which, of course, is what happened.
17
In addition, we have come up with very powerful
18
evidence, we believe, that Florida prosecutors, who
19
participated in the deal, steered the victims and the alleged
20
victims to New York on more than one occasion because they did
21
not want to suffer the sleights of attacks against them. So we
22
have advanced the ball on this very subject and we are prepared
23
to completely report to the court as to where we are and what
24
we've done.
25
Another point. We obviously had contact with our
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client at or around the time of his death, and obviously the
2
attorney-client privilege survives death and we are not going
3
to forfeit the privilege, but we will report to the court, with
4
as much specificity as the court may want, that at or around
5
the time of his death, we did not see a despairing, despondent
6
suicidal person. Details to follow, if the court wishes.
7
The 800-pound gorilla, for us, of course, are the
8
video surveillance tapes. Obviously we assume there is a tape
9
that leads directly to the door where Jeffrey Epstein was
10
housed. If that tape reports for 12 hours before his death
11
that no one went in and out of that room, then the suggestion
12
that there was something other than a suicide seems
13
preposterous.
14
But there is no such evidence that has surfaced to
15
date. Just the opposite. We have heard, and we actually read
16
in the press, that the tapes were either corrupted or not
17
functioning. Talk about a yikes. If, in fact, the system was
18
broken for six months before Jeffrey Epstein was housed, I
19
mean, that would be stunning incompetence. If it was allowed
20
to continue to be inoperative when Jeffrey Epstein was housed,
21
it would be incompetence times ten. But what if the tapes only
22
broke down or were inoperative or were corrupted on the day he
23
was killed or the day he died? Then we're in a completely
24
different situation.
25
So where does this lead? I think where it leads,
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Judge, is there are incredibly important questions that remain
2
open. The public interest in this matter is obvious from this
3
courtroom. There are conspiracy theories galore. We are all
4
for finding the truth. We believe this court has an
5
indispensable role to play.
6
Whether or not this indictment is dismissed, I think
7
this court has the inherent authority to find out what happened
8
on its watch. Obviously, when the court detained Jeffrey
9
Epstein, the court did not anticipate that weeks later he would
10
be dead in his cell. I think given the inherent authority of
11
the court, the court should make inquiry.
12
This could come in many forms. Obviously the court
13
made inquiry as to what happened in the first incident. When
14
there was an allegation of an attempted suicide, the court made
15
inquiry. The court obviously was interested.
16
I recall your language. You talked about that being
17
one of the several open questions indicating an interest on the
18
court for the others as well. Obviously, the ultimate question
19
is what happened to the client.
20
THE COURT: You're talking about the July 23, 2019
21
incident?
22
MR. WEINGARTEN: Yes.
23
The court obviously could hold hearings. The court
24
could assign a lawyer to help the court. I think this is an
25
area where there is intense public interest. We have complete
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confidence in the prosecutors in the Southern District and the
2
FBI to do a competent investigation. But these are allegations
3
against serious components of the United States Department of
4
Justice. Sometimes the appearance of justice is just as
5
important as justice itself.
6
I think the court supervising, or at least keeping an
7
interest in this proceeding, is incredibly important for the
8
public to have confidence in the ultimate findings, and
9
certainly for us to have confidence in the ultimate findings.
10
One more issue, Judge. The conditions of the jail, in
11
a word, they were dreadful. Not just for Jeffrey Epstein, but
12
for many of the prisoners over there. This is a prison within
13
the shadows of this courthouse. The situation is rife with
14
vermin. The abuse and the conditions in that prison, in a
15
word, are a disgrace and everybody knows it.
16
A person with authority told us, someone with
17
knowledge, that the prisoners in Guantanamo -- and he spoke
18
with personal knowledge -- are treated better than the
19
prisoners right across the way. The feds certainly know how to
20
run a disciplined, clean prison. I've been in 20 of them.
21
They know how to do it just fine. And the question is, why in
22
the world does it not happen down the road? I think that is a
23
perfectly legitimate subject for the court to make inquiry.
24
In a word, we want the court to help us find out what
25
happened. The court has a role to play. It is the institution
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1
that most people have confidence in in these very troubled
2
times.
3
So whether or not you dismiss the indictment, to us,
4
is beside the point. We want you to stay on the case, we want
5
you to conduct an investigation, and we want to know what
6
happened here.
7
Thank you, your Honor.
8
THE COURT: Just so it is clear, so your view on the
9
motion directly on its merits of the nolle prosequi order and
10
application by the U.S. Attorney, do you have a view on that?
11
MR. WEINGARTEN: I think if the court felt that the
12
case had to stay alive for the court to continue, we would
13
oppose it. I think --
14
THE COURT: I'm sorry, if what?
15
MR. WEINGARTEN: If the issue, if you took the
16
position for you to conduct the investigation or lead the
17
investigation or participate in the investigation, then we
18
want, the role we want you to play, if the indictment has to be
19
alive, we would oppose the motion.
20
I don't think you need to do that. I think you can
21
dismiss the indictment.
22
THE COURT: So you're suggesting that you support the
23
government's motion, just viewed in the context of --
24
MR. WEINGARTEN: Yes, of course.
25
THE COURT: Great.
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MR. WEINBERG: Judge, if I can just supplement?
2
THE COURT: Absolutely.
3
MR. WEINBERG: Thank you, sir.
4
Thank you, as an out-of-town lawyer for the privilege
5
to appear in front of you, your Honor.
6
THE COURT: It's my pleasure.
7
MR. WEINBERG: First, as to the conditions, we think
8
your Honor trusted the government, the Bureau of Prisons, to
9
keep our client safe and keep him in civilized conditions. The
10
government will again ask, as to other defendants, that they be
11
detained at the MCC, some subset of them will end up in the SHU
12
unit.
13
It is a horrific. I've called it medieval. There's
14
vermin on the floor. There is wet from the plumbing. There is
15
no sunlight. There is limited exercise. It is simply
16
conditions that no pretrial detainee -- and I would go farther
17
as a criminal defense lawyer -- no United States defendant
18
should be subjected to.
19
Certain judges have taken views of the conditions. We
20
would urge your Honor, the government talks about and we talk
21
about transparency, to see what kind of conditions there exist
22
within 50 or 100 yards of one of the great United States
23
district courts.
24
Second, in terms, we have a profound problem with the
25
conclusions of the medical examiner. There are for three
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reasons, your Honor.
2
One is the timing of Mr. Epstein's demise. It was on
3
August 10. On August 12, a bail pending appeal motion was
4
being filed in the Second Circuit. On August 12 or 13, the
5
United States Attorneys were going to respond to our request
6
for the preservation and production of documents that would
7
have facilitated and furthered our efforts to demonstrate
8
communications between the Southern District of Florida, the
9
Northern District of Georgia, which was standing in the shoes
10
of the Southern District of Florida main justice and the
11
Southern District.
12
In other words, we were beginning the process
13
discharging our responsibilities. There had been no new
14
evidence that Mr. Epstein had committed any offense against a
15
minor after 2005. The subject matter of the New York
16
prosecution was squarely within the heartland of the Florida
17
NPA. We had a significant motion to dismiss. This was not a
18
futile, you know, defeatist attitude.
19
Third, we had all the discovery motions that your
20
Honor had scheduled. So the timing for a pretrial detainee to
21
commit suicide on August 10, when his bail pending appeal
22
motion is being filed on August 12, strikes us as implausible.
23
Second, we had an independent doctor who was present
24
at the autopsy which occurred on August 11. On August 11, the
25
city medical examiner's findings were inconclusive. We are
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told by a very experienced forensic pathologist that the broken
2
bones in Mr. Epstein's neck, in his larynx, are more consistent
3
with external pressure, with strangulation, with homicide, if
4
you will, than with suicide. It doesn't exclude suicide, but
5
the pure medical forensic evidence creates profound issues
6
about what happened to him.
7
Also the time of death. Our medical examiner's
8
opinion is it occurred at least 45 minutes and probably hours
9
before 6:30 a.m. on August 10, when he was first found, if you
10
will, according to the reports. Yet he was moved, something
11
that is not ordinary in these circumstances.
12
I would also --
13
THE COURT: Excuse me. He was moved?
14
MR. WEINBERG: Instead of having the cell in the
15
condition it was found, if he had been dead for 45 minutes or
16
two hours or four hours, there were efforts to move him and,
17
therefore, make it more difficult to reconstruct whether or not
18
he died of suicide or some other cause.
19
I spoke to Stacey Richmond, who is a responsible
20
member of this court who represents the family of Mr. Epstein.
21
She spoke to the medical examiner on the Friday after
22
Mr. Epstein's death and asked why, if the conclusion was made
23
late in the afternoon on Friday that week. She specifically
24
asked about what extrinsic nonmedical evidence caused the
25
medical examiner to go from uncertain to suicide, and she was
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told that the medical examiner had seen nine minutes of one
2
video which was on a stairwell between floors at the MCC. She
3
was told that the principal video that would have showed the
4
whole hall was corrupted. It was in DC with the FBI to see if
5
they can reconstruct it.
6
And I asked the same questions that my co-counsel did,
7
you know, was the dysfunction of the critical pivotal video, in
8
the most secure prison east of Florence, out in Colorado known
9
to the MCC before August 10, or was this corruption occurring
10
on August 10, which would again cause us to be skeptical of the
11
servitude of the medical examiner's conclusions that this was
12
suicide rather than some other cause.
13
So with my co-counsel, we ask your Honor, it is not a
14
question of trust or not trust. They ask you to detain people
15
and you trust the Bureau of Prisons. And it is within your
16
inherit authority, your Honor, to find out what happened to our
17
client.
18
We are angry about the conditions he was held in. And
19
we're also angry, quite frankly, your Honor, that the only
20
source of information that we get as to what happened to him is
21
through the media rather than through the United States
22
Attorney's office. We've made requests informal. We have
23
made Touhy requests. We've been told there is a pending
24
investigation.
25
But we trust your Honor and the judiciary, and with
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all due respect, we believe there is an inherent and central
2
role, a pivotal role in your Honor to find out what happened to
3
a defendant in a case before the court, whether or not the
4
court grants the nolle pros today or whether it holds it
5
pending an investigation into Mr. Epstein's death.
6
We're not here without significant doubts regarding
7
the conclusion of suicide. We are not here to say what
8
happened. We don't know what happened. But we deeply want to
9
know what happened to our client.
10
Thank you, sir.
11
THE COURT: And you, as Mr. Weingarten, have the same
12
view of the nolle prosequi motion?
13
MR. WEINBERG: Yes, your Honor.
14
THE COURT: OK.
15
MS.
: Your Honor, may I respond to some of those
16
points?
17
THE COURT: Sure.
18
MS.
: Thank you, your Honor.
19
Just briefly. With the exception of the noting that
20
the defense does not have an objection to the government's
21
motion, virtually everything else that defense counsel just
22
argued, respectfully is completely irrelevant to the purposes
23
of today's proceeding and to the motion that is pending before
24
your Honor.
25
As an initial matter, the question --
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THE COURT: Well, it may be. Well, I don't know. You
2
say irrelevant.
3
It is a public hearing, and I think it is fair game
4
for defense counsel to raise its concerns.
5
MS.
: Certainly, your Honor. But it is
6
irrelevant to whether or not the motion should be granted.
7
THE COURT: Right. I get that.
8
MS.
: I would also note that the question of
9
Mr. Epstein's death is the subject of an ongoing and active
10
investigation, as has been publicly noted, by a separate team
11
of Assistant United States Attorneys from the Southern District
12
of New York, separate from the team who is handling this
13
prosecution, as well as a separate team of FBI agents.
14
There is an ongoing and active grand jury
15
investigation into the circumstances surrounding Mr. Epstein's
16
death. It is the function of a grand jury and of the Federal
17
Bureau of Investigation to investigate crimes in the federal
18
court system. It is not the purview, respectfully, of the
19
court to conduct an investigation into uncharged matters.
20
So respectfully, we disagree with defense counsel's
21
suggestion that the court has some authority to conduct an
22
independent investigation. To the extent any other defendants
23
who are detained in the MCC have concerns about the conditions
24
or believe that the conditions are relevant to a future or
25
current bail determination, it is for those defendants and
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their counsel to raise those arguments and for the judges
2
hearing those arguments to evaluate those claims. It is not
3
relevant to today's proceedings.
4
Thank you, your Honor.
5
THE COURT: In those other cases, Ms.
,
judges do
6
have authority to investigate, but don't here?
7
MS.
:
Not to investigate, your Honor, but to
8
hear arguments about the conditions of confinement in the MCC
9
as they may relate to any bail determination. I believe that
10
was the argument that was made.
11
The bigger picture here, your Honor, is that the focus
12
of today's proceeding, as we understand it, is to allow the
13
victims who have gathered here today to be heard and to comment
14
upon the case and to comment upon the motion that is pending,
15
and to bring this case to a close.
16
THE COURT: Got it.
17
MR. WEINGARTEN: May I?
18
THE COURT: Sure.
19
MR. WEINGARTEN: We obviously saw this as, perhaps,
20
the last opportunity to be before you, and we wanted to take
21
advantage of the opportunity to say our peace and thank you for
22
allowing us.
23
There is precedent here. Ted Stevens, the Senator
24
from Alaska case in Washington, DC, Judge Emmet Sullivan
25
ordered an independent investigation by a private lawyer when
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he was deeply troubled by the alleged Brady violations. I
2
represented the prosecutors in that case, so I'm very, very
3
familiar with it.
4
It is analogous. It is a situation where there was
5
tremendous controversy over what happened in the case and
6
whether or not the prosecutors went off the reservation. Judge
7
Sullivan -- and there were three or four independent -- not
8
independent, DOJ inquiries into the very same matter. But
9
Judge Sullivan wanted his own opportunity to make a judgment
10
with his own independent investigation.
11
THE COURT: OK.
12
MR. WEINBERG: If I could just add one precedent, your
13
Honor.
14
The Chief judge in the District of Massachusetts or
15
the Chief Judge at the time, Judge Wolf, in a case called
16
U.S. V. Fleming, when the conditions at Walpole, which is a
17
state prison where federal prisoners were being held -- we
18
don't have a federal MCC in Boston -- went to the prison,
19
stayed in the prison to determine whether or not the complaints
20
about the conditions were authentic.
21
I think your Honor has the inherent authority to go to
22
the ninth floor and see how the MCC houses pretrial detainees.
23
Thank you.
24
THE COURT: Are you saying that whether or not the
25
motion is granted that is pending before us?
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MR. WEINBERG: Yes, your Honor.
2
I think, like when appeals are taken, bail issues
3
remain before the district court. Jurisdiction is not
4
completely divested. Your Honor issued a pretrial detention
5
order and your Honor has the power, the inherent authority,
6
they are not going to refuse to allow you to go look at the
7
ninth floor. They are going to count on you to make decisions
8
in the future.
9
I just trust that the executive branch is not going to
10
prevent the judicial branch from looking into the death of
11
Jeffrey Epstein or the conditions in the SHU unit at the MCC,
12
sir.
13
THE COURT: Great. Thank you.
14
MS.
: May I, your Honor?
15
Just very briefly, your Honor. I would note that upon
16
the dismissal of the indictment, which I believe the parties
17
agree is appropriate in this case, there would be no case.
18
There would be no jurisdiction for the court to conduct any
19
sort of inquiry, even if the court had such authority.
20
THE COURT: Right.
21
OK. I think we've heard enough.
22
It is at this point in the hearing that I would like
23
to call upon victims' counsel, plural, for any remarks they may
24
have and they may wish to make. Also, to introduce their
25
clients, those of them who wish to be heard.
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It would be helpful if, in doing that, if counsel --
2
Mr. Edwards and I see and I see Mr. Boise as well -- I know
3
they are counsel to several, at least several of the victims.
4
It would be helpful if whoever is speaking, both Mr. Edwards
5
and Mr. Boise, would indicate to the court whether or not they
6
have discussed the pending motion with their clients, that is
7
to say and the rule of abatement, etc., etc. with them prior to
8
today's hearing.
9
Are we going to hear from Mr. Edwards first, is that
10
right?
11
MR. EDWARDS: Thank you, your Honor.
12
THE COURT: You bet.
13
It would be helpful, Mr. Edwards, if you would state
14
and spell your name for the court reporter.
15
If you are going to introduce someone else, which I
16
trust that you are, if you could state and spell their name as
17
well.
18
MR. EDWARDS: Yes, your Honor.
19
May it please the court. Brad Edwards, B-r-a-d
20
E-d-w-a-r-d-s, with the law firm of Edwards Pottinger.
21
I have in the courtroom today 15 victims that I
22
represent and have represented over the years. There are at
23
least 20 more who didn't make this hearing today for a
24
multitude of reasons, some out of fear of public exposure,
25
others because the way in which this case ended will never
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bring full justice, and they decided it was best for them not
2
to talk today.
3
Some of my clients are going to address the court that
4
are here today. Others are not. Some are going to use their
5
names, and have in the past, and others wish to remain
6
anonymous. And I have instructed each of them to inform the
7
court reporter that they will be proceeding as Jane Doe so that
8
the court reporter can take them down.
9
THE COURT: For those who wish to remain anonymous?
10
MR. EDWARDS: Exactly, your Honor.
11
THE COURT: And that is satisfactory, as far as I am
12
concerned.
13
MR. EDWARDS: Before we do that, I would like to
14
address a couple of the things that have occurred this morning.
15
First of all, whether relevant or not, I personally,
16
and on behalf of my clients, do appreciate the presentation
17
that Mr. Weingarten made and Mr. Marty Weinberg made.
18
I have tremendous respect for Mr. Weinberg. I've
19
worked with him through this and related cases for years, and I
20
understand the reason why they made the presentation that they
21
made.
22
There is two things of interest to our clients in that
23
respect. One is, because of the tragic ending, that none of my
24
clients wanted, nor did I, nor did anyone else, if there is
25
some civil rights violation and there is some civil remedy for
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Mr. Epstein that goes to the estate, certainly the victims are
2
interested in that as they might help to repair the damage
3
done.
4
Second, Mr. Epstein's untimely death, the timing is
5
curious to us. But more so, it makes it absolutely impossible
6
for the victims to ever get the day in court that they wanted
7
in court and to get full justice. That now can never happen.
8
I know that Mr. Epstein's attorneys say he wanted it, and they
9
know, we did too. And there are a lot of people here today
10
that are very sad by the way that this ended for both
11
Mr. Epstein and the fact that full justice was robbed from
12
them, once again.
13
The second issue I wanted to address was the Law
14
Review or the Law Journal article that your Honor referenced,
15
which is troubling because the opinion seems to say that
16
transparency is not appropriate in the criminal system and is
17
not appropriate at this point in time.
18
That's tough to swallow, especially in this case,
19
given the long history of this case. Personally, it is tough
20
to swallow, and on behalf of my clients, I can say that is very
21
concerning. Transparency is the only way that the justice
22
system works. We know this because there was a similar
23
investigation of Mr. Epstein many years ago, from 2005 to 2008.
24
My personal involvement in this case was because a
25
young female came into my office named
and she
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came to me not asking to file a lawsuit against Jeffrey
2
Epstein, but simply asking for the government to talk to her.
3
She was cooperating in an FBI investigation and wanted the
4
government to speak with her, and I thought that was going to
5
be an easy task.
6
It was only a few months later that we learned that
7
this investigation that was represented to my client in written
8
form, that it would be a long investigation, and to be patient.
9
Basically, to hang tight. It was resolved by way of a secret
10
deal that never allowed any of the more than 30 victims who had
11
been identified of Mr. Epstein's abuse in Florida to ever
12
participate in a single hearing. There was a hearing. They
13
were never notified.
14
I then went on to represent many of them in civil
15
cases and also in extensive pro bono work. And I can tell your
16
Honor that while Jeffrey Epstein's abuse of them hurt them and
17
harmed them for many years, the feelings they had was
18
aggravated exponentially by the facts that they had no rights
19
in the criminal justice system, by the fact that they were
20
treated as if they didn't matter. They were not allowed their
21
rights under the Crime Victims' Rights Act to meaningfully
22
confer with prosecutors, to be treated with fairness, to be
23
treated with dignity. That is what this is supposed to be
24
about, and to have notice of hearings.
25
So I do want to thank your Honor, and especially the
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prosecutors who have worked this investigation and this case,
2
which is very different in experience for all of my clients and
3
the other Epstein victims in this case, because they were
4
allowed to be a part of the process. While some of them
5
elected not to be here today, that opportunity should always be
6
allowed for them.
7
In 2008, we filed that case under the Crime Victims'
8
Rights Act because our clients' rights were violated, and as
9
your Honor knows, a federal judge has ruled in our clients'
10
favor that their rights were violated. So this hearing today
11
means a lot to them. The fact that they may never get their
12
chance to speak in court, they may never get complete closure,
13
and all of us have to wonder, if their rights had been afforded
14
them the first time, would any of us be here right now. Or
15
wouldn't it more likely be the case that everyone, including
16
Jeffrey Epstein, would have turned out better for it?
17
Today, I have not only represented, but met and become
18
very close with many of these victims. Many of these
19
survivors. They are very strong people. They are people who
20
have persevered through a lot of adversity. It's been a roller
21
coaster of emotions that has led us to where we are today. And
22
while they have all been cast over the years because of the
23
secrecy of the first investigation, in the shadow as victims,
24
you can't put them all in one bucket and say one size fits all.
25
They are each individual people who were harmed differently and
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distinctly through not only the abuse, but the system.
2
And on behalf of all of them, I would like to thank
3
your Honor for the fairness with which they've been treated,
4
and the United States Attorney's office for the way in which
5
you have handled this investigation, and especially how you
6
have treated the victims in this case.
7
Like I said, I have many who want to speak. Some that
8
can't. This is a very difficult day for them. But we
9
appreciate the opportunity and the invitation.
10
The first client that I have that is going to address
11
your Honor is the one who walked into my office in 2008 asking
12
just to be heard,
.
13
THE COURT: Hold on one second. Did you all want to
14
be seated?
15
You don't need to be standing. Whatever is more
16
comfortable until you're ready to give some comments. It's up
17
to you.
18
,
if you could spell your name for the court
19
reporters, please.
20
last name
21
22
(Continued on next page)
23
24
25
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My name is
and I'm a victim
2
of Jeffrey Epstein. Jeffrey Epstein sexually abused me for
3
years, robbing me of my innocence and mental health. Jeffrey
4
Epstein has done nothing but manipulate our justice system,
5
where he has never been held accountable for his actions, even
6
to this day.
7
Jeffrey Epstein robbed myself and all the other
8
victims of our day in court to confront him one by one, and for
9
that he is a coward.
10
I want to thank the U.S. Attorney's for seeking
11
justice that has been long over due, and most importantly,
12
given us, the victims, our day in court to speak our peace and
13
find some sort of closure. I feel very angry and sad that
14
justice has never been served in this case. Thank you.
15
THE COURT: Thanks very much.
16
MR. EDWARDS: I believe my next client who is going to
17
speak is probably going to speak as Jane Doe.
18
JANE DOE NO. 1: Yes, Jane Doe.
19
THE COURT: We'll say Jane Doe No. 1, just for the
20
record.
21
JANE DOE NO. 1: Okay. Thank you for allowing us to
22
speak today. I've shifted what I want to say in hearing
23
what's already been said, and just about the question of
24
Jeffrey's death. I don't know what the relevance is to this
25
hearing, but I do know that it is profoundly relevant to my
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life, as a victim. I don't like that word, but I still feel
2
like I am learning the ways that he's impacted me as a complex
3
situation, but he was also a major part of my life. As
4
destructive as that relationship was and as much of a villain
5
as we have created him to be -- based on facts we've created
6
him to be a villain -- he's a complex villain and actually all
7
of that is irrelevant. Anybody deserves -- an investigation is
8
the right thing to do. Like, we do need to know how he died.
9
It felt like a whole new trauma all over again, and I
10
don't know why, you know, because I -- I'm trying to defend
11
myself against him at this point in my life, but it still does
12
not feel good. It didn't feel good to wake up that morning and
13
find out that he had allegedly committed suicide. Okay. But I
14
also wanted to say to the press, I'm reading -- I read my story
15
in the paper. I read so many other girls' stories that are so
16
similar to my own, and everything that's been focused on is not
17
the most important part of it.
18
There was -- the problem with focusing on these, the
19
facts of the situation, that were out of the ordinary and like
20
because he was such a grand person, and it was just a unique
21
situation. I know that that's the more interesting side of the
22
story, but I don't want to be used as entertainment. And the
23
problem, the fundamental problem of the whole situation is the
24
element of exploitation and coercion, and these are things that
25
so many girls can relate to.
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And even though this Jeffrey Epstein brought it to a
2
grand scale, on some level, a lot of girls could relate to the
3
trauma that we are talking about, and even though this whole
4
situation sucks, I would like to think that it may be possibly
5
a catalyst for change because, obviously, as we're seeing with
6
the "Me Too" movement, change needs to happen and it's -- what
7
I'm seeing in the papers is not a common story, but it's so
8
much more common than you realize. That's all. Thank you.
9
THE COURT: Thank you very much.
10
MR. EDWARDS: I believe that the next client is going
11
to also be a Jane Doe; so I think for the purposes of the
12
record it will be Jane Doe 2.
13
THE COURT: Yes.
14
JANE DOE NO. 2: Good morning, your Honor.
15
THE COURT: Good morning. How are you?
16
JANE DOE NO. 2: Doing okay. I hadn't prepared any
17
words to speak today, but there is something that was on my
18
mind this morning when I got here. It's been on my mind in
19
reading through the press and through the people that I've
20
spoken to about it, friends, family. It's something that's
21
bothered me because I think it has a lot of blame in it, as
22
well, a little bit of what my friend, who was up here, was
23
speaking about.
24
I think that a lot of people asked why we spent so
25
much time, why we stayed. It's an experience that's really
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hard to explain to people who haven't gone through it. I think
2
there's a writer, Thomas Nagel, who wrote an essay called "What
3
is it like to be a bat?" And I think that he touches on it
4
pretty strongly and if you haven't experienced something, it's
5
very hard to fully understand why someone makes the decisions
6
they do and what the circumstances were.
7
I don't want to speak for all of the victims. I think
8
each of us has a different story and different circumstances
9
for why we stayed in it, but for me, I think he was really
10
strategic in how he approached each of us. Things happened
11
slowly over time. We didn't -- it almost was like, putting it
12
like that analogy of a frog being in a pan of water and slowly
13
turning the flame up. You didn't realize it was happening, and
14
it just -- I don't think anyone can fully understand the
15
experience, but I just -- the blame feels very strong.
16
There's a lot of support as well, but I just want
17
people to try and understand that we aren't bad people. We
18
weren't trying to -- it wasn't a situation where we were trying
19
to extort money from someone. A lot of us were in very
20
vulnerable situations and in extreme poverty, circumstances
21
where we didn't have anyone on our side, to speak on our
22
behalf, and that's really scary.
23
You start to blame yourself because, at first, you
24
don't tell anyone what's happening, and it becomes your deep,
25
dark secret that you tried to keep from everyone. And I didn't
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even know I was a victim until I spoke with my lawyers. I had
2
no idea. I had so much self-hatred and doubt and just guilt
3
for everything. I still do. I still don't feel like I deserve
4
to say I'm a victim, and I think that's a big problem with our
5
society right now, that people are still blaming victims, and I
6
think that does need to change.
7
I hope that today people understand that each of us
8
has a story, has a past, has a family and just give us a chance
9
to -- you know, that's basically all I just wanted to say.
10
THE COURT: Thank you so much.
11
JANE DOE NO. 2: Thank you so much.
12
THE COURT: Okay.
13
MR. EDWARDS: Okay. I think that the next person who
14
is going to speak is also going to be speaking as Jane Doe; so
15
for the purpose of the record, Jane Doe No. 3.
16
JANE DOE NO. 3: Thank you for allowing us to speak
17
today. I came to New York City 15 years ago to pursue modeling
18
from a small town. I signed on with an agency and was excited
19
to pursue my passion and my dream. Several months later, I met
20
a female who told me about Mr. Epstein. She portrayed him as
21
an amazing man who genuinely cared for people and that he was
22
going to be able to help me in a modeling career.
23
I was excited to meet him, after hearing her talk
24
about him. He sounded like an amazing person. An introduction
25
was made at his New York home, and it is there that I was
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sexually assaulted. I left his home, after he threw me,
2
basically put money on the table, and I was ashamed. I was
3
embarrassed. This was not the way I was brought up, and I
4
couldn't believe this had happened to me.
5
I left and my world kind of spiraled after that. I
6
stopped going on modeling castings. I gained weight. I became
7
depressed. I stopped going out with my friends, and only five
8
months after I had been in New York City to pursue my dream, I
9
left. I left the modeling industry, and I left New York City,
10
and I totally switched my career paths.
11
I buried this deep within me, and all of the new
12
occurrences that have come up in the media is what brought it
13
back up for me. And I feel sickened and saddened that it took
14
so many years, and God knows how many victims, for this to
15
finally come out, but I'm thankful it did. And I'm just angry
16
that he's not alive anymore to have to pay the price for his
17
actions. So I thank you for your time.
18
THE COURT: You're very welcome.
19
MR. EDWARDS: Your Honor, Jane Doe No. 4, I believe,
20
is going to speak now.
21
JANE DOE NO. 4: Good morning, your Honor.
22
THE COURT: Good morning.
23
JANE DOE NO. 4: I just have something very short to
24
say. I met Jeffrey Epstein at a very vulnerable place in my
25
life, and whatever the outcome is with everything, I just
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wanted to express that we, the victims, we will always carry
2
irreparable damage and pain throughout our lives after this.
3
It's something that's never going to go away.
4
You know, whoever we marry in our life, whatever
5
future we have in our life, it's always going to be something
6
that's always there for us. And I'm very nervous right now.
7
And Jeffrey Epstein, he took away the chance I had at having
8
the future I had envisioned for myself as a young girl, and I
9
think many of us here today will never fully heal from that
10
pain and the heartache that we'll continue carrying with us.
11
So I just wanted to say that. It's something that
12
it's irreparable. I can't even really use a better word to
13
describe that. So thank you for hearing us today.
14
THE COURT: You're very welcome.
15
MR. EDWARDS: Your Honor, Jane Doe No. 5 would like to
16
speak.
17
JANE DOE NO. 5: This is a letter that I wrote; so
18
it's going to be: Dear Jeffrey, I think you are a mentally
19
disturbed human being. You used your power to make me believe
20
at a young age that I could have my dreams of being a model.
21
You paid for your freedom. You violated my rights. You should
22
have to pay for them, just as anyone else. You got a plea deal
23
that no one else would have been able to get. You used your
24
money to get out of paying the price for your actions.
25
Also, as a victim, I never got to see what the
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agreement was or why the special treatment got approved. I
2
think you should have been in jail for several years in
3
population and live like everyone else that is mentally
4
disturbed like you. You paid for yourself to get special
5
treatment while you were in jail. I don't even think you spent
6
a day in a jail as a normal human being.
7
You had investigators come to my house and also went
8
to my friend's house to question them. I will never be able to
9
over -- I will never be able to get over the overwhelming
10
emotions and embarrassment I experienced from that trauma. I
11
needed therapy several times a week and had high stress and
12
anxiety levels.
13
You paid your way to make the public think that the
14
girls had nothing in life going on for them. You wanted to try
15
and blame that we were lower class and that was the problem
16
with the girls. I was from a middle class family and did well
17
in school. I lived the American girl dream -- or the American
18
girl life. I went on family vacations around the world, grew
19
up in a good city, and my parents are still married to this
20
day. Basically, everything you said that we didn't have in our
21
life, I did.
22
It all came down to I was told I was making $200 in an
23
hour. Being young, that was a lot of money, and I didn't know
24
any better. Sadly, you were the one with an illness that you
25
should have to go and see a doctor and also have a mentor group
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for the sickness you have. I will continue with writing my
2
book about that secret life, with all the newspaper articles of
3
the case, my high school agenda book of official dates. I'm
4
basing that proof that I deposited cash after leaving
5
Jeffrey's. I still have all of the information, articles that
6
I collected over the years.
7
You mentally and physically traumatized me. I went to
8
therapy, and it was the best thing I did for myself. If anyone
9
only learns one thing from this case, I hope is that money
10
should not let you buy your way free. A crime is a crime and a
11
victim is a victim. Thank you.
12
THE COURT: Thank you. Thank you very much.
13
MR. EDWARDS: Your Honor, my next client is
14
15
I met Jeffrey Epstein through my first
16
massage teacher, a man who took me in as his apprentice to
17
teach me a practice I wanted to learn while in desperate search
18
to find a cure for a debilitating neurological disorder that I
19
have, which manifests into violent vomiting attacks, largely
20
triggered by stress. It's called Cyclic Vomiting Syndrome.
21
I was recruited by Ghislaine Maxwell. Upon my first
22
meeting of her, I wouldn't know I had been recruited until many
23
years later, when I would read it in a headline. Ghislaine and
24
Jeffrey took me in. They sent me to school. They gave me a
25
job. They flew me around the world, introduced me to a world I
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had only dreamt of and made me feel as though I had become a
2
part of their family, another thing I was desperately searching
3
for.
4
But on my third or fourth time meeting them, they
5
brought me to Jeffrey's island for the first time, and on the
6
first night there,
came tapping on my door late at
7
night to inform me Jeffrey was ready for another massage. My
8
instincts told me this didn't feel right, but I got up and
9
followed her to a villa I hadn't yet seen. Jeffrey and
10
Ghislaine's villa.
11
I began my massage, trying not to let him smell my
12
fear and obvious discomfort, but before I knew what was
13
happening, he grabbed onto my wrist and tugged me towards the
14
15
16
17
18
19
20
21
22
23
I spent two weeks vomiting, almost to death, in a
24
Los Angeles hospital after that first encounter. Jeffrey's
25
abuse would continue for the next three years, and I allowed it
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to continue because I had been taken advantage of my entire
2
life and had been conditioned to just accept it.
3
It took me a long time to come forward, too long
4
maybe, and all it took to bring -- and all that it took to
5
bring this man to justice has been robbed by his death. Every
6
day, every week I've spent in the hospital since, I've suffered
7
and he has won. Every job offer that's been offered to me and
8
then retracted because of my connection to this case, I have
9
suffered and he has won. Every public humiliation I have
10
endured, I have suffered and he has won. Every relationship
11
that I've had to end because of the abuse that I have endured
12
by the hands of this man, I have suffered and he has won.
13
Every woman sitting in this room today, and all of the
14
women who have yet come forward and who have not yet to come
15
forward and whose lives have been affected by Jeffrey Epstein's
16
sick abuse of young girls, we have all suffered, and he is
17
still winning in death.
18
I refuse to let this man win in death. I couldn't
19
fight back when Jeffrey Epstein sexually abused me because I
20
hadn't yet found my voice. Well, I have found my voice now,
21
and while Jeffrey may no longer be here to hear it, I will not
22
stop fighting, and I will not be silenced anymore. I needed
23
him to hear the pain he's caused, what I've gone through
24
because of him. I wrote a 350-page book of all the pain that I
25
have endured at the hands of this man that I really needed him
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to hear. His death has robbed me of that justice.
2
Please don't rob us of justice again. Thank you.
3
THE COURT: Thank you.
4
MR. EDWARDS: Your Honor, I think I have one more
5
client that is going to speak today,
6
THE COURT: Would you spell that?
7
M
Good morning, your Honor.
8
THE COURT: Good morning.
9
My name is spelled
10
11
Thank you, your Honor, for giving us the opportunity
12
to be heard this morning.
13
THE COURT: Sure.
14
When I was introduced to Jeffrey
15
Epstein, I was young and full of hope and the foolishness of a
16
teenager. I was idealistic, and I saw the good in people.
17
Jeffrey Epstein manipulated me, coerced me and sexually abused
18
me.
19
Something I think is very important to communicate is
20
that loss of innocence, trust and joy is not recoverable. The
21
abuse, spanning several years, was devaluing beyond measure and
22
affected my ability to form and maintain healthy relationships,
23
both in my work and my personal life. He could not begin to
24
fathom what he took from us, and I say "us" because I am every
25
girl he did this to, and they're all me. And today we stand
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together, those that are present and those that aren't.
2
I was a victim, and it has taken me many, many years
3
to stand here and say, yes, it was me. I was a victim, but I
4
will not remain a victim and be silent for one more day.
5
Although I think it's tragic when anybody dies before their
6
time, I'm extremely relieved that Jeffrey Epstein will not be
7
in a position to hurt anymore children or anymore women, and
8
I'm glad to be part of a group of women who are now bonded
9
forever in the trauma that we endured at the hands of this man.
10
Thank you.
11
THE COURT: Thank you.
12
MR. EDWARDS: Your Honor, we had one client who was
13
not able to be here but sent a message through a letter. Her
14
name is
last name,
15
And Brittany Henderson, of my office, is going to
16
read her letter as instructed.
17
THE COURT: Sure.
18
MS. HENDERSON: Thank you, your Honor.
19
THE COURT: Yup.
20
MS. HENDERSON: What happened to me occurred many
21
years ago when I was in high school, but it still effects my
22
life. I was told then that Jeffrey Epstein was going to be
23
held accountable, but he was not. In fact, the government
24
worked out a secret deal and didn't tell me about it. The case
25
ended without me knowing what was going on, without him being
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held responsible, without any explanation and without a chance
2
for my voice to be heard. I was treated like I did not matter.
3
Many years later, he was arrested again. These
4
investigators and attorneys representing the United States have
5
been completely different. I am still mad, concerned and
6
confused about how he committed suicide and escaped
7
responsibility again, but I know it is not the fault of the
8
judge or the government attorneys.
9
I was allowed to be a part of the process this time.
10
My attorney was able to tell me what was going on at every
11
stage because they kept him informed. Thank you for inviting
12
me. It means more to me than you can ever know. I was not
13
able to be here this time, but I know that I was allowed to be
14
and I had the chance to attend this hearing, which is helping
15
me in my healing process. The fact that I mattered this time
16
and the other victims mattered is what counts. For that, I am
17
grateful.
18
THE COURT: Thank you.
19
MR. EDWARDS: Your Honor, finally, in 2008 when I
20
filed the case under the Crime Victims Rights Act, it wasn't me
21
alone. I did it with Paul Cassell and Jay Howell.
22
Paul Cassell is here today, and I think your Honor
23
even cited to a piece of -- an opinion of his from when he was
24
on the bench, and he has some remarks to make.
25
Once again, your Honor, I really do believe that this
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is a model for how victims should be treated in a criminal
2
process, and we really do appreciate it. Thank you.
3
THE COURT: Thank you.
4
MR. CASSELL: I'll be very brief because I know there
5
are others that want to speak here. I'm Paul Cassell,
6
C-a-s-s-e-1-1, previously served as a federal judge at the
7
District of Utah, currently a law professor, where I teach
8
crime victims rights at the University of Utah, College of Law.
9
I just wanted to take one minute to address some
10
suggestion that there would be no need for a hearing this
11
morning. I think, having heard already from these powerful
12
victims and recognizing how important giving those statements
13
will be in the trajectory of their lives, makes clear that your
14
Honor has followed exactly the right path. Legally, there is
15
one precedent, which is U.S. V. Heaton, a case that you cited
16
that I wrote about a decade ago, and as explained in that
17
opinion, victims have important interests in the criminal
18
justice system that can only be recognized if they're given
19
their day in court.
20
With all due respect to other law professors that have
21
recently written an article, I think transparency is one of the
22
overriding objectives in our criminal justice system, and the
23
one substantive action that I would urge your Honor to take
24
today is to publish your remarks as a published opinion. The
25
Heaton case is, to my knowledge, the only reported decision on
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this particular issue, even though it's more than a decade old
2
and, yet, we can see today that these problems recur in many
3
other cases. Your remarks today, I think, should be published
4
so that they can serve as a guide for other judges around the
5
country.
6
I would encourage you to add into your remarks a
7
reference to the Crime Victims Rights Act. The Crime Victims
8
Right Act promises victims the right to be treated with
9
fairness, dignity and respect, and the process that we see
10
unfolding this morning is a clear example of how victims can be
11
treated with fairness, dignity and respect.
12
So I know that your Honor is wondering what is the
13
appropriate action here. Unfortunately, it seems like there
14
are no other legal options, but there was a legal option for
15
you to decide to exercise, which was to allow these victims to
16
come forward. And if there's been one positive thing that has
17
come out of the tragedies, the abuse, the other events of this
18
case, it's been your decision to allow these victims to be
19
heard this morning, and I encourage you to publish your
20
decision and to encourage other judges to follow what is
21
clearly a model for crime victims rights and is clearly an
22
example that should be followed in other cases down the road.
23
THE COURT: Thank you very much. I appreciate your
24
being here. I had no idea that you would be here when I wrote
25
the remarks, but it was clear from the literature that you are
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the leading expert formerly of the District Court of Utah, I
2
believe, and it's a pleasure to have you here today.
3
MR. CASSELL: Thank you, your Honor.
4
THE COURT: Thanks.
5
Mr. Boies?
6
MR. BOIES: Thank you, your Honor. David Boies of
7
Boies Schiller Flexner. We have with us today five of the
8
victims that we represent. There are a number of additional
9
victims who either were unable to attend or are still unwilling
10
to come forward publicly. This has been an enormously
11
traumatic aspect of their lives, something that, as you've
12
already heard and will hear more today, is something that they
13
can never entirely escape from.
14
I want to, as prior counsel have, commend both the
15
Court and counsel for the Department of Justice for the
16
consideration and respect and attention that they have paid to
17
the victims. We believe that that is not only right, as a
18
matter of human dignity, but we think that is exactly what the
19
law requires and intends.
20
I will be more blunt than the Court has been, or
21
Professor Cassell has been about Professor Green's article.
22
That is an article that cites no authority, and I believe there
23
is no authority for his proposition. I entirely respect his
24
right to advocate on behalf of his client Alan Dershowitz, who
25
has retained him in connection with litigation that we've
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brought against Mr. Dershowitz, but I would have expected that
2
the Law Journal or Professor Green himself would have disclosed
3
that connection, which I think is a conflict.
4
But regardless of the appropriateness of his
5
disclosure, or lack of disclosure, I think that his article
6
opposing allowing the victims to have a voice in this
7
proceeding is inconsistent not only with the policy that
8
underlies the Crime Victim Rights Act and the very statute that
9
Mr. Epstein is being prosecuted under, but it ignores the
10
actual language of those statutes, and many other statutes, in
11
which Congress has made clear that the purpose of the criminal
12
law is no longer simply to punish the individual defendant, but
13
it is to find some way of trying to mitigate the damage that
14
has been done to the victims through restitution and economic
15
mitigation, but also through the ability to confront and to
16
have the court system and the justice system and the
17
prosecutors treat these victims as they are victims, as they
18
are human beings, and they are entitled to the respect that our
19
society needs to give every human being. So I think that this
20
is not only commendable, but I think it is what the law
21
requires.
22
In response to the question the Court asked, I have
23
discussed this hearing with my clients. I have told them that,
24
under the applicable law, the government has no alternative but
25
to move to dismiss this case, and I believe under the
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applicable law in this circuit, the Court has no alternative
2
but to grant that motion.
3
I think the current law is outdated, as the Court
4
suggested in some of its remarks. I think there will come a
5
time when either an Appellate court or the Congress will make
6
clear that, just as it's possible to continue civil cases
7
against someone after they have deceased, it is possible, at
8
least for purposes of things like restitution, to continue
9
criminal cases, but we are not there now. And, fortunately, in
10
this case, there are other ways and perhaps even more efficient
11
ways to vindicate the interests of the victims here.
12
We greatly appreciate the remarks of the
13
representative of the Department of Justice today, and we, too,
14
on behalf of the victims, are not going to stop when we walk
15
out of this courtroom. We are going to continue to seek
16
vindication against Mr. Epstein's estate and, in some senses,
17
perhaps even more important, against the people who worked with
18
him and enabled him.
19
As you have already heard, and will hear more,
20
Mr. Epstein did not act alone. He could not have done what he
21
did, on the scope and the scale of what he did, for as many
22
years as he did it without the activities and support and the
23
co-conspirator activity of a number of other key individuals,
24
and those individuals also need to bear their share of
25
responsibility, and those people need to have a reckoning as
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well.
2
My partner Sig McCawley, who's been working with me
3
for more than five years on this case, is going to, with the
4
Court's permission, introduce five of our clients who will
5
speak briefly to your Court. Thank you very much.
6
THE COURT: Thank you very much, Mr. Boies. Pleasure
7
to have you here.
8
9
MS. McCAWLEY: Thank you, your Honor, the first victim
10
that would like to speak today is
11
THE COURT: Can we have the spelling of your name?
12
MS. McCAWLEY: Sure. Sigrid, S-i-g-r-i-d, and the
13
last name is M-c-C-a-w-1-e-y, and I'm a partner at Boies
14
Schiller Flexner.
15
THE COURT: Thank you.
16
Good morning.
17
THE COURT: Good morning.
18
Thank you, prosecutors and Judge, and the
19
Court. My name is
I note today I do feel
20
respected and listened to; so I appreciate that, and I have to
21
say that I commend the boldness of the New York prosecutors for
22
pursuing a man that has, you know -- and others, that have
23
clearly taken a lot from a lot of people.
24
17 years ago I knew him only as "Jeffrey." I was
25
recruited and brought from California to New York, and that
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experience for the last 17 years has been a dark corner in my
2
story, in my life, in my life story and that has been
3
definitely made worse by my own self-shame and that -- and
4
anger for normalizing all of the red flags. I feel like we are
5
conditioned to do that, and that's something that needs to
6
change.
7
So I'm here today, you know, I'm coming forward
8
because it is time to bring light to that darkness, and it's
9
time to replace that darkness with light. And I am a survivor
10
of this, and I do aim to progress further from being a
11
survivor, you know. I feel I've worked hard, quite hard, to
12
get to where I'm at now, and I'm definitely at a place in my
13
life where I will no longer cover up. I'll no longer cover up
14
what needs to be brought to light.
15
Jeffrey is no longer here, and the women that helped
16
him are, Ghislaine Maxwell. My experience is with Ghislaine
17
Maxwell and
and they definitely need to be held
18
accountable for helping him, helping themselves, helping one
19
another carry on this huge, almost like a system. So they need
20
to be held accountable, all of them, and I would like to see
21
that, certainly on behalf of myself and for everyone here.
22
Thank you.
23
THE COURT: Thanks so much.
24
MS. McCAWLEY: Our next client, who is going to speak
25
this morning, is
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Good morning, your Honor.
2
THE COURT: Good morning. How are you?
3
Okay. Thank you. My name is
4
5
6
I am a victim of Jeffrey Epstein and Ghislaine Maxwell
7
in the dark and cruel and criminal acts they committed against
8
me and hundreds of other girls and young women for years and
9
years and years, unstopped.
10
Thank you for allowing me to address the Court and
11
speak the truth. I commend the prosecutors from the Southern
12
District of New York for the ongoing investigation and its
13
pursuit of justice for us victims. It has given me hope, and I
14
will not let go of that hope.
15
When I was recruited by Ghislaine Maxwell at
16
Mar-a-Lago, just before I was 17, I thought I was given a big
17
break, and I'd be able to reset my life and become an actual
18
real massage therapist. My hopes were quickly dashed, and my
19
dreams were stolen. Jeffrey Epstein is no longer alive, but
20
this is not about how he died. This is about how he lived.
21
He will not have his day in court, but the reckoning
22
of accountability has begun, supported by the voices of these
23
brave and beautiful women in this courtroom today. The
24
reckoning must not end. It must continue. He did not act
25
alone and we, the victims, know that. We trust the government
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is listening and that the others will be brought to justice.
2
Thank you, your Honor.
3
THE COURT: Thank you very much.
4
MS. McCAWLEY: The next client of ours that will be
5
speaking this morning is
6
Thank you, your Honor. My name is
7
I'm a victim of Jeffrey Epstein and
8
Ghislaine Maxwell's international sex trafficking ring.
9
I would like to thank the Court for the dignity and
10
the respect you are showing me here today, as well as the other
11
victims. I would also like to acknowledge and extend my
12
gratitude to the prosecutors from the Southern District of
13
New York for pursuing justice on behalf of the victims.
14
Please, please finish what you have started. I struggled to
15
find the words to adequately say how important your work is to
16
us.
17
For a very long time Jeffrey Epstein gamed the system
18
at every level, and when he realized he couldn't do that any
19
longer, he showed the world what a depraved and cowardly human
20
being he is by taking his own life. But we, the victims, are
21
still here, prepared to tell the truth, and we all know he did
22
not act alone. We are survivors, and the pursuit of justice
23
should not abate. Thank you, your Honor.
24
THE COURT: You're very welcome.
25
MS. McCAWLEY: Our next client who is going to be
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speaking this morning is
2
Good morning, your Honor.
3
THE COURT: Good morning.
4
5
I had the opportunity to speak at Jeffrey Epstein's
6
bail hearing, and I really appreciate that you heard me and
7
listened to me that day. I am so sorry that others will not
8
have the opportunity to stand before him the way that I did.
9
But I'm here today to speak on behalf of my sister,
10
who could not be here.
11
Jeffrey Epstein, Ghislaine Maxwell not only assaulted
12
her, but as we're hearing from so many of these brave women
13
here today, they stole her dreams and her livelihood. She
14
risked her safety in 1996, so many years ago, to report them,
15
to no avail, and it is heartbreaking to her and to me that all
16
this destruction has been wrought since that time.
17
We were deeply disappointed and disturbed by Epstein's
18
death and the fact that that was allowed to happen while he was
19
in the government's custody, and I'm encouraged to hear that
20
there will be a full investigation as to how that was allowed
21
to happen.
22
But it is extremely important, as others are saying,
23
that he did not act alone and that the other people that were a
24
part of what he did are held accountable and that that
25
investigation continues.
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I believe that we have a real problem in this country
2
with perpetrators of sexual abuse and sexual assault being held
3
accountable. There are so many roadblocks to victims being
4
heard, to cases being investigated thoroughly, and then to
5
those cases being prosecuted. And so I think this is a really
6
important signal to send a message to victims out there that
7
people will take you seriously, people will follow through, and
8
that even those in power, as we have unfortunately seen, that
9
has not been often are able to escape that, that even those in
10
power will be held accountable. Thank you.
11
THE COURT: Thanks so much.
12
MS. McCAWLEY: Our next client, who's going to address
13
the Court is
She says it much more
14
beautifully than I do; so I'll let her say it.
15
:
My first name is spelled,
16
; last name is
17
My name is
and I am a victim of
18
Jeffrey Epstein and the sophisticated sex trafficking operation
19
he ran, where he allegedly was to be a financier.
20
I was 20 and previously modeled and was living in the
21
West Village. I met a young woman named
through a mutual
22
friend. We were friends for a few months. She was an amazing
23
artist and liked to party. One day she called me and asked if
24
I was interested in meeting a friend of hers. She told me he
25
wanted to meet me and really liked blonds, and I thought he was
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our age and liked to do the same things we did at that age; so
2
I agreed.
3
On a sunny, crisp day, we took the train together to
4
the Upper East Side. She then began to talk a little bit about
5
him on our way to his house. I was at his house. I was
6
sexually assaulted by both
and Jeffrey Epstein in his
7
mansion. It left me feeling both disgusted and betrayed.
8
As we walked home to the subway afterwards, she
9
continued to tell me about the man who had just abused me with
10
her participation. She seemed exhilarated from the horrific
11
experience. I was shocked and in a daze. This is a few things
12
that she had told me. She told me he went to Cooper Union. He
13
was a mathematical genius. That he had favorite girls that he
14
would take to Chanel for 15-minute, all-you-can-buy shopping
15
trips. She told me his right-hand person had connection to the
16
arts and the fashion world, and she could help me.
17
This is not my complete story. I'll stop here. I'm
18
in a good, stable place in my life, and I had decided to come
19
forward to be a voice to the victims who may not be able to
20
tell their story, or at least not yet. I feel like I am a
21
survivor.
22
Thank you, Judge Berman, for inviting victims to speak
23
today before you. We hope the government is listening very
24
closely to the words we are saying.
25
THE COURT: Thank you very much.
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MR. BOIES: Your Honor, just very briefly.
2
THE COURT: Sure.
3
MR. BOIES: I would like to express to the Court how
4
proud I am of all of these women who have come forward. It's
5
taken an enormous amount of strength and courage for them to do
6
SO. Thank you.
7
THE COURT: Thanks, Mr. Boies. Hold on one second.
8
(Pause)
9
MS. LERNER: Thank you, your Honor. My name is
10
Kimberly Lerner, of Lerner and Lerner, and your Honor, with
11
your permission, I would like my client,
, to
12
stand next to me.
13
THE COURT: Sure.
14
MS. LERNER: Would that be okay?
15
THE COURT: Absolutely.
16
MS. LERNER: Your Honor, I would like to begin by
17
saying that I am in awe of all of these beautiful women. I
18
just want to let you know, on behalf of
and myself, we
19
admire you, we respect you, and we applaud you, and you are
20
brave survivors. And
S heart is with all of you, and
21
we thank you so much for coming forward.
22
when she went public, she thought she was
23
one of the only ones, and to see all of these faces is, I know,
24
amazing for her.
25
Jeffrey Epstein was a predator, a pedophile and a sick
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individual. However, he was also a thief. He stole
S
2
childhood dreams, her innocence and her self-confidence. She
3
was 14 years old. What he could not buy, he forcibly took.
4
Why? Because he surrounded himself with a network of powerful
5
people who not only looked the other way, but also actively
6
facilitated and participated in his sexual abuse of children.
7
Jeffrey Epstein thought he was above the law, and
8
essentially he was until now. The system let
and the
9
other victims down, but it does not have to end here. We ask
10
the U.S. Attorney's Office and the FBI to bring all of
11
Epstein's enablers and co-conspirators to justice.
12
It has taken
18 years to find her voice, and
13
again, Jeffrey Epstein has tried to silence her. While she
14
will never have her chance to face him in court, he no longer
15
has any power over her. Today, this brave survivor will be
16
heard.
17
: Thank you for allowing me to be able to
18
have my chance in court today, to be able to tell you what this
19
horrific man did to my life. You can't even imagine how much
20
it affected my childhood, all the way through my adult life.
21
He robbed me of my dreams. He robbed me of my chance to pursue
22
a career I always adored. He stole my chance at really feeling
23
love because I was so scared to trust anyone for so many years
24
that I had such severe anxiety. I didn't want to leave my
25
house let alone my bed.
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The fact that he felt entitled to take away my
2
innocence, the fact that he felt that he could do whatever he
3
wanted, regardless of the laws, hurts me so very much. It took
4
me years to tell anyone what Epstein did to me because I was so
5
ashamed and embarrassed at what people would say or think of me
6
until I found out there were other victims, girls just like me.
7
I knew I could no longer keep my silence no matter how ruthless
8
and powerful Epstein was, and still is even after his death.
9
The fact I will never have a chance to face my
10
predator in court eats away at my soul. Even in death, Epstein
11
is trying to hurt me. I had hoped to at last get an apology,
12
but this evil man had no remorse or caring for what he did to
13
anyone. I felt let down by the people who were supposed to
14
watch him in prison. They let this man kill himself and kill
15
the chance of justice for so many others in the process, taking
16
away our ability to speak.
17
Out of all the damages and side effects that Epstein
18
caused by his heartless and selfish acts, it's very hard to put
19
my feelings and emotions into words, trying to let his
20
horrendous actions go and attempting to forgive him, has been
21
so difficult for me. Yet, as hard as it's been to come so
22
publicly forward, I refuse to let Epstein take me as a victim
23
anymore.
24
I am a survivor. The many that stand before me here
25
today that have shared the horrific experiences with this
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deplorable human being, because even though this weak, evil
2
coward tried to steal all of our childhoods, tried to steal all
3
of our innocence and tried to steal all of our means of
4
justice, he will never steal our inner strength, and he will
5
never, ever, ever steal our voice. Thank you so much.
6
THE COURT: You're welcome.
7
MS. GIBBS: Good morning, your Honor. Teri Gibbs,
8
T-e-r-i, G-i-b-b-s. For the record, I am a California
9
attorney. I'm not admitted to the New York State bar. I am
10
here to make a statement on behalf of New York attorney, Lisa
11
Bloom. I work for her firm, The Bloom Firm.
12
Lisa Bloom represents four of Jeffrey Epstein's
13
victims, Jane Doe 6, for the record, Jane Doe 7 and Jane Doe 8.
14
I am so proud of all of you victims who are here today and are
15
able to voice yourselves today. I will not and cannot comment
16
on the criminal case, or Ms. Bloom's communications with her
17
clients.
18
Ms. Bloom would like to share three of her client's
19
statements for the record. Here are the statements. Statement
20
of Jane Doe 6.
21
To the Honorable Richard M. Berman. Jeffrey Epstein
22
stole my innocence. He gave me a life sentence of guilt and
23
shame. I do not consider myself a victim. I see myself a
24
survivor. The abuse that I endured cannot continue. Let's
25
stop this before it happens to other young women. Jane Doe.
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Statement of Jane Doe 7. To the Honorable Richard M.
2
Berman. I used to be relatively carefree, inquisitive, hopeful
3
and excited about life, but my life changed because of Jeffrey
4
Epstein. My perspective on life became very dark when I was
5
unknowingly recruited by one of his agents. Jeffrey Epstein
6
ruined me. His recruiter ruined me. The far-reaching
7
consequences of that day ruined my family's lives.
8
I've chosen to remain anonymous in order to protect my
9
family from unwanted media attention.
10
I was just trying to figure out my path in life when I
11
encountered Jeffrey Epstein in his New York City mansion. I
12
cannot even begin to summarize the many detriments this
13
experience of sexual assault has had on my life. Immediately
14
following the incident, I was unable to function and be around
15
other people. My parents had to rescue me and bring me home,
16
where I became a recluse for years.
17
I was changed forever and buried my assault deep down,
18
where the darkness couldn't hurt me anymore, but of course, it
19
has always been here, lingering and affecting me unconsciously.
20
At the time, I was mired in shame, guilt and humiliation. I
21
had somehow tricked myself into thinking that I had allowed the
22
assault to happen, that I did it to myself, that I don't
23
deserve to be alive or to be loved. I believed that I was a
24
disgusting, shameful person who does not deserve to ever be
25
happy. These are the thoughts I've lived with on a daily
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basis.
2
Furthermore, because I couldn't tell anyone, out of
3
fear of judgment, blame or retaliation, keeping this secret
4
completely hindered my ability to uncover why these issues
5
existed for me, which could have led to a path of healing over
6
the years.
7
It is time for those of power to do the right thing.
8
It is time for compassion toward our fellow human beings to
9
reign over money, power and greed. We need to protect our most
10
vulnerable to allow them a chance at a normal life, and nothing
11
should come in the way of that. I believe that for future
12
generations, including my own children, this case will set a
13
precedent that victims must no longer suffer in silence on our
14
own or be shamed for coming forward to seek protection.
15
This case should demonstrate to those who want to harm
16
others that there will be a reckoning, and they will pay dearly
17
for the harm they inflict on innocent people. Judge Berman, I
18
thank you for from the bottom of my heart for this forum and
19
opportunity.
20
To all of those survivors who came before me, I
21
commend your bravery. There is no way I could have done this
22
without you.
23
Thank you to the public following this story, for your
24
outrage and desire for answers, which will hopefully move this
25
case forward so that victims can stop having to relive their
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1
experiences every day and move on to begin to heal.
2
God bless the victims, their families, the
3
investigators and public servants working so diligently to find
4
those answers and to right all these wrongs. Jane Doe 7.
5
(Continued on next page)
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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THE COURT: Thanks very much.
2
MS. GIBBS: One more. Statement of Jane Doe 8.
3
In the past few weeks, I have had to reflect on my
4
interaction with Jeffrey Epstein and realized that, though I
5
have yet to put it all behind me, I am still a victim. I say
6
this because I have to come to terms with it in an effort to
7
truly get past the abuse I suffered at the hands of Epstein.
8
Pursuing criminal penalties against him and having an
9
opportunity to address the egregious crimes he committed
10
against me and other young woman would have helped my recovery
11
process. This all came to an abrupt halt when he took his own
12
life. This point of disclosure is lost.
13
I cannot say that I am pleased he committed suicide,
14
but I am at peace knowing he will not be able to hurt anyone
15
else. However, a sad truth remains. I, along with other
16
people, will never have an answer as to why. I will never have
17
an apology for the wrongdoing. And most importantly, Epstein
18
will not be justly sentenced for his crimes. Now I sit in my
19
home questioning the well-being of those girls like myself. In
20
choosing death, Epstein denied everyone justice.
21
Any efforts made to protect Epstein's name and legacy
22
send a message to the victims that he wins and that he is
23
untouchable. I understand his case may be dismissed or closed,
24
but this makes me feel as though I, and anyone else who fell
25
pry to his hands, simply do not matter.
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I ask that you very seriously consider the final
2
decision, because it will undoubtedly affect all other facets
3
of this case, including any future charges brought against the
4
recruiters or third parties to his crimes. I do not want the
5
narrative to be, Those poor girls. I want to send a message to
6
anyone who would consider engaging in similar acts to think
7
twice beforehand. I want some sort of closure for those of us
8
who relive those horrible moments where we were assaulted,
9
abused, and taken advantage of by Epstein.
10
You have the opportunity to help us seek that closure.
11
I appreciate your time and consideration and ask for your
12
continued support in dealing with this case to illustrate that
13
we, Epstein's victims, do matter.
14
Sincerely, Jane Doe 8.
15
On behalf of Lisa Bloom and The Bloom Firm, thank you,
16
your Honor.
17
THE COURT: Thank you, Ms. Gibbs.
18
Did we have any other victim's counsel or victims?
19
Ms. Allred.
20
MS. ALLRED: Good morning, your Honor.
21
THE COURT: Good morning. How are you?
22
MS. ALLRED: Fine. Thank you.
23
Allred, Maroko & Goldberg by Gloria Allred,
24
G-l-o-r-i-a A-1-1-r-e-d.
25
Your Honor, thank you so much for this opportunity to
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afford the victims their voice, because many of them have never
2
spoken before. They never spoke in Florida. They never spoke
3
anywhere. They never told their mother. They never told their
4
father. They never told their family members. This is an
5
opportunity for them to be heard. We thank you for that.
6
Your Honor, for 43 years my firm has been the leading
7
women's rights private law firm in the United States. We have
8
helped thousands of victims. And I, as an officer of the
9
court, and as a believer in the system, have tried to encourage
10
the victims to have confidence in the system that should
11
provide them access to justice that should help them to assert
12
and vindicate their rights in a court of law. It has been
13
increasingly difficult in this case for me to say to my clients
14
that they should have confidence in the system of justice given
15
what has occurred in this case, People V. Jeffrey Epstein.
16
Having said that, I am encouraged by the fact that
17
this court, essentially, in an unprecedented situation where
18
the defendant is deceased, is still affording these victims an
19
opportunity to be heard. So we thank you for that. It is some
20
encouragement.
21
Your Honor, you also asked do our clients wish to be
22
heard in reference to some of the issues that have been raised
23
this morning, including what should happen into this case.
24
Your Honor, there has been a suggestion that the court should
25
investigate the circumstances of the death of Mr. Epstein. I'm
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not going to repeat the arguments made by counsel, but I would
2
say that if there is jurisdiction, and I know that is a legal
3
issue which has been previously argued, that certainly it would
4
increase the confidence of my clients. Not just my clients,
5
but victims all over, and some are, by the way, located in
6
other parts of the world, to have the court oversee the
7
investigation.
8
We are encouraged by the sensitivity of the attorneys
9
for the United States Attorney's office for the Southern
10
District of New York and the investigation that is going on
11
with the separate team. However, and, of course, the defense
12
is also conducting its own investigation. But I do think the
13
greatest confidence would be if the court in some way would be
14
able to oversee an investigation because the court is a neutral
15
party. And although the court certainly has a stake in finding
16
out what happened to defendants who are in the custody of the
17
federal system and who should be there to face the prosecutors
18
and the charges against them, but now are not because clearly
19
the system has failed.
20
And the United States Attorney has admitted that, and
21
even before he admitted that, everybody knows the system
22
failed. Failed the victims, failed the court, failed everyone.
23
In any event, your Honor, having seen so many
24
thousands of victims of gender violence, sex harassment, sexual
25
assault, I've dealt with child sex trafficking, child
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molesters, I mean, this is a unique case because there are so
2
many victims and so many failures of the system. At this
3
point, what we would really ask for is not just words, but
4
words have been helpful, but deeds, and that is very important.
5
In addition, I would like to say, throughout this case
6
is the running theme of the betrayal of trust. Betrayal of
7
trust by Jeffrey Epstein. Betrayal of trust by the system.
8
And betrayal of trust to the victims who had a right to
9
justice. And the Crime Victims' Act should not just be words,
10
it should have meaning and it should be enforced.
11
In essence, we are asking, although you may need to,
12
of course, grant this motion to dismiss, I think because the
13
court has shown sensitivity to victims and victims' needs, if
14
there is a way to at least keep the record open so that victims
15
who have not been able to be physically present in the
16
courtroom today and who have not been able to submit to the
17
court any letters, victim impact, and who have not been able to
18
secure attorneys or speak to attorneys yet -- so, for example,
19
I'll still hearing from victims who I have not been able to
20
meet with yet because they just recently are now contacting
21
me -- so if they could submit, at least for the record, their
22
victim impact statements, that, I think, would be a very
23
important assistance to them. So that would be, at least they
24
would know that what they are sharing is on the record.
25
So, in summary, I would say that they are looking
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forward to the very serious investigation by the United States
2
Attorney of who may have conspired in this case, and that is
3
very hopeful, and we're hoping that everyone who may have a
4
role to this criminal prosecution will submit that evidence.
5
This is about power. This is about many victims
6
having lived in fear -- fear of the rich, the powerful, the
7
famous, fear that the system will not afford them justice. So
8
fear of not coming forward. And fear, of course, is a weapon
9
that the rich, powerful, famous, and sexual predators used to
10
silence the victims. But that is gone for a lot of victims
11
because they refuse to suffer in silence.
12
Finally, it does take courage to speak truth to power.
13
We thank this honorable court for giving these victims a voice.
14
We thank them, even after the death of the defendant, for
15
showing respect for the victims, allowing them dignity,
16
allowing them a voice. We do want truth, we do want justice,
17
we do want accountability, and we do want those conspirators to
18
face the justice system.
19
Your Honor, right now we have two of our clients who
20
would like to address the court.
21
THE COURT: Sure.
22
MS. ALLRED: Then I have a couple of statements on
23
victims who do not wish to address the court.
24
As they come up, we'll give them the opportunity to
25
say either their name or Jane Doe.
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By the way, thank you, your Honor, for allowing some
2
of these victims to be called Jane Doe. What number the court
3
affords to them, we'll accept whatever that is.
4
Thank you.
5
THE COURT: We're up to nine.
6
MS. ALLRED: Thank you.
7
Hello. My name is
That is
8
9
I was going to start this statement by saying that I
10
was a victim of Jeffrey Epstein. But that's not the case. I'm
11
still a victim of Jeffrey Epstein. I'm still a victim because
12
the fear of not being heard stopped me from telling my story
13
for so many years. This lingering fear almost stopped me from
14
attending this monumental movement of strength and power.
15
I'm still a victim because I am fearful for my
16
daughters and everyone's daughters. I'm fearful for their
17
future in this world, where there are predators in power, a
18
world where people can avoid justice if their pockets run deep
19
enough.
20
I'm still a victim because the 17-year-old
was
21
manipulated into thinking she had found someone who cared,
22
someone who wanted to help. Jeffrey knew I had nowhere to go.
23
He knew I was vulnerable, and he took advantage of that poor
24
girl, who will never be the same.
25
I cannot eat at the thought that Jeffrey Epstein -- I
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cannot eat at the thought of Jeffrey Epstein not serving the
2
time he needed to realize the pain and suffering he caused so
3
many vulnerable young girls. He thought he was untouchable,
4
and honestly, so did I. I thought he was the most powerful
5
person I would ever meet.
6
But the end is here and here I stand becoming more
7
powerful than he will ever be. Thank you.
8
THE COURT: Thank you.
9
JANE DOE: Jane Doe.
10
Um, in 2004, when I was 15 years old, I flew on
11
Jeffrey Epstein's plane to Zorro Ranch, where I was sexual
12
molested by him for many hours. What I remember most vividly
13
was him explaining to me how beneficial the experience was for
14
me and how much he was helping me to grow. Yikes.
15
I remember feeling so small and powerless, especially
16
after he positioned me by laying me on his floor so that I was
17
confronted by all the framed photographs on his dresser of him
18
smiling with wealthy celebrities and politicians.
19
After he finished with me, he told me to describe in
20
detail how good my first sexual experience felt. That was the
21
first of many lies I was forced to carry for him, the weight of
22
which proliferated my trauma. I felt powerless not merely
23
because one man wanted to strip me of my innocence, but because
24
I was the victim of a system that just enfranchises human
25
beings, making them vulnerable to pedophilic exploitation.
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As unjust as what happened to me was, I believe that
2
experience to be a symptom of insidious and pathological
3
violence that extreme wealth yields, a violence which
4
ultimately stays hidden through channels of extreme power that
5
serve it.
6
I first identified with this feeling the night after I
7
was molested by Epstein, when another girl and I took out two
8
of his ATVs and raised them across the mesa. I crashed mine
9
and expressed my concern to the other girl of getting in
10
trouble, which she replied to me, Don't worry, no one gets in
11
trouble for anything here.
12
Even as a child, I understood, in a sad and precocious
13
way, what I hoped we have the ability of changing now. Even
14
though Epstein is dead, there is still justice to be brought
15
for the crimes we felt powerless against concealing for him and
16
the system that supported him for all these years.
17
Thank you.
18
THE COURT: You're very welcome.
19
MS. ALLRED: Thank you.
20
Your Honor, may it please the court. I would like to
21
read a statement for Jane Doe, my client, who is present in
22
court, but requested that I read it.
23
We only have one opportunity at childhood. One
24
opportunity to develop. One opportunity to find direction for
25
our lives. Jeffrey Epstein robbed and denied me at each
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opportunity he had.
2
I came from a small Texas town, not far from the New
3
Mexico border. My mother died when I was 11, after suffering
4
from cancer for many years. My father was devastated, as were
5
my siblings and I. My father was saddled with debt. My only
6
hope for college was to get a scholarship.
7
When I was 15, I was a blossoming freshman in high
8
school and was trying to carry on my mother's dream. She
9
wanted me to master the violin. After school, I would often go
10
to a mall in a nearby city. A lady approached me and saw I had
11
a violin case with me and asked if I was any good. We talked
12
about the violin, my family, and why I had clothes that looked
13
like hand-me-downs.
14
The lady told me she works for a very rich man who had
15
a home close by and that he would pay to hear me play. I was
16
told that if I could get away, she could arrange for
17
transportation to and from his place and have me back before
18
anyone knew I was gone. After some hesitation, I agreed. This
19
decision was the beginning of the end of my childhood.
20
The man who only identified himself as J or Jeff had
21
asked if I would give him a massage, and over four visits,
22
eventually progressed
The money he
23
gave me further placed my young soul into a perverse sense of
24
hell.
25
I was so utterly disgusted with myself and what he did
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to me that I stopped going to see him. I had documented the
2
events with a Texas rape crisis center about the man I know now
3
as Jeffrey Epstein.
4
Epstein targeted and took advantage of me, a young
5
girl, whose mother had recently died a horrific death and whose
6
family structure had deteriorated. His actions placed me, a
7
young girl, into a downward spiral to the point where I
8
purchased a gun and drove myself to an isolated place to end my
9
suffering.
10
A voice that could only have been from my mother told
11
me, quote, I am not the victim, I am the victor, and I dare not
12
pull the trigger. " I returned the gun days later.
13
Epstein is a coward. He lived his life leaching off
14
the souls of inspiring, young girls due to the fact that he
15
could never know how it feels inspired to live. Like a leach,
16
once Epstein had his fill, he would unlatch and seek out
17
another victim.
18
The only sense of justice I had hoped to see was
19
Epstein being sentenced. However, Epstein died as he lived,
20
taking the easy way out without any responsibility.
21
Your Honor, the next statement is also a statement of
22
a Jane Doe. May it please the court.
23
I was a 16-year-old virgin when Jeffrey Epstein first
24
raped me. I was naive and gullable. He was a pillar of
25
finance and a giant in the world that I was an insignificant
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part of. I was so impressed that this great man would even
2
talk to me and impart any of his wisdom on me. I gladly jumped
3
at the chance to meet him again, when he told me how impressed
4
he was with my personal story and maturity for my age.
5
When I was in his presence, he made an effort to call
6
celebrities and influential people on speakerphone, like
7
Academy Award-winning actresses and super models, who always
8
answered his calls. Sadly, I was impressed.
9
He was friends with former and future heads of states
10
and every other fixture in the New York social scene and
11
beyond. He knew important people in my own world that I looked
12
up to and revered, but he spoke about them like they were sweet
13
distractions far beneath his stature. He could easily reach
14
down from his position and influence the people directly
15
involved with my daily life and future prosperity. I was the
16
perfect victim.
17
My whole life was extremely turbulent. But one of my
18
mother's greatest wishes was that all her children would
19
graduate from respectable universities. He promised me that he
20
would write me a letter of recommendation for Harvard if I got
21
the grades and scores needed for admission. His word was worth
22
a lot, he assured me, as he was in the midst of funding and
23
leading Harvard's studies on the human brain, and the president
24
was his friend.
25
The fact that all of you already know these next
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details, which I'll share, should ignite fire instead of induce
2
the complacency they did in the past, when heard repeatedly
3
over the years, but yes, an innocent massage turned sexual
4
almost immediately.
5
"Here, come. Come help me with a kink in my shoulder
6
while we finish our discussion. "
and a couple
7
of hundred dollars, disgust and dirty secret, more praise and
8
imparted wisdom from a godlike figure, a deliberate diabolical
9
depression of grooming and submission for his pleasure and
10
release. Even if I resisted, I was no match for him. I felt
11
powerless, ashamed, and embarrassed. I wanted to vomit
12
remembering these moments.
13
What I learned in those depraved sessions, staring up
14
at the dome ceiling in his private massage room, tore a violent
15
hole through any normal sexual awakening. I'm haunted forever,
16
having learned everything there is to know about sex through a
17
vile criminal. Every time a new molestation would bring a new
18
lesson, the progressive and constant unwinding. I was nothing
19
more than a teenage prostitute. I was his slave.
20
I had never even kissed a boy before I met him, and
21
never throughout the horrific abuse did Jeffrey Epstein kiss me
22
even once.
23
24
25
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2
3
4
5
6
I got a few hundred dollars, as usual, as he led me
7
out of his mansion with assurances that I was on the right path
8
guided by him. I lied to myself and tried to believe him. I
9
became a hollow shell. If I missed an appointment, he
10
threatened me and let me know who was in charge. "Do you know
11
how important my time is? I'll bury you. I owe this -- I
12
won't say the word -- F'ing town. " He would hang up.
13
I would stand there frozen in the street, terrified
14
that his assistant would call to reschedule. I made sure to
15
stay in line and not disobey him. I was in complete denial.
16
Being paid after every scheduled meeting felt routine and
17
disgusting. He was the master of the universe and the world
18
bent to his will.
19
He would eventually brag to his assistants about my
20
ability to please him sexually right in front of me, leaving me
21
feeling grotesque and worthless. Everything in my outside life
22
was falling apart. I distanced myself from friends and grew
23
further away from my family. I felt less human after each
24
ordeal. My psyche broke down completely and wouldn't let me
25
continue.
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One day I walked out of his residence and passed a
2
girl similar to myself. When I turned around, she was entering
3
Jeffrey's residence. He no longer even tried to schedule his
4
appointments with other girls in secrecy from me. Maybe he
5
never did. I was too stupid to see.
6
My world shattered. I had been so naive. I had an
7
epiphany in a calvary of desperation. I realized I was just
8
one of many young girls he had in rotation come to perform for
9
him for money. I went into a deep depression and never lifted
10
completely. I wanted to inflict pain on myself. I was
11
humiliated, angry, and suicidal. I locked myself away from
12
everything. I cut myself off forever from the world I had
13
known.
14
I endured the daily agony of knowing my life would
15
never be the same. I could never go back to New York City and
16
the wonderful life I had taken for granted before I met this
17
demon named Jeffrey Epstein.
18
This creature had manipulated and outwitted the whole
19
system, including some of the most intelligent scientists,
20
political people, prosecutors, and power players. How easy was
21
it to manipulate a 16-year-old virgin who never had a boyfriend
22
and came from a background of hardship with no parental
23
guidance or support.
24
I went to therapy and was given antidepressants for
25
severe anxiety and depression. My only solace, years later,
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was my desire to succeed on my own terms. I emersed myself
2
into my studies and was accepted to every college I applied to,
3
graduating from a top university. To this day, there is still
4
an ache in my being that I did not apply to Harvard in fear of
5
his influence there.
6
They say you never forget your first. I'm in a
7
never-ending nightmare trying to do just that. I'm forever
8
suffering because everything reminds me of that horror. This
9
new wave of worldwide publicity only worsens my despair.
10
It was only many years later that I was finally
11
intimate with a man again, and those moments were marred by my
12
actions as a child with Jeffrey Epstein. Even now is
13
impossible to separate his treachery from any care of a good
14
man.
15
For one brief moment there was elation when he was
16
recently arrested. I would finally get my chance to see him
17
again face to face and show him what I had become, that I had
18
succeeded on my own, that I was worth something in spite of his
19
abuse, and that I had surmounted the monumental obstacles he
20
laid before me throughout my entire life since falling prey to
21
him.
22
I had hoped humanity would prevail, but it seems to me
23
that he outsmarted everyone so far, and his ghost is still
24
laughing at us. I appeal to all of those just and true that
25
his evil legacy and his death not stand in the way of
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resolution and justice for all of his underaged victims.
2
Thank you, your Honor.
3
And then just one last one, and this is much shorter.
4
Statement of Jane Doe, also my client.
5
I was a model in another country when I came to the
6
United States. I was told by a booker that I needed to meet
7
with a man named Jeffrey Epstein, who was the owner of
8
Victoria's Secret. The booker told me that Mr. Epstein could
9
help me get into Victoria Secret's world.
10
It was my childhood dream to be a Victoria's Secret
11
model. So I went one day in the afternoon and I met
12
Mr. Epstein in his office in his mansion in New York. A woman
13
introduced herself and suggested to me that I should be
14
extremely nice to Mr. Epstein, because if he liked me, he would
15
probably have photographers shooting photos of me right away.
16
The told me to go upstairs and directed me to Jeffrey
17
Epstein's office. Mr. Epstein had a white robe on and we
18
chatted very briefly. I had my portfolio of photos, but he
19
didn't even look at it. Suddenly, he took his robe off and got
20
close to me. I got up to leave, but the door was locked.
21
I didn't know what was going on. It was my first
22
official meeting to be cast in the United States. I was a
23
young girl and confused. He got very close to me, and I had a
24
skirt on.
25
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2
At that point, I ran to the door again and figured out
3
how to get out of there. A girl outside asked me where I was
4
going and she said to be careful. She said that Mr. Epstein
5
knew a lot of powerful people, including Bill Clinton, and that
6
if I didn't do what Mr. Epstein wanted, I would not be able to
7
have any job in the industry.
8
I was so scared. I couldn't wait to get out of there,
9
and I left. I took the train home. I had spent all of my
10
savings getting Victoria's Secret lingerie to prepare for what
11
I thought would be my audition. But instead, it seemed like a
12
casting call for prostitution. I felt like I was in hell.
13
Thank you, your Honor.
14
Thank you.
15
THE COURT: Thank you, Ms. Allred.
16
Was there anybody else, any victim's counsel or any of
17
the other victims who have not been heard and wish to be heard?
18
Well, OK then. All I have to say, really, is thank
19
you, all of you, for your participation in today's remarkable
20
hearing. I think everybody has benefited greatly from your
21
input, and especially from the testimony of victims here today
22
and who have had the courage to come forward.
23
We have also benefited throughout these proceedings,
24
however brief altogether, from the attorneys' legal advocacy
25
and their written and oral submissions. I'm grateful to them
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as well, both for the government and the defense and those
2
representing the victims.
3
Finally, we're also grateful to the press for their
4
very diligent coverage of seemingly every detail of this case.
5
That concludes our work for today and we stand
6
adjourned.
7
Thanks.
8
(Adjourned)
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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